WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning five individuals and one entity for their role in generating illicit revenue for the Democratic People’s Republic of Korea (DPRK) government’s weapons of mass destruction (WMD) and ballistic missile programs, including by selling weapons to the Burmese military regime.
“North Korea’s unlawful weapons programs are a direct threat to America and our allies. At Treasury, we will continue to dismantle the financial networks that sustain them” said Under Secretary for Terrorism and Financial Intelligence John K. Hurley.
This targeted action focuses on overseas representatives of DPRK government agencies who are key to the regime’s ability to finance its unlawful WMD and ballistic missile programs: the Korea Mining Development Trading Corporation (KOMID) and the Reconnaissance General Bureau (RGB), both of which are designated by the United Nations and OFAC. KOMID, also known as “221 General Bureau,” serves as the DPRK’s primary arms dealer and is the principal exporter of goods, including critical equipment for ballistic missiles and conventional weapons. The RGB orchestrates military and intelligence operations for the DPRK regime. Both KOMID and the RGB maintain offices and representatives in numerous countries around the world, setting up front companies to disguise foreign currency earnings, which are then illicitly funneled back to Pyongyang.
Today’s designation also includes a key network facilitating weapons deals between KOMID and the Burmese military regime. Since the Burmese military’s February 1, 2021 coup that overthrew the country’s democratically elected government, the military regime has relied on indiscriminate aerial and artillery attacks during its military operations against resistance groups. Consequently, military airstrikes affecting infrastructure—including schools, religious sites, and hospitals—have led to many civilian deaths. Today’s action disrupts these weapons sales to Burma, cutting off an important funding stream for the DPRK regime.
BURMESE ARMS PROCUREMENT NETWORK
Royal Shune Lei Company Limited (Royal Shune Lei) is a Burmese arms procurement company that first brokered a weapons deal with KOMID for the Burmese military in 2022. In order to facilitate additional sales for KOMID, since late 2023, Royal Shune Lei employee Kyaw Thu Myo Myint and CEO Tin Myo Aung traveled to China to have multiple business meetings with KOMID representatives. Royal Shune Lei employees also traveled to Beijing to secure visas for a Burmese delegation to visit the DPRK. Kim Yong Ju, the deputy KOMID representative in Beijing, worked with other KOMID representatives, Tin Myo Aung, and Kyaw Thu Myo Myint, to coordinate the sales of two types of aerial bomb guidance kits, in addition to bombs and airborne monitoring equipment, for the Burmese Air Force via Royal Shune Lei. KOMID supplied samples of the aerial bomb guidance kits to Royal Shune Lei for testing and in order to finalize Royal Shune Lei’s order of weapons and related equipment. Aung Ko Ko Oo is a director of Royal Shune Lei.
Royal Shune Lei and Kyaw Thu Myo Myint are being designated pursuant to Executive Order (E.O.) 13551 for having attempted to, directly or indirectly, provide training, advice, or other services or assistance, or engage in financial transactions, related to the manufacture, maintenance, or use of any arms or related materiel to be imported, exported, or reexported to, into, or from North Korea, or following their importation, exportation, or reexportation to, into, or from North Korea. Royal Shune Lei and Kyaw Thu Myo Myint are also being designated pursuant to E.O. 14014 for operating in the defense sector of the Burmese economy. Royal Shune Lei was also designated by Canada and the United Kingdom in October 2024 and by the European Union in December 2023.
Tin Myo Aung and Aung Ko Ko Oo are being designated pursuant to E.O. 13551 for having acted or purported to act for or on behalf of, directly or indirectly, Royal Shune Lei, a person whose property and interests in property are blocked pursuant to E.O. 13551, and pursuant to E.O. 14014 for being or having been leaders or officials of Royal Shune Lei, an entity whose property and interests in property are blocked pursuant to E.O. 14014 as a result of activities related to the leader’s or official’s tenure.
Kim Yong Ju is being designated pursuant to E.O. 13687 for having acted or purported to act for or on behalf of, directly or indirectly, KOMID, an entity whose property and interests in property are blocked pursuant to E.O. 13687.
DPRK RECONNAISSANCE GENERAL BUREAU REPRESENTATIVE
Nam Chol Ung is an intelligence officer and representative of U.S.-designated DPRK Reconnaissance General Bureau (RGB) who has been engaged in multiple overseas revenue generation schemes on behalf of the DPRK government since at least 2013. Nam Chol Ung has built a sprawling network consisting of multiple companies and restaurants in Laos and Thailand, including a resort, and he uses his businesses to launder foreign currency earnings for the regime. This includes import-export companies that are involved in smuggling DPRK-made tobacco products to Southeast Asian countries. Nam Chol Unghas also forged trade contracts for importing goods into the DPRK, including for OFAC-designated Korea Sobaeksu United Corporation.
Nam Chol Ung is being designated pursuant to E.O. 13551 for having acted or purported to act for or on behalf of, directly or indirectly, the RGB, a person whose property and interests in property are blocked pursuant to E.O. 13551.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person. Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions.
Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions. OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person who is designated pursuant to the relevant authority.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons List (SDN List), but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, or to submit a request, please refer to OFAC’s guidance on Filing a Petition for Removal from an OFAC List.
Click here for more information on the persons designated today.