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OFSI [& JERSEY] advisory note on the risks posed by North Korean workers.

15/09/2024
  1. On 12 September 2024, the UK's Office of Financial Sanctions Implementation (“OFSI") released an advisory on North Korean IT workers.
  2. The advisory identifies critical threats posed by North Korean IT workers who seek to breach financial sanctions on the Democratic People's Republic of Korea (“DPRK", aka North Korea) and provides recommendations on how firms can mitigate their risk exposure.
  3. The advisory is aimed at the Information Technology (“IT"), Cryptocurrency, Electronic Money Institutions (“EMI"), Money Service Businesses (“MSB"), and Professional Services sectors.
  4. The DPRK is subject to significant sanctions imposed by the UK by its obligations under United Nations Security Council (“UNSC") resolutions. They are aimed at countering the proliferation of weapons of mass destruction (“WMD") and ballistic missiles.
The OFSI Advisory on North Korean IT Workers
  1. The OFSI Advisory on North Korean IT Workers can be found here​.  https://assets.publishing.service.gov.uk/media/66e2ec410d913026165c3d91/OFSI_Advisory_on_North_Korean_IT_Workers.pdf
  2. A link to the advisory has also been added to the Proliferation Financing section of the Government of Jersey website: https://www.gov.je/Industry/Finance/FinancialCrime/Sanctions/Pages/CombattingProliferationFinancing.aspx
JERSEY REQUIREMENTS
  1.  Both UNSC sanctions and autonomous UK sanctions are implemented in Jersey through
    1. The Sanctions and Asset-Freezing (Jersey) Law 2019, and
    2. The Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021. 
  2. Individuals and entities who employ or pay DPRK IT workers could be directly or indirectly breaching financial sanctions.
  3. To comply with any reporting obligations in respect of financial sanctions in Jersey, including notification of any breach, a completed Sanctions Compliance Reporting Form should be submitted to the Minister for External Relations at sanctions@gov.je.
    1. https://www.gov.je/SiteCollectionDocuments/Industry and finance/Sanctions Compliance Reporting form.docx
  4. These reporting obligations include reporting to the Financial Intelligence Unit.
    1. https://services.jersey.police.uk/PolSAR/Login.aspx?ReturnUrl=/PolSAR/Logout.aspx
Further information
  1. Find more information on sanctions or sanctions on the Jersey Financial Services Commission (JFSC).
  2. Jersey guidance on the DPRK sanctions regime is available on sanctions by country and category on JFSC.
  3. A copy of the UK Regulations can be obtained from legislation.gov.uk. Other relevant information about this regime can be found on financial sanctions targets by the regime on GOV.UK.
Enquiries 
  1. Non-media enquiries, sanctions compliance reporting, and licence applications should be emailed to the Financial Sanctions Implementation Unit at sanctions@gov.je.
JERSEY SANCTIONS UNITED KINGDOM

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