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North Korea

Sanctions - North Korea

The Democratic People's Republic of Korea (DPRK) has been subject to United Nations sanctions since October 2006, when the UN Security Council adopted Resolution 1718 following the DPRK's first nuclear test on 9 October 2006. A series of further UNSC resolutions from 2009 to 2017 progressively tightened and expanded those measures in response to successive nuclear tests and ballistic missile launches.

The DPRK operates one of the most heavily sanctioned economies in the world. Both the United States and the European Union have imposed autonomous sanctions regimes that go substantially beyond the scope of the UN regime, particularly in the areas of trade, investment, financial services, human rights, and cyber operations. The United Kingdom, following its departure from the EU, has transposed and maintained the pre-existing EU regime through domestic legislation and has since aligned with international partners on additional designations.

The post-2021 period has been characterised by two overlapping developments. First, the DPRK has resumed and accelerated its ballistic missile and nuclear programmes, conducting numerous intercontinental ballistic missile (ICBM) launches in defiance of UN resolutions. Second, the DPRK has deepened its military and economic relationship with the Russian Federation, providing ammunition, munitions, and reportedly troops to support Russia's war of aggression in Ukraine - a development that has materially affected the sanctions landscape and prompted autonomous designations by the US, UK, and EU targeting facilitators of this relationship.

UN - North Korea Sanctions Regime

The core UN-mandated sanctions regime is based on a series of UNSCRs from 2016 to 2017. The key maritime prohibitions include:

  • Ban on the purchase or transport from the DPRK of gold, titanium ore, vanadium ore, rare earth minerals, coal, iron and iron ore, lead and lead ore, and seafood.
  • Ban on the sale and supply to the DPRK of aviation and rocket fuels, condensates, and natural gas liquids.
  • Cap of 500,000 barrels per year on refined petroleum products imported into the DPRK, with Member States required to notify the Security Council every 30 days of quantities supplied.
  • Crude oil supply to the DPRK is capped at current levels; new crude oil supply contracts are prohibited.
  • Ban on exports of textiles from the DPRK.
  • Comprehensive arms embargo: prohibition on all transfers of arms and related materiel, both to and from the DPRK.
  • Ban on all leasing or chartering of vessels and the provision of crew services to the DPRK.
  • Ban on owning, operating, or providing classification, certification, or other similar services to vessels flagged by the DPRK.
  • Ban on DPRK-flagged vessels, or vessels owned, operated, or crewed by the DPRK, entering ports of Member States.
  • Prohibition on new joint ventures or cooperative entities with DPRK individuals or entities.
  • Ban on granting work authorisations to DPRK nationals.
  • Expanded arms embargo and expanded list of prohibited luxury goods designated under annex resolutions.

The Club has produced two News Items on these enhanced sanctions, on 12 May 2016 and 7 July 2016.

These contain links to helpful briefings prepared by Holman Fenwick Willan (to whom we are grateful for their permission to use these briefings) as well as the relevant EU, US and UN materials.

Member States of the UN are rigorously enforcing these measures and with a clear focus on the shipping industry. Further details of these enforcement efforts and the potential penalties for those parties who are found to have breached sanctions against North Korea can be found in our News Item of 13 March 2018 and Notice to Members No.12 2018/2019 which we strongly recommend Members read.

United States

The US sanctions regime against the DPRK is the most extensive unilateral regime in force and is administered by the Office of Foreign Assets Control (OFAC) within the US Department of the Treasury. The primary regulatory instrument is the North Korea Sanctions Regulations (NKSR), codified at 31 CFR Part 510.

The NKSR prohibitions apply to all US persons wherever located in the world. The regime also has secondary sanctions implications for non-US persons. Under E.O. 13810, a foreign financial institution may be subject to restrictions on its US correspondent accounts or payable-through accounts if it is found to have knowingly conducted or facilitated a significant transaction on behalf of a blocked person, or in connection with trade with the DPRK.

Comprehensive Trade Embargo

The NKSR impose a near-comprehensive embargo on economic transactions between US persons and the DPRK:

  • Prohibition on the exportation or re-exportation to the DPRK of goods, services, and technology from the United States or by a US person - except for food and medicine.
  • The US Export Administration Regulations (EAR) additionally prohibit the export or reexport of foreign-made products to the DPRK if they incorporate more than 10% US-origin commodities by value (the de minimis threshold).
  • Prohibition on the importation into the United States of any goods, services, or technology from the DPRK.
  • Prohibition on the importation of any goods produced by DPRK nationals, regardless of the country of origin of those goods - specifically intended to prevent goods produced by DPRK overseas laborer's from entering the United States.
  • Prohibition on US persons entering into new investment in the DPRK.
  • Prohibition on the facilitation of any transaction by a third party that a US person could not itself undertake.

Asset Blocking

All property and interests in property of designated SDNs (and of entities 50% or more owned or controlled by designated persons) that are in the United States, or that come within the possession or control of a US person, are blocked. Dealings with blocked property are prohibited without OFAC authorisation.

The 180-Day Rule (Port Call Prohibition)

Pursuant to E.O. 13810 and 31 CFR Part 510:

  • Any vessel that has called at a port or place in the DPRK within the previous 180 days is prohibited from entering US waters.
  • Any vessel that has engaged in a ship-to-ship (STS) transfer with a vessel that called at a DPRK port within the previous 180 days is likewise prohibited from entering US waters.
  • An exception exists for vessels in distress (31 CFR § 510.518).

This rule has significant practical consequences for Members. Any vessel that has made a DPRK port call or participated in a DPRK-linked STS transfer faces a blanket 180-day exclusion from all US ports, regardless of subsequent ownership or charter arrangements.

Secondary Sanctions - Prohibition on Third-Country Dealings

Non-US persons and entities may be sanctioned (and added to the SDN List) if they are found to have materially assisted, sponsored, or provided financial, material, or technological support for the DPRK's WMD or ballistic missile programmes, or for the Government of the DPRK or the Workers' Party of Korea.

Designations in 2024–2025 have specifically targeted facilitators of DPRK arms transfers to Russia and DPRK IT worker networks generating revenue for the regime.

Exemptions include

  • Exports of food and medicine to the DPRK (not otherwise prohibited by other export control authorities).
  • NGO activities: Authorised under General Licence 4 (as amended) for specified humanitarian relief, democracy-building, and civil society activities, and for necessary transactions with the DPRK government incidental to those activities (e.g. payment of required local taxes or fees).
  • Export/reexport of items specifically licensed by the US Department of Commerce (added February 2024 amendment, 31 CFR § 510.520).

United Kingdom

The UK's DPRK sanctions regime is established under the Democratic People's Republic of Korea (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/411). These Regulations were made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) and transposed, with substantially the same effect, the EU DPRK sanctions regime as it stood at the time of the UK's departure from the EU.

The Regulations were most recently by the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024 (S.I. 2024/1157), which strengthened OFSI's enforcement powers, intelligence-gathering capacities, and licensing procedures. The statutory guidance was last updated on 5 November 2025.

In September 2024, the UK’s Office of Financial Sanctions Implementation (OFSI) (HM Treasury) has issued a targeted advisory on DPRK IT workers warning UK firms of the risk of inadvertently employing DPRK nationals whose income is remitted to the regime.

As of 28 January 2026, the OFSI Consolidated List of Asset Freeze Targets has been closed, and the UK Sanctions List is now the sole authoritative source for all UK sanctions designations, including DPRK designations.

Prohibitions

Asset Freeze - Financial Sanctions

It is prohibited for any UK person, or any person within the UK, to:

  • Deal with funds or economic resources owned, held, or controlled by a designated person.
  • Make any funds or economic resources available, directly or indirectly, to or for the benefit of a designated person.
  • Entities owned or controlled (directly or indirectly) by a designated person are subject to equivalent restrictions.
  • Financial sanctions apply to all UK persons wherever located in the world, including UK-incorporated companies and UK nationals operating abroad.

Trade Prohibitions - Export

The Regulations impose the following export prohibitions:

  • Prohibition on the export of arms and related materiel to or for use in the DPRK, including all goods falling within Chapter 93 of the Goods Classification table.
  • Prohibition on the export of dual-use goods and technology to any DPRK military end-user or entity connected to WMD programmes.
  • Prohibition on the export of goods, technology, or materials that could contribute to the DPRK's nuclear-related, ballistic missile-related, or other WMD-related programmes, as set out in relevant schedules.
  • Prohibition on the export of certain luxury goods designated in the schedules to the Regulations.
  • Prohibition on the export of new helicopters and new vessels to the DPRK.
  • Prohibition on the export of aviation fuel (jet fuel, petrol, rocket fuel, condensates, and natural gas liquids).
  • Prohibition on the transfer of technical assistance, brokerage services, or financial assistance connected to prohibited goods.

Trade Prohibitions - Import

The Regulations impose four categories of import prohibition:

  • Prohibition on the import of arms and related materiel, dual-use goods, and other WMD-related goods originating in or consigned from the DPRK (including all goods within Chapter 93 of the Goods Classification table).
  • Prohibition on the import of 'armed forces goods' - i.e. goods, except food or medicine, capable of supporting or enhancing the operational capability of the armed forces of any country other than the DPRK - if consigned from or originating in the DPRK.
  • Prohibition on the import of: coal, iron, iron ore, lead, lead ore, gold, titanium ore, vanadium ore, rare earth minerals, copper, nickel, silver, zinc, and seafood if consigned from or originating in the DPRK.
  • Prohibition on the import of gold, precious metals, or diamonds consigned from a DPRK government person (broadly defined to include the Government, its members, bodies owned or controlled by it, and persons acting on its behalf).

Transport and Vessel Prohibitions

  • Prohibition on the provision of vessel chartering or leasing services, or crew services, to the DPRK.
  • Prohibition on owning, operating, or providing classification, certification, or other similar services to DPRK-flagged vessels.
  • Prohibition on DPRK-flagged vessels, or vessels owned or operated by the DPRK, calling at UK ports.
  • Prohibition on the provision of port access services to vessels believed to be carrying prohibited goods.

Transit and transhipment: The transit and transhipment exception that applies under other regimes does not apply to goods subject to import prohibitions under the DPRK Regulations. Goods transiting through the UK destined for the DPRK require a licence.

European Union

The EU's DPRK sanctions regime is described by the European Council as currently one of the most restrictive in force. Its legal foundation comprises:

The EU regime implements all UN Security Council resolutions adopted since 2006 and additionally imposes a substantial body of autonomous measures that extend significantly beyond the UN framework. The regime has been updated through successive implementing regulations, most recently:

The EU regime is periodically renewed. The December 2025 renewal brought the total number of persons listed autonomously by the EU to approximately 65.

Albania, Armenia, Bosnia and Herzegovina, Georgia, Iceland, Liechtenstein, Moldova, Montenegro, North Macedonia, Norway, Serbia, and Ukraine have aligned their national policies with the December 2025 Council Decision.

Prohibitions

Asset Freeze and Funds Prohibition

All funds and economic resources belonging to, owned, held, or controlled by listed persons are frozen. EU persons are prohibited from:

  • Making available, directly or indirectly, any funds or economic resources to listed individuals or entities.
  • Participating in activities the object or effect of which is, directly or indirectly, to circumvent the asset freeze.
  • Entities owned or controlled 50% or more by a listed person are subject to equivalent restrictions.

Comprehensive Arms Embargo

The direct or indirect sale, supply, transfer, or export - from or through EU territory - of all arms and related materiel, including weapons, ammunition, military vehicles, paramilitary equipment, and spare parts, to the DPRK is prohibited. Equally prohibited are:

  • The provision of technical assistance, brokering services, financing, or other services related to military activities or related to the provision, manufacture, maintenance, or use of arms.
  • The purchase, import, or transfer of arms and related materiel originating from the DPRK.

Trade in Prohibited Goods

The following import and export prohibitions are in force:

  • Export prohibition: New helicopters and new vessels to the DPRK.
  • Export prohibition: Aviation fuel (jet fuel, aviation petrol, kerosene-type jet fuel, rocket fuel, condensates, and natural gas liquids).
  • Export prohibition: Refined petroleum products; crude oil above UN-agreed caps.
  • Import prohibition: Coal, iron, iron ore, lead, lead ore - reflecting UNSCR 2270 and UNSCR 2321.
  • Import prohibition: Gold, titanium ore, vanadium ore, rare earth minerals, copper, nickel, silver, zinc - reflecting UNSCR 2321.
  • Import prohibition: Seafood (fish, crustaceans, molluscs) from the DPRK - reflecting UNSCR 2371.
  • Import prohibition: Textiles (woven fabrics, apparel, etc.) from the DPRK - reflecting UNSCR 2375.
  • Import and export prohibition: Luxury goods (as specified in Annex III to the Regulation).
  • Import prohibition: Statues from the DPRK.

Shipping and Transport Prohibitions

  • Prohibition on the chartering or leasing of vessels or aircraft to the DPRK.
  • Prohibition on owning, operating, or providing classification, certification, or similar services to DPRK-flagged vessels.
  • Prohibition on DPRK-flagged vessels, or vessels owned or operated by the DPRK, entering EU ports.
  • Prohibition on the use of DPRK nationals as crew on EU-flagged vessels.
  • Member States are required to inspect vessels calling at their ports where there are reasonable grounds to believe the vessel is carrying prohibited cargo.

Travel Ban

Designated individuals are subject to a travel ban preventing entry into or transit through EU Member State territories.

Exemptions

  • Humanitarian: All restrictive measures are designed to avoid adverse humanitarian consequences for the civilian population. Member States may, on a case-by-case basis, authorise otherwise prohibited transactions for strictly humanitarian purposes.
  • Medical exchanges: Scientific and technical cooperation for medical purposes is exempt from the general suspension of cooperation.
  • Livelihood exemptions: Consistent with the UN framework, exceptions apply for livelihood and humanitarian purposes where appropriate.

Impacts on maritime trade

Members should be in no doubt that any trade with North Korea will be subject to the greatest scrutiny. Vessels may be subject to search and detention at ports whilst suspicious activity is investigated. Any activity in breach of sanctions will result in insurance coverage being immediately withdrawn and a very high likelihood of severe penalties being imposed which at best, will affect the future trading of the vessel and at worst could prove fatal to the future viability of a Member's whole enterprise.

Even if it were possible to undertake legitimate trade with North Korea, Members should bear in mind that the Club is very unlikely to be able to support vessels trading to North Korean ports, with payment of claims and fees and the provision of security liable to be very delayed and perhaps completely prohibited. Any vessel doing so will also be automatically banned from US waters for the following 180 days.

All Members are therefore strongly urged to re-assess the risks of undertaking any business with North Korea and should also exercise the fullest possible due diligence to ensure that they are not unwittingly entering into prohibited activities with North Korean entities.

Important note

The information provided by the Club and in particular through its website is not and is not intended to be exhaustive. Every effort is made to ensure the accuracy of the information provided. However this cannot be guaranteed given that sanctions measures are subject to alteration by governmental organisations at short notice. Further the information on this site is not, and should not be relied upon as, independent legal advice.

Members are strongly advised to undertake due diligence before fixing any business to or from a sanctioned country in order to ensure that neither the prospective cargo nor the parties to the planned venture are sanctioned. The Club is willing to assist Members where possible but they may nevertheless wish to take independent legal advice.