WATCH FOR TRANSACTIONS WITH CHINESE BANKS, AFTER DOJ DISCLOSES US BANK TARGETED

Buried in the news about North Korea is the disclosure that the Department of Justice is looking at transactions at eight major US banks, for the purpose of locating, and seizing, transfers involving Chinese banks who are fronting for North Korea, which is the subject of major American sanctions. US-based Compliance officers would be well advised to examine any substantial payment being directed to Chinese banks, located in the northern portion of the country, to rule out hidden transfers destined for North Korea. A possible rule of thumb: the closer to the Yalu River (PRC-DPRK border), the bank is, the more you should trot out your enhanced due diligence specialist. Does the bank's business include North Korea ?

Be always alert for any possibility that your bank client is buying goods, which are ostensibly of Chinese manufacture, and even marked "Made in China," but truly crafted in the DPRK, and shipped through China. Do your client's "Chinese" purchases constitute goods that are known to have been manufactured in North Korean factories in the past ? If there are a number of Red Flags, you may want to being in an expert in the precise field, to consult with, to render an opinion on the issue.