The Laundry Man by Kenneth Rijock ( Penguin/Random House UK)

Saturday, July 1, 2017


 The US Treasury's Notice of Proposed Rulemaking, filed against the Bank of Dandong, for assisting the DPRK (North Korea) in its illegal weapons programs, and for assisting in sanctions evasion, is a wake-up call for compliance officers who bank customers are conducting transactions with ANY Chinese financial institution. The Treasury Notice states that the Bank is a "financial institution of Primary Money Laundering Concern," which means that it will be denied access to the US financial structure. Readers who wish to review the Notice may access the complete text here.

Dandong is not the only Chinese bank that is assisting North Korea in evading US and global sanctions; it is just the first one named & shamed. There are indications that other Chinese financial institutions will be identified, and most likely, sanctioned in some way. If your bank clients are trading with Chinese companies, especially in manufacturing, where DPRK-made goods have been identified as having "Made in China" labels, the risk levels of your clients unwittingly importing North Korean goods should be examined, and appropriate action taken with the client, where you suspect North Korea is circumventing sanctions, up to and including account closing, and the filing of SARs.

Given the Trump Administration's hard-line attitude towards North Korea, which is completely justified, in my humble opinion, you can expect more sanctions, and you certainly do not want to be banking any American company exposed as a willing participant in the Chinese charade, when its Chinese bank facilitates evasion, through the use of their US correspondent accounts, to repatriate North Korean profits. Pay particular attention to Chinese banks in the north of China; the Bank of Dandong is literally at North Korea's doorstep.

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