U.S. Office of Foreign Assets Control (OFAC) announced over a $1 Million settlement with Bukit Muria Jaya (BMJ), a paper products manufacturer located in Indonesia. BMJ was fined for its civil liability for 28 violations of the North Korea Sanctions Regulations, 31 C.F.R. part 510. As U.S. Department of the Treasury stated, BMJ exported cigarette paper to persons and companies located in or doing business on behalf of the North Korea, also using an intermediary company in China that procured cigarette paper from BMJ on behalf of OFAC-designated Korea Daesong General Trading Corporation (“Daesong”) while Daesong was operating under an alias.

Per U.S. Treasury, the approximate value of Bukit Muria Jaya’s exports to North Korea was close to $1 Millions USD. The company had initially referenced North Korean entities on transactional documents, but at the request of its customers certain employees later replaced such references with the names of intermediaries located in third countries, including on invoices, packing lists, and bills of lading. Bukit Muria Jaya subsequently directed payments for its North Korea related exports to its U.S. dollar bank account at a non-U.S. bank. Several wire transfers related to stated exports to clear through U.S. banks were executed during two years timeframe. In summary, Bukit Muria Jaya have violated North Korea Sanctions Regulations when it caused U.S. banks to:

(i) deal in the property or interests in property of a Specially Designated National or Blocked Person;

(ii) export financial services to the DPRK; or

(iii) facilitate export transactions that would have been prohibited if engaged in by U.S. persons in violation of §§ 510.201, 510.206, and 510.211 of the North Korean Sanctions Regulations.

More information on this OFAC sanctions violation and respective statement on the settlement can be found here.

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