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4/27/23, 9:06 AM

Treasury Targets Actors Facilitating Illicit DPRK Financial Activity in Support of Weapons Programs | U.S. Department of the Treas…

U.S. DEPARTMENT OF THE TREASURY
Treasury Targets Actors Facilitating Illicit DPRK Financial
Activity in Support of Weapons Programs
April 24, 2023

WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control
(OFAC) sanctioned three individuals for providing support to the Democratic People’s Republic
of Korea (DPRK) through illicit financing and malicious cyber activity. The DPRK launders stolen
virtual currency and deploys information technology (IT) workers to fraudulently obtain
employment to generate revenue in virtual currency to support the regime and its unlawful
weapons of mass destruction and ballistic missile programs. Today’s actions have been taken in
close coordination with the Republic of Korea.
“The DPRK’s use of illicit facilitation networks to access the international financial system and
generate revenue using virtual currency for the regime’s unlawful weapons of mass
destruction(WMD) and ballistic missile programs directly threatens international security,” said
Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The
United States and our partners are committed to safeguarding the international financial
system and preventing its use in the DPRK’s destabilizing activities, especially in light of the
DPRK’s three launches of intercontinental ballistic missiles (ICBMs) this year alone.”

SUPPORT TO DPRK MALICIOUS CYBER ACTIVITY
Wu Huihui (Wu) is being designated pursuant to Executive Order (E.O.) 13722 for providing
material support to the Lazarus Group, which was previously designated pursuant to that same
authority on September 13, 2019. Cheng Hung Man (Cheng) is being designated pursuant to
E.O. 13722 for providing material support to Wu.
The Lazarus Group targets institutions such as financial, manufacturing, publishing, media,
entertainment, and international shipping companies, as well as government and military and
critical infrastructure, using tactics such as cyber espionage, data theft, monetary heists, and
destructive malware operations. The group is controlled by the Reconnaissance General Bureau
(RGB), the DPRK’s primary intelligence bureau and main entity responsible for the country’s
malicious cyber activities, and is involved in the trade of DPRK arms. On March 23, 2022, the
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Lazarus Group carried out the largest virtual currency heist to date, stealing almost $620 million
in virtual currency from a blockchain project linked to the online game Axie Infinity.
Since at least late 2017, the DPRK has been engaged in virtual currency thefts and fraud
schemes to generate revenue for its unlawful ballistic missile and weapons of mass destruction
programs. According to public reporting, DPRK cyber actors were able to steal an estimated $1.7
billion worth of virtual currency through various hacks in 2022 alone. The DPRK often launders
the stolen virtual currency through a complicated process to convert stolen virtual currency into
fiat currency. The DPRK leverages a network of over-the-counter (OTC) virtual currency traders
to convert crypto currency into fiat currency. Frequently, DPRK actors use these networks of
OTC traders, including People’s Republic of China (PRC)-based OTC traders, to conduct
transactions on their behalf to avoid detection by financial institutions or competent
authorities.
Wu is a PRC-based OTC virtual currency trader who facilitated the conversion of virtual currency
stolen by DPRK actors working with the Lazarus Group to fiat currency. In 2021, Wu processed
multiple transactions that converted millions of dollars’ worth of virtual currency into fiat
currency for DPRK cyber actors. Cheng is a Hong Kong-based OTC trader who worked with Wu
to remit payment to companies in exchange for virtual currency. Cheng utilized front companies
to enable DPRK actors to bypass countering illicit finance requirements at financial institutions
and access the U.S. financial system. Cheng worked with Wu and other virtual currency OTC
traders who facilitate conversion of virtual currency stolen by DPRK hackers into fiat currency
for use by the DPRK government.

ILLICIT ACCESS TO THE INTERNATIONAL FINANCIAL
SYSTEM
OFAC is also designating Sim Hyon Sop (Sim) pursuant to E.O. 13382, for acting for or on behalf
of the Korea Kwangson Banking Corp (KKBC), an entity previously designated under E.O. 13382,
an authority that targets proliferators of WMD and their supporters. KKBC was designated for
providing financial services in support of both Tanchon Commercial Bank and Korea Hyoksin
Trading Corporation, entities previously designated pursuant to E.O. 13382.
Sim is a KKBC Deputy Representative who recently relocated to Dandong, China. The DPRK’s
Foreign Trade Bank, also previously designated under E.O. 13382, is KKBC’s parent company.
According to the Financial Crimes Enforcement Network (FinCEN), the DPRK uses and maintains
a network of financial representatives, primarily in the PRC, who operate as agents for DPRK
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financial institutions. In this capacity, these representatives orchestrate schemes, set up shell
companies, and manage surreptitious bank accounts to move and disguise illicit funds and
finance the DPRK’s WMD and ballistic missile programs. In his position with KKBC, Sim has
coordinated millions of dollars in financial transfers for the DPRK.
The DPRK also generates revenue through the deployment of IT workers who fraudulently
obtain employment in the technology and virtual currency industries. The DPRK maintains a
workforce of thousands of highly skilled IT workers around the world to generate revenue that
contributes to its unlawful WMD and ballistic missile programs. Since September 2021, Sim has
received tens of millions of dollars in virtual currency. That virtual currency was, in part, derived
from DPRK individuals unknowingly hired by U.S.-based companies to provide IT development
work. These DPRK IT workers typically use fake personas to apply for jobs at these companies.
When the IT workers obtain employment, they are known to request to be paid in virtual
currency and send the majority of their salaries through a complicated laundering pattern to
funnel these illegally obtained funds back to the DPRK. Sim appears to be receiving money from
IT development work being fraudulently conducted by DPRK individuals abroad and,
separately, directing OTC traders, including Wu and Cheng, to send payments to front
companies with funds derived from stolen virtual currency, so that those front companies can
make payments in fiat currency for goods, such as tobacco and communications devices, on
behalf of the DPRK regime.
Today’s action is the result of OFAC’s ongoing collaboration with the Department of Justice and
the Federal Bureau of Investigation. On April 18, 2023, a federal indictment was returned in the
U.S District Court for the District of Columbia for Wu, Cheng, and Sim. Today’s action was also
closely coordinated with the Republic of Korea, which is also designating Sim for his illicit
activities

SANCTIONS IMPLICATIONS
As a result of today’s action, pursuant to E.O. 13722 and E.O. 13382, all property and interests in
property of the persons named 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, 50 percent or more by one or more blocked persons are also
blocked.
In addition, persons that engage in certain transactions with the individuals or entities
designated today may themselves be exposed to designation. Furthermore, any foreign
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financial institution that knowingly facilitates a significant transaction or provides significant
financial services for any of the individuals or entities designated today could be subject to U.S.
correspondent or payable-through account sanctions.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and
add persons to the Specially Designated Nationals and Blocked Persons (SDN) List, but also
from its willingness to remove persons from the SDN List consistent with the law. The ultimate
goal of sanctions is not to punish, but to bring about a positive change in behavior. For
information concerning the process for seeking removal from an OFAC list, including the SDN
List, please refer to OFAC’s Frequently Asked Question 897.
For additional information regarding the DPRK’s IT workers, see the May 16, 2022, Guidance on
the Democratic People’s Republic of Korea Information Technology Workers.
For detailed information on the process to submit a request for removal from an OFAC sanctions
list.
For guidance on complying with sanctions, see OFAC’s Sanctions Compliance Guidance for the
Virtual Currency Industry and OFAC’s FAQs on virtual currency.
Find identifying information on the individuals sanctioned today here.
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