The U.S. State Department has issued an alert to companies who may be doing business with North Korea and are unaware of the fact that North Korea is masking and misrepresenting services and goods produced in North Korea and exported under a different name, or providing service and manufacturing products by a company outside of North Korea, but North Korea-controlled.
Near absolute restrictions are applicable to U.S. persons, including U.S. companies and their foreign business units, on conducting any business with North Korean companies or North Korean citizens.
U.S. companies need to ensure the country of origin of raw materials, and goods and services purchased from foreign sources, to ensure that they do not involve production in or with subcontracted support of North Korean companies.
It is also important that U.S. companies dealing with foreign individuals representing a foreign company know where the company they are representing is located, and that they carry out appropriate due diligence on the potential sale and/or shipment – this includes obtaining appropriate end-use and end-user certification.
North Korea is making a concerted effort to mask or mispresent their involvement with or manufacturing of services their company is providing, presenting an added risk to U.S. companies.
Comprehensive and clearly discernable import and export controls are important to ensuring that a company is compliant with U.S. import and export laws and regulations.
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