The U.S. Department of the Treasury recently announced a Notice of Finding that the Democratic People’s Republic of Korea (“North Korea”) is a jurisdiction of “primary money laundering concern” under Section 311 of the USA PATRIOT Act. The Department of Financial Services (“DFS”) shares the Treasury Department’s concerns that North Korea, acting through government agencies and associated front companies, is engaged in illicit activities and may be seeking banking services in other jurisdictions. Also, the Treasury Department, through its Financial Crimes Enforcement Network (“FinCEN”) released a notice of proposed rulemaking (“NPRM”) recommending a special measure to further isolate North Korea from the international financial system by prohibiting covered U.S. financial institutions from opening or maintaining correspondent accounts with North Korean financial institutions, and prohibiting the use of U.S. correspondent accounts to process transactions for North Korean financial institutions.
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