October 25, 2018: OFAC adds to DPRK sanctions, amends counter terror listings

On Thursday, OFAC added the following person: 

TAN, Wee Beng, 51 Siang Kuang Avenue, Singapore; DOB 14 Feb 1977; Gender Male; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Director of Wee Tiong (S) Pte Ltd; Managing Director of WT Marine Pte Ltd (individual) [DPRK].

entities: 

WEE TIONG (S) PTE LTD (a.k.a. WEE TIONG S PTE LTD), 1813 Geylang Bahru, #01-01 Kallang Distripark 339715, Singapore; 64D Kallang Pudding Road, #02-00, Wee Tiong Building 349323, Singapore; 02-00 Wee Tiong Building, 64D, Kallang Pudding Road 349323, Singapore; 1805 Geylang Bahru #01-03 339711, Singapore; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Registration Number 199308567K [DPRK]. 
 
WT MARINE PTE LTD, #11-09 Parkway Parade 449269, Singapore; 64D Kallang Pudding Road, #09-00 Wee Tiong Building 349323, Singapore; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Registration Number 201616714Z [DPRK].

and vessels: 

JW JEWEL Singapore flag; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Vessel Registration Identification IMO 9402964 (vessel) [DPRK] (Linked To: WT MARINE PTE LTD). 
 
NYMEX STAR Singapore flag; Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Vessel Registration Identification IMO 9078191 (vessel) [DPRK] (Linked To: WT MARINE PTE LTD).

to the SDN List under the North Korea sanctions program.

Additionally, they amended the following counter terrorism (and Iran) sanctions listings:

OWHADI, Mohammad Ebrahim (a.k.a. OWHADI, Jalal; a.k.a. TAHERI, Jalal; a.k.a. VAHEDI, Jalal), Iran; DOB 1963; Gender Male (individual) [SDGT] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: TALIBAN). -to- OWHADI, Mohammad Ebrahim (a.k.a. OWHADI, Jalal; a.k.a. TAHERI, Jalal; a.k.a. VAHEDI, Jalal), Iran; DOB 1963; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male(individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: TALIBAN). 
 
RAZAVI, Esma’il (a.k.a. MOHAJERI, Mostafa), Iran; DOB 1959; Gender Male (individual) [SDGT] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: TALIBAN). -to- RAZAVI, Esma’il (a.k.a. MOHAJERI, Mostafa), Iran; DOB 1959; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE; Linked To: TALIBAN).

And the Treasury Department issued the following press release:

Treasury Designates Singapore-Based Targets for Laundering Money in Support of North Korea

 
October 25, 2018

WASHINGTON – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced North Korea-related designations of two entities and one individual, continuing the implementation of existing sanctions.  In a related action, today the U.S. Department of Justice unsealed criminal charges against the same individual, Tan Wee Beng.  Today’s action highlights North Korea’s continued illicit use of the financial system to circumvent sanctions, as well as the U.S. Government’s commitment to safeguard the international financial system and implement existing UN Security Council (UNSC) resolutions.  Today’s action also makes clear that the United States will not hesitate to impose sanctions on any individual, entity, or vessel supporting North Korea’s illicit activities, regardless of nationality.

“Tan Wee Beng and his co-conspirators made deliberate efforts to launder money through the U.S. financial system on behalf of North Korea,” said Secretary Steven T. Mnuchin.  “Governments, financial institutions, and other companies worldwide need to be on high alert to these types of schemes.  The U.S. government will not overlook these deceptive practices.  We are deeply committed to the final, fully verified denuclearization of North Korea, and Treasury will continue to enforce and implement sanctions until that time.”

OFAC designated Singapore-based Tan Wee Beng, Wee Tiong (S) Pte Ltd, and WT Marine Pte Ltd pursuant to E.O. 13551 for having, directly or indirectly, engaged in money laundering, the counterfeiting of goods or currency, bulk cash smuggling, narcotics trafficking, or other illicit economic activity that involves or supports the Government of North Korea or any senior official thereof. 

Tan Wee Beng is a director and significant shareholder of Wee Tiong (S) Pte Ltd, a Singapore-based commodities trading company.  Over several years, dating back to at least 2011, Tan Wee Beng and at least one other individual in his company fulfilled millions of dollars in commodities contracts for North Korea.  To do so, Tan Wee Beng made a concerted effort to obfuscate payment origins and structure transactions to avoid regulatory scrutiny.  Tan Wee Beng and his co-conspirators also knew of and took efforts to evade financial sanctions on North Korea.  In at least one instance, when a wire payment was rejected, Tan Wee Beng and Wee Tiong (S) Pte Ltd orchestrated payment in bulk cash, hand-delivered to a North Korean. 

OFAC also designated WT Marine Pte Ltd, a marine fuels company closely related to Wee Tiong (S) Pte Ltd, and of which Tan Wee Beng is the Managing Director.  Last year, the JW JEWEL (IMO: 9402964) and NYMEX STAR (IMO: 9078191), vessels operated and managed by WT Marine Pte Ltd, engaged in illicit economic activity that involves or supports the Government of North Korea. 

Many of the activities undertaken by Tan Wee Beng and his associated companies are the types of activities that were highlighted in the November 2, 2017 Advisory on North Korea’s  Use of the International Financial System published by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).  Most notably, today’s designations illustrate Treasury’s previous warnings regarding North Korea’s use of third-country companies to divide their payments into smaller outflows in complex layering schemes directed through front companies, shell companies, and shipping or trade businesses elsewhere in Asia.  Moreover, North Korean financial representatives use third-country corporate service providers to establish the front or shell companies and use these companies to open bank accounts to access the U.S. and international financial systems.  Tan Wee Beng’s role in Wee Tiong (S) Pte Ltd and WT Marine Pte Ltd is also indicative of how North Korea-linked financial facilitators often establish and use multiple companies with the same owners or managers.  These companies also frequently share addresses, telephone numbers, and employees, and they may transact with similar business partners.  Additional questions or comments regarding the contents of the November 2, 2017 advisory should be addressed to the FinCEN Resource Center at FRC@fincen.gov.

Moreover, UNSC resolution 1718 (2006) prohibits transactions with designated entities who subject to an asset freeze.  In Resolution 2375 (2017) the UNSC decided that all Member State shall prohibit their nationals, persons subject to their jurisdiction, entities incorporated in their territory or subject to their jurisdiction, and vessels flying their flag from facilitating or engaging in ship-to-ship transfers to or from Democratic People’s Republic of Korea (DPRK)-flagged vessels of any goods or items that are being supplied, sold, or transferred to or from the DPRK.

As a result of today’s action, any property or interests in property of the designated persons, including the two vessels, in the possession or control of U.S. persons or within the United States is blocked, and U.S. persons generally are prohibited from dealing with the designated persons. 

Links:

OFAC Notice

Treasury Press Release

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