The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has published major revisions to its humanitarian authorizations and other general licenses under the North Korean Sanctions Regulations (“NKSR”), which took effect on February 16, 2024. These regulatory changes expand the scope of authorized activity in North Korea, which should lead to fewer specific license applications for NGOs engaged in humanitarian work relating to the DPRK. In this regard, OFAC has narrowed the restriction on authorized activity arising from “partnerships” with the DPRK government. OFAC has also established a new authorization for journalistic activities in North Korea. These revisions to the NKSR, along with some improved guidance from OFAC regarding banks’ due diligence expectations, may result in less de-risking by financial institutions when it comes to customer activity involving North Korea.
At the same time, there remain important limitations and conditions to these authorizations that must be observed. Moreover, OFAC has implemented a new advance reporting requirement if one intends to use the revised humanitarian general license, which may increase the compliance burden on NGOs as well as provide the State Department an opportunity to object to the use of the general license on a case-by-case basis. Continue Reading OFAC Issues Significantly Revised NGO Authorizations for North Korea