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OFAC Issues North Korea Sanctions, Tornado Cash Guidance

The Office of Foreign Assets Control announced several North Korea-related sanctions measures this week, including designations against two people involved in illegally importing goods into the country. OFAC also delisted and redesignated the virtual currency mixer Tornado Cash to account for “additional information” and to include an “additional basis” for the mixer’s designation. The agency issued a new frequently asked question to offer compliance guidance for Tornado Cash and updated three existing FAQs.

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Among the two new designations is Ri Sok, a “representative” of Air Koryo, North Korea’s national flag carrier that was sanctioned by OFAC in 2016. The agency said Sok represents Ai Koryo in Dandong, China, and helps to transport electronic parts from China to North Korea on behalf of North Korea’s Ministry of Rocket Industry. OFAC also sanctioned Yan Zhiyong, a logistics manager with Air Koryo who helps to ship goods to North Korea from China on behalf of the Reconnaissance General Bureau, the country’s intelligence agency.

OFAC said it redesignated Tornado Cash -- which was first sanctioned in August (see 2208080031) -- to account for its “role in enabling malicious cyber activities” that support North Korea’s weapons program. New FAQ 1095 outlines Tornado Cash’s organizational structure and stresses that OFAC hasn’t designated Tornado Cash’s “individual founders, developers,” members of the company’s Tornado Cash Decentralized Autonomous Organization, or “other persons involved in supporting Tornado Cash at this time.” OFAC updated FAQs 1079, 1078 and 1076 to reflect Tornado Cash’s redesignation.

These sanctions are the U.S.’s latest steps to try to limit North Korea’s ballistic missile and weapons programs, OFAC said, specifically referencing the country’s recent string of missile launches off its coast (see 2211070016).