Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a network of six individuals and five entities based in the People’s Republic of China (PRC), involved in the procurement of items supporting the Democratic People’s Republic of Korea’s (DPRK) ballistic missile and space programs. In flagrant violation of multiple United Nations (UN) Security Council Resolutions (UNSCR), the DPRK has continued to conduct launches using ballistic missile technology, including a recent failed effort to place a military satellite into orbit in late May 2024. Moreover, the DPRK has supplied ballistic missiles to the Russian Federation, which continues to target civilian population centers and infrastructure in Ukraine, sustaining Russia’s brutal and unprovoked war.
For its part, Russia has vetoed the renewal of the UN Panel of Experts tasked with monitoring for violations of DPRK-related UNSCR sanctions, making it easier for the DPRK and other actors to evade UN sanctions. Today’s action reaffirms that the relevant UNSCRs remain in full force and reiterates the United States’ commitment to countering sanctions evasion and strengthening efforts for enforcement.
“The DPRK’s continued development and proliferation its of ballistic missile technologies-in violation of UN sanctions-is both irresponsible and destabilizing for both the region and the international community,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States remains committed to using our tools to enforce these international sanctions, including disrupting the illicit procurement networks that provide key inputs for these technologies and holding accountable those who seek to enable these activities.”
Today’s action was taken pursuant to Executive Order 13382 (E.O. 13382), which targets proliferators of weapons of mass destruction (WMD) and their supporters. This action builds on OFAC’s June 15, 2023 designation of Choe Chol Min, a Beijing-based representative of the DPRK’s Second Academy of Natural Sciences (SANS). OFAC designated Choe Chol Min pursuant to E.O. 13382 for acting or purporting to act for or on behalf of SANS, an entity whose property and interests in property are blocked pursuant to E.O. 13382. SANS was designated by the U.S. Department of State on August 30, 2010, pursuant to E.O. 13382 for materially contributing to the DPRK’s WMD programs; it was also designated for a UN asset freeze on March 7, 2013. SANS has subordinate defense-related procurement and proliferation entities that it uses to obtain commodities and technology to support the DPRK’s defense research and development programs.
DPRK PROCUREMENT OF FOREIGN ITEMS
The DPRK’s ballistic missile and space programs rely on foreign-sourced materials and components that it cannot produce domestically. To procure these materials and components, the DPRK uses an extensive network of procurement agents overseas, including officials who operate from DPRK diplomatic missions or trade offices, as well as third-country nationals. The DPRK also leverages foreign-incorporated companies to purchase items in support of its ballistic missile and weapons production. These companies consolidate and repackage items for onward shipment to the DPRK, concealing the true end-user from the manufacturers and distributors of the items.
SANS representative Choe Chol Min has worked with DPRK weapons trading officials, PRC nationals, and other associates to purchase and procure a range of items, including items known to be materials used in the production of DPRK ballistic missiles. Choe Chol Min received procurement requests from the DPRK and coordinated with associates to fulfill those orders.
THE SHI QIANPEI NETWORK
Shi Qianpei is a Chinese national and key facilitator for Choe Chol Min. Shi Qianpei worked with Choe Chol Min to procure various items, including metal sheets that are known to be used in the production of North Korean missiles, according to the North Korea Ballistic Missile Procurement Advisory.
Choe Chol Min also worked to procure sensitive electronics through Shi Qianpei. Shi Qianpei’s employees Du Jiaxin and Wang Dongliang assisted with the procurement efforts. Chen Tianxin, Shi Qianpei’s wife, acted as his business partner and was involved in his procurement activities for Choe Chol Min. Shi Anhui is Shi Qianpei’s father and has also been involved in aiding DPRK procurement activity. As late as 2023, Shi Qianpei fulfilled procurement requests from Choe Chol Min for electronic devices, including the acquisition of items likely intended to support the DPRK space and satellite program.
- Shi Qianpei is being designated for providing, or attempting to provide, financial, material, technological or other support for, or goods or services in support of, Choe Chol Min, an individual whose property and interests in property are blocked pursuant to E.O. 13382.
- Du Jiaxin, Wang Dongliang, Chen Tianxin, and Shi Anhui are being designated for providing, or attempting to provide, financial, material, technological or other support for, or goods or services in support of, Shi Qianpei, an individual whose property and interests in property are blocked pursuant to E.O. 13382.
Beijing Sanshunda Electronics Science and Technology Co., Ltd. (Beijing Sanshunda), Qidong Hengcheng Electronics Factory (Qidong Hengcheng), and Shenzhen City Mean Well Electronics Co., Ltd (Shenzhen City Mean Well) are companies used by Shi Qianpei and his associates to procure items and materials on behalf of Choe Chol Min.
Chen Tianxin is the legal representative, chief executive officer, and manager of Beijing Sanshunda. Chen Tianxin is also the legal representative and chief executive officer of Beijing Jinghua Qidi Electronic Technology Co., Ltd. (Beijing Jinghua Qidi), a company in which Wang Dongliang serves as a board member.
Shi Anhui is the legal representative, manager, and sole shareholder of Qidong Hengcheng. Shi Anhui is also the legal representative and majority owner of Shenzhen City Mean Well, a company in which Shi Qianpei is a member of the board of supervisors.
- Beijing Sanshunda and Beijing Jinghua Qidi are being designated pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, Chen Tianxin, a person whose property and interests in property are blocked pursuant to E.O. 13382.
- Qidong Hengcheng and Shenzhen City Mean Well are being designated pursuant to E.O. 13382 for being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, Shi Anhui, an individual whose property and interests in property are blocked pursuant to E.O. 13382.
Han Dejian is a supplier of metal alloys sheets via his company, Yidatong Tianjin Metal Materials Co., Ltd. (Yidatong). Shi Qianpei relied on Han Dejian for his metal material orders. As late as 2023, Shi Qianpei received procurement requests for metal alloys from Choe Chol Min that were then fulfilled by Han Dejian.
- Han Dejian is being designated for providing, or attempting to provide, financial, material, technological or other support for, or goods or services in support of, Shi Qianpei, an individual whose property and interests in property are blocked pursuant to E.O. 13382.
- Yidatong is being designated pursuant to E.O. 13382 for being owned or controlled by, or acting acted or purporting to act for or on behalf of, directly or indirectly, Han Dejian, an individual whose property and interests in property are blocked pursuant to E.O. 13382.
Han Dejian and Yidatong were previously sanctioned by the U.S. Department of State on May 20, 2024 pursuant to the Iran, North Korea, and Syria Nonproliferation Act (INKSNA). INKSNA provides for the imposition of measures on entities or individuals for the transfer to or acquisition from Iran, Syria, or North Korea of equipment or technology controlled under multilateral export control lists or otherwise having the potential to make a material contribution to the proliferation of WMD or cruise or ballistic missile systems.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. sanctions, including the factors that OFAC generally considers when determining an appropriate response to an apparent violation.