Company Fined for North Korea Sanctions Violations

A Vietnam-based holding company settled OFAC charges for financial transactions involving the sale of alcohol to North Korean entities in violation of US sanctions. 

According to OFAC, the company's subsidiaries sold alcoholic beverages through 26 contracts to North Korean entities. OFAC stated that payments for these sales, totaling approximately $1.14 million, were made in US dollars and processed through US financial institutions. OFAC found that during the relevant period, the subsidiaries issued 47 invoices for shipments to North Korean customers. OFAC said the transactions were processed through 15 third-party companies in Hong Kong, Singapore, and the Seychelles, and involved US correspondent banks. 

OFAC found that these payments constituted an unlawful export of financial services to North Korea. As a result, OFAC said the company violated Sections 510.206 ("Prohibited exportation or reexportation of goods, services, or technology to North Korea") and 510.212 ("Evasions; attempts; causing violations; conspiracies") of the North Korea Sanctions Regulations. 

To settle the charges, the company agreed to pay a $860,000 civil monetary penalty. OFAC said the settlement amount reflected the company's cooperation, "including its proactive notification to OFAC of its internal findings, and [] remedial measures implemented after discovering the apparent violations."