Reed Smith Client Alerts

In the wake of recent cyber-attacks, President Obama signed an Executive Order January 2, 2015, imposing additional economic sanctions against the Democratic People’s Republic of Korea. The Executive Order authorizes the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) to apply sanctions against officials and entities associated with North Korea's government and the ruling Workers' Party of Korea.

The Obama administration has maintained that North Korea supported the cyber-attack against Sony Pictures Entertainment and the subsequent threats of violence against movie theaters. The Executive Order is the first official act of retribution against the country for the cyber-attack and is only the first part of the administration’s “proportional” response to North Korea’s actions.

Pursuant to the authority issued under the Executive Order, the Treasury designated the following three controlled entities of the government of North Korea:

  • Reconnaissance General Bureau (RGB) – North Korea’s primary intelligence organization responsible for collecting strategic, operational, and tactical intelligence for the Ministry of the People’s Armed Forces. Many of North Korea’s major cyber operations run through RGB.
  • Korea Mining Development Trading Corporation (KOMID) – North Korea’s primary arms dealer and main exporter of goods and equipment related to ballistic missiles and conventional weapons.
  • Korea Tangun Trading Corporation – Primarily responsible for the procurement of commodities and technologies to support North Korea's defense research and development programs.

The Treasury also sanctioned 10 designated persons of the North Korean government:

  • Kil Jong Hun and Kim Kwang Yon – Officials of the North Korean government; representative of the southern African interests of KOMID
  • Jang Song Chol – Official of the North Korean government; KOMID representative in Russia
  • Yu Kwang Ho – Official of the North Korean government
  • Kim Yong Chol – Official of the North Korean government; KOMID representative in Iran
  • Jang Yong Son – Official of the North Korean government; KOMID representative in Iran
  • Kim Kyu – Official of North Korean government; KOMID External Affairs Officer
  • Ryu Jin and Kang Ryong – Officials of the North Korean government; KOMID officials operating in Syria
  • Kim Kwang Chun – Official of the North Korean government; Korea Tangun Trading Corporation representative in Shenyang, China

The Secretary of the Treasury stressed that the Executive Order and accompanying sanctions reflect “the ongoing commitment of the United States to hold North Korea accountable for its destabilizing, destructive and repressive actions, particularly its efforts to undermine U.S. cyber-security and intimidate U.S. businesses and artists exercising their right of freedom of speech.”


Client Alert 2015-001