Too Tight! OFAC creates 9 loopholes in DPRK sanctions

With such far-reaching sanctions, the new Executive Order with respect to North Korea needed to have some carve-outs. In fact, there are nine:

  • General License 1 – permits transactions for the DPRK UN mission, as well as to the mission’s employees and their families
  • General License 2 – authorizes provision of certain legal services and advice
  • General License 3 – permits the charging of service fees for blocked accounts
  • General License 4 – authorizes no commercial personal remittances
  • General License 5 – authorizes certain services provided by non-governmental organizations (NGOs)
  • General License 6 – authorizes payments for third-country diplomatic missions and consulates located in North Korea
  • General License 7 – authorizes mail and telecommunications transactions
  • General License 8 – authorizes transactions related to intellectual property (patents, trademarks and copyrights)
  • General License 9 – authorizes provision of emergency medical services

The licenses will be added to the Licenses page.

Links:

General License 1

General License 2

General License 3

General License 4

General License 5

General License 6

General License 7

General License 8

General License 9

 

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