Democratic People's Republic of Korea sanctions: guidance

Question 1

1. Prohibitions and requirements imposed by the Democratic People’s Republic of Korea (Sanctions) (EU Exit) Regulations 2019

Accepted Answer

The Regulations impose financial, trade, aircraft, shipping and immigration sanctions for the purpose of giving effect to the United Kingdom’s obligations under United Nations Security Council Resolutions including 1718 (2006), 1874 (2009), 2087 (2013), 2094 (2013), 2270 (2016), 2321 (2016), 2356 (2017), 2371 (2017), 2375 (2017) and 2397 (2017) (‘UNSCR 1718’, ‘UNSCR 1874’, UNSCR 2087’, ‘UNSCR 2094’, UNSCR 2270’, ‘UNSCR 2321’, ‘UNSCR 2356’, ‘UNSCR 2371’, ‘UNSCR 2375’, ‘UNSCR 2397’); and the additional statutory purposes set out in the Regulations. As a whole this sanctions regime is aimed at restricting the ability of the Democratic People’s Republic of Korea (DPRK) to continue with its WMD programmes, encouraging them to abandon those programmes and to decommission weapons in accordance with decisions of the UN Security Council, and promoting peace, security and stability on the Korean peninsula.

In order to achieve the stated purposes, the Regulations impose a number of prohibitions and requirements. In order to enforce these, the Regulations establish penalties and offences, which are set out in detail in the corresponding report under section 18 of the Sanctions Act in relation to criminal offences.

The prohibitions and requirements imposed by the Regulations apply within the territory of the United Kingdom (UK) (including Northern Ireland) and in relation to the conduct of all UK persons wherever they are in the world. UK persons includes British nationals, as well as all bodies incorporated or constituted under the law of any part of the UK. Accordingly, the prohibitions and requirements imposed by the Regulations apply to all companies established in any part of the UK, and they also apply to branches of UK companies operating overseas.

The maritime enforcement powers contained in Part 12 of the Regulations apply in relation to British ships in international or foreign waters, ships without nationality in international waters and foreign ships in international waters.

It is prohibited to intentionally participate in any activities if you know that the object or effect of them is directly or indirectly to circumvent the prohibitions imposed by the Regulations or to enable or facilitate the contravention of those prohibitions.

If you are unclear about any aspect of the Regulations, in particular about whether action you are considering taking could contravene the Regulations, you are advised to seek independent legal advice.

The financial, trade, aircraft, shipping and immigration sanctions contained in the Regulations are set out below.

1.1 Designation of persons

The Regulations provide that the Secretary of State may designate persons for the purposes of financial and/or immigration and/or certain trade and shipping sanctions if they are, or have been, involved in a relevant activity (as defined in regulation 6).

The Regulations also provide that each person for the time being named by the United Nations Security Council or Sanctions Committee for the purposes of paragraph 8(d) of UNSCR 1718 is a designated person for the purposes of the financial, trade and shipping sanctions.

Persons subject to a travel ban under UNSCR 1718 are not captured by the Regulations. For further information, please refer to the Immigration Sanctions section below.

The UK Sanctions List lists the people designated under the Regulations, and details of the sanctions in respect of which they have been designated.

1.2 Financial sanctions

Asset freeze and making available provisions

The Regulations impose financial sanctions through a targeted asset freeze on designated persons and prohibitions on making funds or economic resources available. This involves the freezing of funds and economic resources (non-monetary assets, such as property or vehicles) of designated persons and ensuring that funds and economic resources are not made available to or for the benefit of designated persons, either directly or indirectly.

More information on financial sanctions can be found in the OFSI guidance.

OFSI is the authority responsible for implementing the UK’s financial sanctions on behalf of HM Treasury. OFSI helps to ensure that financial sanctions are properly understood, implemented and enforced in the UK. Further information on how OFSI implements financial sanctions can be found on the OFSI pages of GOV.UK.

Investment and financial services and markets

The Regulations also impose sectoral sanctions, by restricting certain investment and financial services activities and access to markets.

Some of these restrictions relate to dealings with credit or financial institutions domiciled in the DPRK, their branches and subsidiaries (wherever located) and other credit or financial institutions not domiciled in the DPRK but owned or controlled by persons domiciled there (DPRK-connected credit or financial institutions).

The Regulations, for example, impose restrictions on UK credit or financial institutions establishing a banking or correspondent banking relationship with DPRK-connected credit or financial institutions, or on opening representative offices or establishing branches or subsidiaries in the DPRK. UK credit or financial institutions must also sever existing financial relationships with DPRK-connected credit or financial institutions, such as terminating joint ventures and relinquishing ownership interests. Nor can a UK credit or financial institution open a bank account for DPRK diplomatic missions or a DPRK diplomat.

There are restrictions relating to branches, subsidiaries and representative offices of DPRK-connected credit or financial institutions, such as on the opening of representative offices or branches in the UK. It is also prohibited for DPRK-connected credit or financial institutions to acquire or extend any ownership interests in UK credit or financial institutions and prohibited for any person to participate in joint ventures and other business arrangements with a designated person.

The Regulations also impose sectoral restrictions prohibiting persons from accepting or approving investments in commercial activities where the investment is made by the Government of the DPRK, DPRK nationals and companies and others acting on their behalf or owned or controlled by such persons. These sectoral restrictions also include accepting or approving investments and prohibitions on the provision of financial services with and making funds available to such persons (with the exception of DPRK nationals), joint ventures and ownership interests with such persons. It is also prohibited for any person to transfer any funds to, or receive funds from, the DPRK.

Any sale or purchase of certain bonds must not be made to or from the DPRK Government, Central Bank or DPRK-connected credit or financial institutions. Nor must any person provide brokering, advertising or other services which assist the DPRK Government and other bodies to issue such bonds.

There is a prohibition on the leasing to, or otherwise making available of any land to, the Government of DPRK, any member of the Government of DPRK, or anyone that is known or suspected of acting on behalf of the Government of DPRK, or leasing any land from such a person.

Insurance or reinsurance in relation to ships is prohibited, where that ship is owned, controlled or operated by a person connected with the DPRK, if it is registered with the DPRK, flying the flag of DPRK or is a “specified” ship under regulation 11(1) or (2).

1.3 Trade sanctions

The Regulations impose trade prohibitions relating to:

military goods and military technology (as specified in Schedule 2 to the Export Control Order 2008)
any thing which falls within Chapter 93 of the Goods Classification Table^{[footnote 1]}, other than military goods
dual-use goods and technology (as specified in Annex I to Council Regulation 428/2009 as retained by the European Union (Withdrawal) Act 2018 (‘the Dual-Use Regulation’))
other arms- and WMD-related goods and technology (specified in Schedule 2 of the Regulation and in a number of lists adopted by the UN, as set out at regulation 64)
goods and technology for the armed forces of DPRK, as set out in regulation 43
“armed forces goods” and “armed forces technology”, as defined in regulation 44
certain other goods - namely aviation fuel; condensates and natural gas liquids; crude oil; helicopters and vessels; industrial machinery, vehicles, iron, steel and other metals; luxury goods; and refined petroleum products; coal, iron and iron ore; copper, nickel, silver and zinc; earth and stone; food and agricultural products; gold ores and concentrates, titanium ore, vanadium ore and rare-earth minerals; lead and lead ore; machinery and electrical equipment; petroleum products; seafood; statues; textiles and wood
fishing rights
bank notes and coinage
gold, precious metals and diamonds
provision of mining, manufacturing and computer services
the provision of certain services relating to ships and aircraft

Many of these goods and services are specified by reference to annexes in EU Regulation 2017/1509 of 30 August 2017 concerning restrictive measures against the Democratic People’s Republic of Korea as in force immediately prior to IP completion day.

There are circumstances (set out in the relevant lists of controlled items) in which certain items are not controlled, for example when body armour or a helmet is accompanying a person for that person’s own protection. Please check the relevant lists as applicable.

Further detail on these trade prohibitions, including key terminology used, is explained below. Please have regard to the relevant legislation which contains full definitions of terms used herein.

Export of goods

The concept of ‘export’ is set out in customs legislation, but is further detailed in Paragraph 32 of Schedule 1 to the Sanctions Act, which clarifies that “export” means export from the UK, but does not capture where goods are removed to the Isle of Man from the UK.

The export prohibitions (other than in regulations 43, 44, 51 and 52) cover exports to DPRK as well as exports that are for use in DPRK. Regulation 43 covers exports to or for the benefit of the armed forces of the DPRK. Regulation 44 covers certain exports to the DPRK. Regulation 51 covers exports of bank notes or coinage to or for the benefit of the Central Bank of the DPRK. Regulation 52 covers exports of gold, precious metal or diamonds to a ‘DPRK Government person’ as defined in regulation 64(1). This means that, even if the immediate destination is not DPRK, the prohibition may still apply. Exporters should check the ultimate end use of goods and may apply for a licence or contact the Export Control Joint Unit (ECJU) if they know or think the items may be used in a way that would breach a prohibition.

A sanctions licence is not required for exports of non-military goods covered by the Regulations from Northern Ireland to an EU Member State where the final destination is the DPRK. You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the onward export to the DPRK. You will also have to comply with any other licensing requirements under UK export control legislation as applicable.

Import of goods

The concept of ‘import’ is set out in customs legislation, but is further detailed in Paragraph 33 of Schedule 1 to the Sanctions Act. This clarifies in particular that goods removed to the UK from the Isle of Man are not to be regarded as imported. Paragraph 34 details limited exceptions to this.

The import prohibitions (other than in regulation 52) cover imports that are consigned from DPRK and goods that originated in DPRK. Regulation 52 covers imports of gold, precious metal or diamonds consigned from a ‘DPRK Government person’ as defined in regulation 64(1). This means that even if the immediate place the goods were shipped from was not DPRK, the prohibition may still apply. Therefore, importers should check the original place and person goods were consigned from, and apply for a licence or contact the DIT Import Licensing Branch if they think the items may have originated in or have been consigned from DPRK.

A sanctions licence is not required for imports of non-military goods covered by the Regulations from an EU Member State which originate in or are consigned from the DPRK. You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the original import into the customs territory of the EU. You will also have to comply with any other licensing requirements under UK import control legislation as applicable.

Supply and delivery of goods

Supply and delivery prohibitions in the Regulations prohibit the direct or indirect supply or delivery of certain goods. Regulations 37 and 44 concern the movement of certain goods from a third country to a place in DPRK and from a place in DPRK to a third country. Regulation 43 covers movement of goods from a third country to or for the benefit of the armed forces of the DPRK. Regulation 46 covers the movement of certain goods from a third country to a place in the DPRK. Regulation 49 covers the movement of certain goods from a place in the DPRK to a third country. Regulation 51 covers movement of bank notes or coinage from a third country to or for the benefit of the Central Bank of the DPRK. Regulation 52 covers movement of gold, precious metals or diamonds from a third country to a ‘DPRK Government person’ as defined in regulation 64(1), and from a ‘DPRK Government person’ to a place in a ‘non-UK country’.

‘Third country’ and ‘non-UK country’ are defined in the relevant regulations.

Making available goods and technology

Prohibitions in regulations 38 and 47 on making restricted goods or technology available (e.g. through a sale) include directly or indirectly making them available for use in DPRK or to a person “connected with” DPRK. Regulation 43 covers making goods or technology available to or for the benefit of the armed forces of the DPRK. Regulation 44 covers making certain goods or technology available to a person connected with the DPRK. Regulation 51 covers making certain goods available to or for the benefit of the Central Bank of the DPRK. Regulation 52 covers making certain goods available to a ‘DPRK Government person’ as defined in regulation 64(1).

Regulation 2(2) sets out when a person is to be regarded as “connected with” DPRK.

Acquisition of goods and technology

Prohibitions in regulations 38 and 50 on acquiring certain goods or technology cover directly or indirectly acquiring them 1) from a person connected with the DPRK 2) where they originate in the DPRK or 3) where they are located in the DPRK. Regulation 44 concerns the direct or indirect acquisition of armed forces goods or armed forces technology 1) from a person connected with the DPRK or 2) located in the DPRK. Regulation 52 covers acquiring goods from a ‘DPRK Government person’ as defined in Regulation 64(1).

Acquisition or transfer of fishing rights

Regulation 50(3) prohibits the direct or indirect acquisition or transfer of fishing rights where these are from a person connected with the DPRK, or where they are exercisable in DPRK waters. ‘Fishing rights’ is defined in Regulation 50(7).

Transfer of technology

Prohibitions in the Regulations on the transfer of certain technology (other than in Regulation 43) include transfer to a place in DPRK or a person connected with DPRK. They also include transfer of restricted technology to persons outside the UK or to a place outside the UK, where the transfer is from a place in DPRK. Regulation 43 covers the transfer of technology to or for the benefit of the armed forces of the DPRK.

The term ‘transfer’ is defined in Paragraph 37 of Schedule 1 to the Sanctions Act, which states that it ‘means a transfer by any means (or combination of means), including oral communication and the transfer of goods on which the technology is recorded or from which it can be derived, other than the export of such goods.’

Where restricted technology is contained within a good, it would be classified as a restricted good under the accompanying goods-related provisions. This includes information contained on USB memory devices, laptops, tablets and the like.

Technical assistance

The term ‘technical assistance’ in relation to goods or technology is defined in regulation 64, which states that it means:

technical support relating to the repair, development, production, assembly, testing, use or maintenance of the goods or technology, or
any other technical service relating to the goods or technology

Prohibitions apply where the technical assistance relates to certain specified goods or technology.

The prohibitions at regulation 40 apply to the direct or indirect provision of such technical assistance (1) to persons connected with DPRK or (2) for use in DPRK; and to the procurement of such technical assistance (1) from persons connected with the DPRK or (2) for use in the DPRK.

This means that, even if the person to or from whom you are providing or procuring technical assistance, is not in or “connected with DPRK”, the prohibition may still apply if the goods or technology to which the technical assistance relates are for use in DPRK. Therefore, if you are providing or procuring technical assistance you should check whether the goods or technology may be used in DPRK and apply for a licence or contact ECJU if so.

Regulation 53 prohibits the direct or indirect provision of technical assistance relating to gold, precious metals or diamonds to a DPRK Government person.

‘Financial services’ refer to any services of a financial nature in many different forms including insurance and banking. Financial services include payment and money transmission services. The full definition of ‘financial services’ can be found in Section 61 of the Sanctions Act.

‘Funds’ means financial assets and benefits of every kind, including cash, securities and interest. The full definition of ‘funds’ can be found in Section 60 of the Sanctions Act.

Trade sanctions prohibitions on the provision of financial services and funds apply where they relate to certain specified goods or technology.

Prohibitions at regulation 41 prohibit the direct or indirect provision of financial services, and the direct or indirect making available of funds to persons connected with DPRK in pursuance of or in connection with specific arrangements set out in regulation 41(1). The Regulations also prohibit the direct or indirect procurement of financial services from a person connected with the DPRK in pursuance of or in connection with specific arrangements set out in regulation 41(1). This captures arrangements related to the goods or technology controlled by the Regulations, for example, an arrangement for the export of goods or the direct or indirect supply or delivery of goods.

These prohibitions also prohibit the direct or indirect provision of financial services or funds to anyone, and the procurement of financial services from anyone, where this is in pursuance of or in connection with specific arrangements, as set out in regulation 41(3). This captures arrangements the object or effect of which falls into one of the prohibitions, for example an arrangement for the export of restricted goods to or for use in the DPRK.

The Regulation also contains prohibitions at regulation 54 on the direct or indirect provision of financial services, and the direct or indirect making available of funds, to a DPRK Government person in pursuance of or in connection with specific arrangements set out at regulation 54(1). The Regulations also prohibit the direct or indirect provision of financial services or funds, to a DPRK Government person in pursuance of or in connection with arrangements set out at regulation 54(3).

In addition, regulation 57 prohibits the provision of financial services or funds for the purpose of trade with the DPRK. This does not apply to any provision of financial service or funds which is prohibited under Chapter 1 of Part 6, or elsewhere in Chapter 2 of Part 6, of the Regulations.

Brokering services

The definition of ‘brokering services’ is set out in Regulation 2, which states that it means any service to secure, or otherwise in relation to, an arrangement, including (but not limited to):

the selection or introduction of persons as parties or potential parties to the arrangement
the negotiation of the arrangement
the facilitation of anything that enables the arrangement to be entered into, and
the provision of any assistance that in any way promotes or facilitates the arrangement

The Regulations prohibit the direct or indirect provision of brokering services where they relate to specific arrangements. Those arrangements are set out in regulation 42.

The Regulation also contains prohibitions at regulation 55 on the direct or indirect provision of brokering services to a DPRK Government person, and prohibitions on the direct or indirect provision of brokering services in relation to arrangements set out at regulation 55(2).

Other service provisions

Certain other services are prohibited in the Regulations. These include the provision of mining, manufacturing and computer services, and services relating to certain ships and aircraft.

Prohibitions relating to mining and manufacturing services are set out in Regulation 56 and relate to the provision of services incidental to mining, or to manufacturing in certain industries, to a person connected with the DPRK or where the mining or manufacturing is carried on in the DPRK.

Prohibitions relating to computer and related services are also set out in Regulation 56 and relate to the provision of such services to or for the benefit of a person connected with the DPRK.

Prohibitions relating to the leasing or chartering of ships and aircraft and provision of crew services are set out in regulations 58 and 59. These relate to the provision of such services to designated persons, those acting on their behalf or direction, those owned or controlled (directly or indirectly) by them, and to persons connected with the DPRK. It is also prohibited to procure crew services from persons connected with the DPRK.

Prohibitions relating to ship classification services are set out in regulation 60 and relate to the provision of such services where they relate to ships specified under regulation 11(1) or (2), ships registered in the DPRK, or ships flying the flag of the DPRK.

Prohibitions relating to bunkering or ship supply services are set out in regulation 61 and relate to the provision of such services to ships specified under regulation 11(1) or (2).

DIT contact details

The Department for International Trade (DIT) has overall responsibility for trade sanctions licensing. For general guidance on export controls and trade sanctions, contact the Export Control Joint Unit:

email: exportcontrol.help@trade.gov.uk or tradesanctions@trade.gov.uk

helpline: +44 (0) 20 7215 4594

For general guidance on import controls and trade sanctions contact the Import Controls team:

email: importcontrols@trade.gov.uk

1.4 Immigration sanctions

The effect of the Regulations is to impose a travel ban on persons who are designated by the Secretary of State for the purposes of being made subject to immigration sanctions under the Sanctions Act. Such persons are excluded persons for the purposes of section 8B of the Immigration Act 1971.

Persons who are subject to existing designations by the UN Security Council or its Sanctions Committee under UNSCR 1718 for travel ban purposes are not additionally designated under the Regulations as they are already excluded persons for the purposes of section 8B of the Immigration Act 1971.

Individuals designated under either the Regulations or UNSCR 1718 will be refused leave to enter or remain in the UK. Any applications they make for a visa to travel to the UK, including for transit purposes, will be refused. Any foreign national who is subject to a travel ban under the Regulations or UNSCR 1718, and who is currently in the UK, will have their permission to stay in the UK cancelled and steps will be taken to remove them from the UK.

If you are the subject of an immigration sanction and try to travel to the UK, carriers are required to deny you boarding.

Further information on how the Home Office deals with those who are subject to a travel ban can be found on the Home Office pages of GOV.UK.

1.5 Transport sanctions

The Regulations impose transport prohibitions relating to:

the movement of ships and aircraft in UK waters and airspace, including entry into ports and landing in the UK
the ownership and control of ships
the asset freeze on vessels designated by the UN for that purpose
the registration of ships on the UK Ship Register
the registration of ships in the DPRK
ship-to-ship transfers of goods

The Department for Transport (DfT) is ultimately responsible for the implementation of these transport restrictions some of which are enforced through the Maritime and Coastguard Agency, the Civil Aviation Authority (CAA) and National Air Traffic Services Limited (NATS) and airport operators.

DfT also has overall responsibility for issuing licences allowing specific exceptions to these prohibitions.

Further details are available on how to apply for a transport sanctions licence.

1.6 Information and record keeping

For the purpose of the financial sanctions contained in the Regulations, Part 10 of the Regulations places obligations on relevant firms (the definition of which is set out in the Regulations) to report information to HM Treasury about known or suspected designated persons or about persons who may have committed an offence under specified provisions of the Regulations.

A relevant firm must inform the National Crime Agency without delay if, in the course of its business with specified categories of persons, it acquires information that leads it to know or reasonably suspect that a person is making available funds that could contribute to any of the DPRK’s banned weapons programmes.

It also grants powers to HM Treasury to request information from, amongst others, a designated person, including powers to request the production of documents. It also establishes offences for failing to comply with these requests (including for providing false information).

Part 10 also establishes information powers and record-keeping responsibilities in relation to the trade sanctions contained in the Regulations. It provides for offences for failing to comply with any of those requirements or intentionally obstructing an official in the exercise of those powers.

If you have obligations or responsibilities under Part 10 of the Regulations, it is important that you familiarise yourself with them. If you are unclear of your obligations or responsibilities, you are advised to seek independent legal advice.

Question 2

2. How will these sanctions measures be enforced?

Accepted Answer

The Regulations make it a criminal offence to contravene the finance, trade, aircraft and shipping sanctions. It is also an offence to enable or facilitate a contravention of, or to circumvent, the finance or trade sanctions, or the prohibitions on dealing with a ship subject to a UN asset freeze or on ship to ship transfers. They also prescribe the mode of trial and penalties that apply to such offences. In some cases, offences related to contraventions of prohibitions in the Regulations are contained within other legislation, such as the Customs and Excise Management Act 1979 (CEMA).

In addition to the below, further details on offences and penalties can be found in the corresponding report under section 18 of the Sanctions Act.

2.1 Financial sanctions

Breaches of financial sanctions are a serious criminal offence. Any breach of the main financial prohibitions in the Regulations is an offence that is triable either way and carries a maximum sentence on indictment of 7 years’ imprisonment or a fine (or both).

Offences under regulations 99(6), 101 or 104 (reporting obligations, proliferation financing and information offences in connection with financial sanctions under the Regulations) are summary offences only and carry a maximum sentence of 6 months’ imprisonment or a fine (which in Scotland or Northern Ireland may not exceed level 5 on the standard scale) or both.

OFSI is responsible for monitoring compliance with financial sanctions and for assessing suspected breaches. It also has the power to impose monetary penalties for breaches of financial sanctions and to refer cases to law enforcement agencies for investigation and potential prosecution.

OFSI works with other parts of government, supervisory bodies and regulators to consider all cases reported to it, sharing relevant information accordingly.

If you find out that a person or organisation you are dealing with is subject to the financial sanctions detailed in the Regulations, you must immediately:

stop dealing with them
freeze any assets you are holding for them
inform OFSI as soon as possible by either emailing ofsi@hmtreasury.gov.uk or by calling their general enquiries line: +44 (0)20 7270 5454

More detailed information on OFSI’s approach to compliance and enforcement can be found in Chapter 7 of OFSI’s guidance.

2.2 Trade sanctions

Any breach of the trade sanctions prohibitions in the Regulations is triable either way and carries a maximum sentence on indictment of 10 years’ imprisonment or a fine (or both). Any breach of the trade licensing provisions or information requirements in connection with general trade licences is also triable either way and carries a maximum sentence on indictment of 2 years’ imprisonment or a fine (or both).

HM Revenue and Customs (HMRC) is responsible for enforcing the licensing restrictions and investigating suspected offences.

If you discover that you have breached any of the trade prohibitions or licensing provisions, you should report the irregularity to HMRC (sometimes known as ‘voluntary disclosure’) as soon as possible. If the irregularity was found in an Export Control Joint Unit compliance audit, the compliance inspector will have informed HMRC and you are strongly advised to do the same. Guidance is available on how to make a voluntary disclosure.

2.3 Transport sanctions

Transport sanctions are integral to the enforcement of the overall sanctions regime. There are serious offences associated with breaching the principal transport restrictions; these are triable either way and carry a maximum sentence of 7 years’ imprisonment or a fine (or both).

Where the conditions on which a transport sanctions licence has been issued are broken, the offence is triable either way and those found to be culpable can be imprisoned for up to a maximum of 2 years, receive a fine, or both.

Failure to comply with directions in relation to ships and aircraft is also an offence under the Regulations.

The Department for Transport (DfT) takes an overview of the enforcement of transport sanctions, some of which will involve the Secretary of State issuing directions. The implementation of the shipping and aircraft directions is carried out, where relevant, by the Maritime and Coastguard Agency, the CAA, NATS, airport operators and harbour authorities.

Where necessary, specific cases will be referred to other relevant enforcement bodies such as the Police or HMRC to ensure that effective action can be taken.

If you become aware that a breach of the transport sanctions detailed in the Regulations has taken or will take place, then you must report it as soon as possible by calling DfT on 020 7944 5999 and by emailing transportsanctions@dft.gov.uk.

Question 3

3. Are there circumstances when I can get an authorisation or licence for a sanctioned activity?

Accepted Answer

Licencing, exception and direction provisions are contained in Part 9 of the Regulations.

3.1 Exceptions

The Regulations set out exceptions to some of the sanctions prohibitions which apply within certain defined circumstances. An exception applies automatically, and does not require you to obtain a licence issued in accordance with the Regulations.

The Regulations establish exceptions relating to financial sanctions including for the crediting of a frozen account by a relevant institution (any such interest or other earnings will be frozen in accordance with the relevant legislation underpinning the asset freeze). An exception also exists from the prohibition on making funds available to a designated person, when funds are transferred to a frozen account in discharge (or partial discharge) of an obligation which arose before the recipient became a designated person.

Exceptions are also in place for conducting transactions with the Foreign Trade Bank of the DPRK or with the Korean National Insurance Company, if the transaction is for the sole purpose of the operation of a diplomatic mission or consular post in the DPRK, or humanitarian assistance activities undertaken by, or in co-ordination with, the UN.

For one limited category of designated persons (certain entities of the Government of the DPRK or the Workers’ Party of Korea), the asset-freeze provisions do not apply to actions necessary for the operation of any DPRK mission to the UN and other diplomatic missions and consular posts of the DPRK.

It is permitted to lease or make available property to the Government of the DPRK for diplomatic missions or consular posts. The prohibition on activities linked to the use of land does not apply to the provision of goods or services which are necessary for the operation of a diplomatic mission or consular post as long as they cannot be used to generate income or profit, directly or indirectly, for the Government of the DPRK.

An exception exists for transfers of funds in relation to transactions amounting to a value of £13,000 or less:

related to foodstuffs, healthcare or medical equipment
for agricultural and humanitarian purposes
which fall within a specified exception set out in Part 9 of the Regulations or which is permitted under a Treasury issued licence or a Trade licence issued under part 9
related to trade activities which are not prohibited by Part 6 of the Regulations
for the official purposes of a diplomatic or consular mission of the DPRK
required exclusively for development projects addressing the needs of the civilian population or promotion of denuclearisation of the DPRK, which are funded by any part of the UK government

The Regulations include an exception for making or receiving a transfer of funds with a value of £4,000 or less for a personal remittance.

Exceptions are also in place for transferring funds for the official purposes of a diplomatic mission or consular post in the DPRK, or an international organisation that has immunities in the DPRK in accordance with international law.

The Regulations establish exceptions relating to trade sanctions. These are contained in regulation 84.

There are exceptions for the export, supply, delivery or making available of aviation fuel in a third country, for consumption by a civilian passenger aircraft flying to or from the DPRK.

The prohibitions on the import, export, supply, delivery, making available or acquisition of luxury goods do not apply in relation to the personal effects of someone travelling to or from the DPRK, or non-commercial goods for personal use contained in their luggage. They also do not apply to goods which are necessary for the official purposes of a diplomatic post or consular mission in the DPRK, or international mission enjoying immunities in the DPRK; or the personal effects of a member of a diplomatic mission or consular post in the DPRK.

The prohibition on the provision of computer and related services does not apply where those services are provided for the official purposes of a diplomatic mission or consular post in the DPRK, or international mission enjoying immunities in the DPRK. They also do not apply where they are provided by persons that receive funding from any part of the UK government to provide them for development projects addressing the needs of the civilian population or the promotion of denuclearisation of the DPRK.

The prohibitions on the provision of bunkering or ship supply services do not apply where a failure to provide those services would endanger the lives of persons on board a ship.

The Regulations establish exceptions relating to transport sanctions. An aircraft which is normally prohibited from overflying or landing in the UK is allowed to do so if failing to land would endanger the lives of persons on board or the safety of the aircraft itself. A ship which is normally prohibiting from entering UK ports is allowed to enter in the case of an emergency or if a direction to that effect has been issued to the master or pilot.

Regulation 86A establishes an exception for certain conduct in the Channel Islands, Isle of Man or any British Overseas Territory where the conduct is authorised by a licence, direction or other authorisation issued under the corresponding law in the relevant jurisdiction.

There is an exception to regulations 13 to 17 in respect of “relevant activity” (being any activity which would otherwise be prohibited by regulations 13 to 17) which is necessary to ensure the timely delivery of humanitarian assistance or to support other activities that support basic human needs by:

(a) the United Nations, including its—

(i) programmes and funds,
(ii) other entities and bodies, and
(iii) specialised agencies and related organisations,

(b) international organisations,

(c) humanitarian organisations having observer status with the United Nations General Assembly and members of those humanitarian organisations,

(d) bilaterally or multilaterally funded non-governmental organisations participating in the United Nations Humanitarian Response Plans, Refugee Response Plans, other United Nations appeals, or humanitarian clusters coordinated by the United Nations Office for the Coordination of Humanitarian Affairs,

(e) any grantee, subsidiary, or implementing partner of any organisation falling within sub-paragraphs (a) to (d) while and to the extent that they are acting in those capacities (reference in the regulations to an organisation (or entity) includes reference to the employees of that organisation while acting in that capacity),

(f) any other persons authorised by the Committee for the purposes of resolution 2664.

This exception means the prohibitions of the asset freeze are not contravened by a person carrying out relevant activity which is necessary to ensure the timely delivery of humanitarian assistance or to carry out other activities that support basic human needs. This includes the provision, processing and payment of funds, other financial assets or economic resources, and the provision of goods and services necessary to ensure the timely delivery of such assistance or to support such activities.

The prohibitions of the asset freeze are not contravened where the person undertaking the relevant activity believes carrying it out is necessary to ensure the timely delivery of humanitarian assistance, or to carry out other activities that support basic human needs and there is no reasonable cause for them to suspect otherwise.

The Regulations also include an exception in relation to any prohibition or requirement imposed by the Regulations for actions which a responsible officer has determined to be in the interests of national security, or the prevention or detection of serious crime in the UK or elsewhere.

If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.

3.2 Licensing for financial sanctions

Where a person is designated for the purpose of the financial sanctions (asset freeze measures and making available provisions) contained in the Regulations, the designated person or a representative (on their behalf) may apply for a licence from OFSI to use their funds or economic resources (non-monetary assets, such as property or vehicles). Schedule 3 to the Regulations sets out the purposes pursuant to which, or for which activities, OFSI may grant an individual licence. In summary these are:

basic needs
reasonable professional fees for or reasonable expenses associated with the provision of legal services
reasonable fees or service charges arising from the routine holding or maintenance of frozen funds or economic resources
extraordinary expenses
pre-existing judicial decisions etc
humanitarian assistance activities etc
diplomatic missions etc
prior obligations (non-UN designated persons only)
extraordinary situations (non-UN designated persons only)

The Regulations also provide a power for licences to be issued by OFSI where other financial sanctions apply and details of these can be found in regulation 88.

Specifically, in respect of the prohibitions on the transfer of funds in regulation 28, a licence can be granted, where considered appropriate, in the following circumstances:

transfer of funds of a value over £13,000 relating to a transaction mentioned in regulation 83(2) and which includes transactions:
- relating to foodstuffs, healthcare or medical equipment
- for agricultural or humanitarian purposes
- for the official purposes of a diplomatic or consular mission of the DPRK
- required exclusively for the implementation of projects which are funded by any part of the Government of the United Kingdom which are for—
  - development purposes directly addressing the needs of the civilian population of the DPRK, or
  - the promotion of denuclearisation of the DPRK
transfer of funds of a value over £4,000, which relates to a transaction regarding a personal remittance
to enable anything to be done in connection with the performance of—
- any humanitarian assistance activity, or
- any activity whose purpose is consistent with the objectives of UNSCRs 1718, 1874, 2087, 2094, 2270, 2321, 2356, 2371, 2375 or 2397

OFSI may need to notify, or in some cases seek approval from the relevant United Nations Sanctions Committee before issuing a licence. These requirements are set out in the relevant UN Security Council Resolutions. These requirements will lengthen the processing time for such licence applications and may in some cases prevent a licence from being issued.

Further information on exceptions and licensing grounds can be found in OFSI’s guidance.

Information on licence applications and the relevant form can be found on OFSI’s GOV.UK licensing webpage.

Directions

A Treasury direction may provide an exception to the requirements in regulations 19 (severance of existing financial relationships), 23 (closure of representative offices) and 26(7) (closure of joint venture or co-operative entity).

3.3 Licensing for trade sanctions

Licences may also be issued for certain trade activities that would otherwise be prohibited by the Regulations. The Department for International Trade (DIT) has overall responsibility for trade sanctions licensing. The Secretary of State for International Trade is ultimately responsible for decisions to grant or refuse a trade sanctions licence in any individual case.

The Export Control Joint Unit sits within DIT and is responsible for administering the licensing provisions on behalf of the Secretary of State for all trade sanctions, except those relating to imports which are administered by the DIT Import Licensing Branch. In exercising these powers, DIT seeks and considers advice from other government departments.

In making decisions on whether to grant a licence to permit something which would otherwise be prohibited under Part 6 of the Regulations, the Secretary of State will consider each application on a case-by-case basis to determine whether granting a licence would be consistent with the stated purposes of the sanctions regime and any UN or other relevant international law obligations.

For some prohibitions there are some specific activities which DIT considers are likely to be consistent with the aims of the sanctions. These are set out in the table below. If you think that your proposed activity falls within one of these specific descriptions, you should make this clear and explain why you believe this to be the case in your application for a licence.

Some of the licensing grounds set out include requirements relating to the UN Security Council Sanctions Committee on DPRK (‘UNSC’):

where the Secretary of State is required to give the UNSC notice of a licence granted under this sanctions regime, the Secretary of State will first determine whether granting a licence would be consistent with the purposes set out in the Regulations. If the Secretary of State determines that granting a licence would be consistent with those purposes and goes on to grant a licence, the UK (via the FCDO) will notify the UNSC
where approval from the UNSC is required in order to grant a licence, the Secretary of State will first determine whether granting that the licence would be consistent with the purposes set out in the Regulations. If the Secretary of State determines that granting a licence would be consistent with those purposes, the UK (via the FCDO) will submit the necessary information to the UNSC to seek the approval of the committee. The Secretary of State will only grant a licence when confirmation of the UNSC’s approval has been received

You should not assume that a licence will be granted or engage in any activities prohibited by trade sanctions until your licence has been granted.

Common grounds for granting licences

Prohibition description	Prohibition reference	Considerations for licensing
All prohibitions below		A licence may be granted for any activity that would otherwise be prohibited by the Regulations or by UNSC Resolutions relating to the DPRK^{[footnote 2]} if the Secretary of State considers that the activity is necessary to facilitate the work of international and non-governmental organisations carrying out assistance and relief activities in the DPRK for the benefit of the civilian population in the DPRK; or for any other purpose consistent with the objectives of the UNSC Resolutions relating to the DPRK, which may include activities undertaken solely for humanitarian or denuclearisation purposes. This is subject to UNSC approval.
All prohibitions below		A licence may be granted for any activity that would otherwise be prohibited by the Regulations or by UNSC Resolutions relating to the DPRK if the Secretary of State considers that the activity is necessary for the functioning of diplomatic missions or consular posts in the DPRK pursuant to the 1961 and 1963 Vienna Conventions, or of international organisations enjoying immunities in accordance with international law in the DPRK.

Specific grounds for granting licences

Prohibition description	Prohibition reference	Considerations for licensing
Prohibitions on the export, making available, acquisition, transfer, supply or delivery of restricted goods or restricted technology	35, 37-39	A licence may be granted for the export, making available, transfer, supply or delivery of non-combat vehicles which have been manufactured or fitted with materials to provide ballistic protection and are intended solely for protective use of personnel of the UK Government in the DPRK.
		Common grounds listed above apply.
Imports of restricted goods or restricted technology	36	No specific grounds, only common grounds listed above apply.
Prohibitions on the provision of technical assistance, financial services, funds, and brokering services, and procurement of technical assistance and financial services relating to restricted goods or restricted technology	40-42	A licence may be granted for the provision of technical assistance, financial services, funds or brokering services, or procurement of technical assistance or financial services, related to non-combat vehicles which have been manufactured or fitted with materials to provide ballistic protection and are intended solely for protective use of personnel of the UK Government in the DPRK.
		Common grounds listed above apply.
Prohibitions on the export, making available, transfer, supply or delivery of goods^{[footnote 3]} or technology to or for the benefit of the DPRK armed forces	43	A licence may be granted for the export, making available, transfer, supply or delivery of goods or technology to or for the benefit of the DPRK armed forces if the Secretary of State considers that: - the goods or technology do not relate to the production, development, maintenance or use of military goods, or development or maintenance of military personnel, and do not directly contribute to the development of the operational capabilities of the DPRK’s armed forces, and - such activity is exclusively for either humanitarian or livelihood purposes which will not be used by DPRK persons, entities or bodies to generate revenue, and is not related to any activity prohibited by relevant UNSC resolutions^{[footnote 4]} This is subject to advance UNSC notification. As part of your application for a licence under this provision, you will need to be able to demonstrate that measures are in place to prevent the diversion of items for a prohibited purpose. We will notify the UNSC of the licence in advance of the activity taking place and inform them of those preventative measures taken.
		A licence may be granted for the export, making available, transfer, supply or delivery of goods or technology to or for the benefit of the DPRK armed forces if the Secretary of State considers that: - the goods or technology do not relate to the production, development, maintenance or use of military goods, or development or maintenance of military personnel, and do not directly contribute to the development of the operational capabilities of the DPRK’s armed forces, and - the UNSC has approved that such activity would not be contrary to the objectives of relevant UNSC resolutions^{[footnote 5]}
		Common grounds listed above apply.
Prohibition on the export, import, making available, acquisition, transfer, supply or delivery of armed forces goods or armed forces technology^{[footnote 6]}	44	A licence may be granted for the export, import, making available, acquisition, transfer, supply or delivery of armed forces goods and armed forces technology where the Secretary of State considers that: - the goods or technology do not relate to the production, development, maintenance or use of military goods, or the development or maintenance of military personnel, and do not directly contribute to exports that support or enhance the operational capabilities of the armed forces of a third country, and - such activity is exclusively for either humanitarian or livelihood purposes which will not be used by DPRK persons, entities or bodies to generate revenue, and is not related to any activity prohibited by relevant UNSC resolutions^{[footnote 7]} This is subject to advance UNSC notification. As part of your application for a licence under this provision, you will need to be able to demonstrate that measures are in place to prevent the diversion of items for a prohibited purpose. We will notify the UNSC of the licence in advance of the activity taking place and inform them of those preventative measures taken.
		A licence may be granted for the export, import, making available, acquisition, transfer, supply or delivery of armed forces goods and armed forces technology where the Secretary of State considers that: - the goods or technology do not relate to the production, development, maintenance or use of military goods, or the development or maintenance of military personnel, and do not directly contribute to exports that support or enhance the operational capabilities of the armed forces of a third country, and - the UNSC has approved that such activity would not be contrary to the objectives of relevant UNSC resolutions^{[footnote 8]}
		Common grounds listed above apply.
Prohibition on the export, making available, supply or delivery of certain goods.	45-47	A licence may be granted for the export, making available, supply or delivery of aviation fuel for verified essential humanitarian needs. The applicant will be expected to comply with conditions set out in the licence to monitor the delivery and use of the items. This is subject to advance UNSC approval.
		A licence may be granted for the export, making available, supply or delivery of crude oil if the Secretary of State considers that it is exclusively for livelihood purposes of DPRK nationals and unrelated to the DPRK’s nuclear or ballistic missile programmes or other activities prohibited by relevant resolutions^{[footnote 9]} ; or if the applicable UN threshold (4 million barrels or 525,000 tons in the aggregate per twelve month period) has not been met. This is subject to advance UNSC approval. The Secretary of State will provide regular (every 90 days) notification of these transactions to the UNSC.
		A licence may be granted for the export, making available, supply or delivery of certain industrial machinery, vehicles, iron, steel and other metals amounting to spare parts where the Secretary of State considers that the provision of such spare parts is needed to maintain the safe operation of DPRK commercial civilian passenger aircraft of the aircraft models and types listed in Part B of Annex XII of Regulation 2017/1509 as defined in the Regulations.
		A licence may be granted for export, making available, supply or delivery of refined petroleum products where the Secretary of State considers that: - the transaction does not involve individuals or entities that are associated with DPRK’s nuclear or ballistic missile programmes or other activities prohibited by relevant UNSCRs^{[footnote 10]} ; and - the transaction is exclusively for livelihood purposes of DPRK nationals and unrelated to generating revenue for the DPRK’s nuclear or ballistic missile programmes or other activities prohibited by this Regulation or relevant UNSCRs^{[footnote 11]} provided that: - the applicable UN threshold for such transactions has not been met (the aggregate amount of refined petroleum products does not exceed 500,000 barrels per year); and - the UNSC has not notified the Secretary of State that 95% of the aggregate annual limit has been reached. The Secretary of State will provide regular (every 30 days) notification of these transactions to the UNSC.
		A licence may be granted for the export, making available, supply or delivery of vehicles for the transport of persons (on earth, air or sea) of a value exceeding £9,000 each, teleferics, chairlifts, ski-draglines, traction mechanisms for funiculars, motorbikes of a value exceeding £1000 each, as well as their accessories and spare parts, where the Secretary of State considers that the goods are for humanitarian purposes.
		Common grounds listed above apply.
Prohibitions on the import, acquisition, supply or delivery of certain goods	48-50	A licence may be granted for the import, acquisition, supply or delivery of coal where the Secretary of State considers that: - it originated from outside the DPRK, - it was transported through the DPRK solely for export from the port of Rajin (Ranson), and - the transactions are unrelated to generating revenue for the DPRK’s nuclear or ballistic-missile programmes or other activities prohibited by relevant UNSC resolutions or these Regulations. The UNSC must be notified in advance of such transactions.
		Common grounds listed above apply.
Prohibition on the acquisition or transfer of fishing rights	50(3)	No specific grounds, only common grounds listed above apply.
Prohibitions on the export, making available, supply or delivery of bank notes or coinage.	51	No specific grounds, only common grounds listed above apply.
Prohibitions on the export, making available, supply or delivery of gold, precious metals or diamonds	52	No specific grounds, only common grounds listed above apply.
Prohibitions on the import, acquisition, supply or delivery of gold, precious metals or diamonds.	52	No specific grounds, only common grounds listed above apply.
Prohibitions on the provision of technical assistance, financial services, funds, or brokering services relating to gold, precious metals or diamonds	53-55	No specific grounds, only common grounds listed above apply.
Prohibitions on the provision of services incidental to mining or to manufacturing in the chemical, mining and refining industry, or provision of computer and related services.	56	A licence may be granted for the provision of services incidental to mining or to manufacturing in the chemical, mining and refining industries where the Secretary of State considers that the services are intended exclusively for development purposes that directly address the needs of the civilian population or the promotion of denuclearisation.
		A licence may be granted for the provision of computer and related services where the Secretary of State considers that the services are provided exclusively for development purposes that directly address the needs of the civilian population or the promotion of denuclearisation.
		Common grounds listed above apply.
Prohibitions on the provision of financial services or funds for the purposes of trade	57	No specific grounds, only common grounds listed above apply.
Prohibitions on the leasing or chartering of ships and aircraft, the provision of crew services, the provision of ship classification services or the provision of bunkering or ship supply services	58-61	No specific grounds, only common grounds listed above apply.

Applications for trade sanctions licences can be made through SPIRE. Information on the activities you wish to carry out and any other relevant documentation can be provided in a cover letter and attached to the application. If you have questions on trade sanctions licensing, please contact us via tradesanctions@trade.gov.uk.

When you export goods, you may need to submit an electronic export declaration via the National Export System (NES), part of His Majesty’s Revenue and Customs’ (HMRC) Customs Handling of Import and Export Freight (CHIEF) system. Guidance is available on how to make an export declaration.

Licence applications for import of armed forces goods and coal can be made through the online import licensing system ICMS, managed by DIT’s Import Licensing Branch (ILB). The DIT Import Licensing Branch will, to the extent possible, aim to inform the trader of the application outcome within 30 days. However, in some circumstances, for operational or legal reasons, DIT may need to take longer than the 30 day period. We will inform the applicant if this is the case.

When you import goods, you may need to submit an import declaration through His Majesty’s Revenue and Customs’ (HMRC) Customs Handling of Import and Export Freight (CHIEF) system. Guidance is available on how to make an import declaration.

3.4 Overlap with strategic export licensing

Military goods and military technology

Please note that the export of and trade in military goods and military technology are also controlled under the Export Control Order 2008 and so you may also need a licence which is valid under that legislation. This means that all licence applications relating to military goods and military technology will also need to be considered against the Strategic Export Licensing Criteria. A licence under the Regulations is unlikely to be granted if a licence is refused for the same activity under the Export Control Order 2008.

The way this will work in practice is that we will consider an application for a licence which relates to activities that are licensable under both the Regulations and the Export Control Order 2008 as an application for a licence under both pieces of legislation. This means that only a single licence application is required.

The application will be considered against the relevant licensing criteria. If a licence is granted it will be valid under both the Export Control Order 2008 and the Regulations.

Dual-use goods and technology

Please note that the export of and trade in dual-use goods and technology are also controlled under the Dual-Use Regulation. Authorisations under that Regulation are granted by the Secretary of State for International Trade under licensing powers in the Export Control Order 2008.

This means that all licence applications relating to items which are controlled dual-use goods and technology will also need to be considered against the Strategic Export Licensing Criteria. A licence under the Regulations is unlikely to be granted if an authorisation is refused for the same activity under the Dual-Use Regulation.

As explained above in relation to military goods and technology, only a single licence application will be required in relation to dual-use goods and technology which falls within the scope of both the Regulations and the Dual-Use Regulation. If the application is compatible with both criteria, a licence will be granted which will be valid under the Dual-Use Regulation and the Export Control Order 2008 as well as the Regulations.

Overlap between trade sanctions and financial sanctions

If you import or export goods, you need to consider if financial sanctions apply to you. You may need a licence from OFSI as well as from the Export Control Joint Unit or the Import Licensing Branch.

Transit control

Certain goods transiting the UK are still regarded as being exported when they leave the country and are therefore subject to control. Article 17 of the Export Control Order 2008 includes a transit and transhipment exception meaning that in many situations a licence is not required. This exception does not apply to goods destined for DPRK, meaning that a licence is required to transit goods through the UK or to tranship them in the UK with a view to re-exportation to DPRK.

3.5 Licensing for transport sanctions

Where an exception does not apply, a licence may be issued by the Department for Transport in particular circumstances to allow for time-limited and specific actions to take place which would otherwise be prohibited by the Regulations.

The activities for which a licence may be granted are:

for overflying UK airspace, entering UK airspace, landing at a UK airport or for taking off from a UK airport for reasons not related to an emergency (for example to take on board medicines or emergency food supplies)
to allow for the ownership, control, chartering or operation of a DPRK ship
to enable the transfer of goods to or from a DPRK ship
to permit the registration of a ship in the DPRK or for a person to obtain authorisation for a ship to fly the flag of the DPRK

A licence may be general or be issued to a particular category of person or to a particular person. Licences may contain conditions and they may be of a defined duration or of indefinite duration.

Information on how to apply for a transport sanctions licence is available on GOV.UK.

3.6 Directions in respect of immigration sanctions

If you are subject to immigration sanctions the Home Office may direct, on a case by case basis, that the sanction does not apply in particular circumstances, such as for travel to, or through, the UK for a UN sponsored meeting. You can check how to apply for a UK visa, and find further information about travelling to the UK on GOV.UK.

Question 4

4. Further information

Accepted Answer

Sign up to receive Notices to Exporters and view the Notices to Importers for updates on trade sanctions.

To receive an email alerting you to any changes to the consolidated list of financial sanctions targets, you can subscribe to OFSI’s e-alert.

“the Goods Classification Table” means the table so named in Annex I in Part Three of the Tariff of the United Kingdom. ↩
UNSCRs 1718 (2006), 1874 (2009), 2087 (2013), 2094 (2013), 2270 (2016), 2321 (2016), 2356 (2017), 2371 (2017), 2375 (2017) or 2397 (2017) ↩
For the purposes of the prohibitions contained in regulation 43, regulation 43(5) defines “goods” as not including food or medicine. ↩
Including UNSCRs 1718 (2006), 1874 (2009), 2087 (2013), 2094 (2013), 2270 (2016), 2321 (2016), 2356 (2017), 2371 (2017), 2375 (2017) and 2397 (2017). ↩
Including UNSCRs 1718 (2006), 1874 (2009), 2087 (2013), 2094 (2013), 2270 (2016), 2321 (2016), 2356 (2017), 2371 (2017), 2375 (2017) and 2397 (2017). ↩
The terms “armed forces goods” and “armed forces technology” have the meaning ascribed to them by regulation 44(7) i.e. goods (except food or medicine) and technology which could support or enhance the operational capability of the armed forces of any country other than the DPRK. ↩
Including UNSCRs 1718 (2006), 1874 (2009), 2087 (2013), 2094 (2013), 2270 (2016), 2321 (2016), 2356 (2017), 2371 (2017), 2375 (2017) and 2397 (2017). ↩
Including UNSCRs 1718 (2006), 1874 (2009), 2087 (2013), 2094 (2013), 2270 (2016), 2321 (2016), 2356 (2017), 2371 (2017), 2375 (2017) and 2397 (2017). ↩
UNSCRs 1718 (2006), 1874 (2009), 2087 (2013), 2094 (2013), 2270 (2016), 2321 (2016), 2356 (2017), 2371 (2017), 2375 (2017) and 2397 (2017). ↩
UNSCRs 1718 (2006), 1874 (2009), 2087 (2013), 2094 (2013), 2270 (2016), 2321 (2016), 2356 (2017), 2371 (2017), 2375 (2017) and 2397 (2017). ↩
UNSCRs 1718 (2006), 1874 (2009), 2087 (2013), 2094 (2013), 2270 (2016), 2321 (2016), 2356 (2017), 2371 (2017), 2375 (2017) and 2397 (2017). ↩

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