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The APUNCAC Strategy to Counter DPRK Sanctions Evasion

Research output: Contribution to journalArticlepeer-review

Abstract

Transnational organized criminal groups operate in ways that are resistant to prosecution. In response, a proposed change in domestic law would aim to ensnare front men who serve to hide the identities of criminals, enabling prosecutors to flip them via cooperation agreements, thereby unraveling transnational criminal schemes. The proposal would require the ultimate beneficial sender, and ultimate beneficial recipient, to certify beneficial ownership (as sender and recipient) when funds are transacted in amounts exceeding USD 3000; and would require foreign financial institution personnel, who handle transactions with a nexus to a party to the Rule, to collect and submit, to a central law enforcement database, certifications by the ultimate beneficial sender and recipient of covered funds that are deposited, transmitted, transferred, or paid. Analysis of the proposed change in law indicates that it may be effective in addressing the impunity that prevails when organized criminal groups operate in China and North Korea in ways that appear to be outside the reach of domestic U.S. law enforcement authorities.

Original languageEnglish (US)
Article number9
JournalLaws
Volume15
Issue number1
DOIs
StatePublished - Feb 2026

Bibliographical note

Publisher Copyright:
© 2026 by the author.

UN SDGs

This output contributes to the following UN Sustainable Development Goals (SDGs)

  1. SDG 10 - Reduced Inequalities
    SDG 10 Reduced Inequalities
  2. SDG 16 - Peace, Justice and Strong Institutions
    SDG 16 Peace, Justice and Strong Institutions
  3. SDG 17 - Partnerships for the Goals
    SDG 17 Partnerships for the Goals

Keywords

  • APUNCAC beneficial owner rule
  • North Korea
  • banking
  • money laundering
  • oil smuggling
  • regulation
  • transnational organized crime

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