US issues sanctions against an Indian national, 39 others for corruption and human rights abuse



The US Department of the Treasury’s Office of Foreign Assets Control (OFAC), in recognition of International Anti-Corruption Day and Human Rights Day, on December 9 issued sanctions on a diverse array of over 40 individuals and entities that are connected to corruption or human rights abuse across nine countries.

In 2022, Treasury took numerous actions to promote accountability for human rights abusers and corrupt actors across the world, including sanctions on dozens of individuals and entities including in the Western Balkans, Belarus, Liberia, Guatemala, the Russian Federation, Burma, and Iran. Treasury utilized various tools and authorities — including Executive Order (E.O.) 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act — to demonstrate the US government’s focus on promoting respect for human rights and countering corruption.

“Corrupt actors and human rights abusers both rely on deficiencies in the international financial system to perpetrate their activities,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “Over the past year, Treasury has made combatting corruption and serious human rights abuse a top priority, including through the use of financial sanctions and addressing vulnerabilities in the U.S. and international financial systems. By exposing the egregious behavior of these actors, we can help disrupt their activities, dismantle their networks, and starve them of resources.”

On December 9 OFAC designated the Democratic People’s Republic of Korea’s (DPRK) Ministry of State Security Border Guard General Bureau (BGGB), which is responsible for security along the DPRK’s borders with China and Russia. People inside the DPRK reportedly are subjected to forced labor, torture, and other human rights violations and abuses at the hands of the government.

The US Department of the Treasury stated: “Foreign entities that are involved in the use of DPRK labor enable the continued poor treatment that these workers endure, which includes constant surveillance, being forced to work long hours, and having a significant portion of their wages confiscated by the regime.”

“The DPRK government-run animation studio, SEK Studio (SEK), which was previously designated on December 10, 2021 pursuant to E.O. 13722, has been subcontracted by foreign companies to provide low-cost labor and has utilized its animation workers that are located in the DRRK and the PRC to fulfill these contracts. SEK has also evaded sanctions targeting the DPRK government using front companies,” it added.

The sanction against Deepak Jadhav of India has been issued because – Jadhav, India-based director of Funsaga Pte Ltd., has entered a contract with SEK to produce an animation project while providing payments to Quanzhou Yiyangjin Import and Export Trade Co., Ltd. and Yancheng Three Line One Point Animation Co., Ltd.

A SEK official indicated that Deepak Jadhav sent over $15,000 to Quanzhou Yiyangjin Import and Export Trade Co., Ltd. and Funsaga Pte. Ltd. sent more than $50,000 to SEK, with part of the funds being transferred to Tian Fang (Hong Kong) Holdings Ltd. Kinoatis LLC has sent over $100,000 to Fujian Nanan Import and Export Corporation, which acted as an affiliate for SEK, to pay for an animation project. Deepak Jadhav, Funsaga Pte Ltd., and Kinoatis LLC are being designated pursuant to E.O. 13722 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, SEK.

Kim Myong Chol, a Paris-based representative of SEK and has facilitated payment transactions for SEK in 2022, including the collection of unpaid payments on contracts between European companies and SEK. Everlasting Empire Limited, Tian Fang (Hong Kong) Holdings Limited, Yancheng Three Line One Point Animation Co., Ltd., Quanzhou Yiyangjin Import and Export Trade Co., Ltd., and Fujian Nanan Import and Export Corporation have all facilitated financial transactions on behalf of SEK. Kim Myong Chol, Everlasting Empire Limited, Tian Fang (Hong Kong) Holdings Limited, Yancheng Three Line One Point Animation Co., Ltd., Quanzhou Yiyangjin Import and Export Trade Co., Ltd., and Fujian Nanan Import and Export Corporation are being designated pursuant to E.O. 13722 for having acted or purported to act for or on behalf of, directly or indirectly, SEK.

“Due to their dire circumstances, tens of thousands of North Koreans have fled the country in the past two decades. The journey to leave the DPRK is particularly treacherous due to attempts by state security agencies, including the BGGB, to thwart escapes through tight border controls, including land mines and shoot-on-sight orders that have resulted in the deaths of numerous North Koreans. The BGGB is designated pursuant to E.O. 13687 for being an agency, instrumentality, or controlled entity of the Government of North Korea or the Workers’ Party of Korea,” the US Department of Treasury stated.

“DPRK nationals are also often forced to work in foreign countries to generate foreign currency that is utilized to support the DPRK’s weapons of mass destruction (WMD) and ballistic missile programs. UN Security Council Resolution 2397, adopted on December 22, 2017, requires UN Member States to have repatriated DPRK nationals earning income in their jurisdictions by December 22, 2019, subject to limited exceptions,” the department said in a press release.

The sanctions are a key component of the Biden-Harris Administration’s efforts to implement the first-ever US Strategy for Countering Corruption, released in December 2021.

All property and interests in property of the designated persons that are in the United States or in the possession or control of US persons are effectively blocked and must be reported to OFAC. In addition, OFAC’s regulations prohibit all transactions by US persons or within (or transiting) the United States that involve any property or interests in the property of designated or otherwise blocked persons.

“The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Department of the Treasury’s List of Specially Designated Nationals and Blocked Persons (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,” the department said.


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