Lifting the Veil on a Sanctioned North Korean Entity

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A multinational company engaged Nardello & Co. to address allegations that its Chinese supplier was acquiring raw materials from a North Korean entity.

Facing allegations that its Chinese supplier was acquiring raw materials from a North Korean entity, a multinational company engaged Nardello & Co. to determine the beneficial ownership of the Pyongyang company. Discreet inquiries with North Korean defectors, academics, and intelligence sources in South Korea revealed that the entity was wholly owned by a company controlled by Office 39, a secretive organization that provides critical support to the North Korean leadership, in part through engaging in illicit economic activities such as currency counterfeiting and narcotics manufacturing. Defectors and other sources also claimed that forced labor had been used to mine the raw materials sold to the client’s supplier. While such claims could not be confirmed, they echoed accounts of practices documented extensively by human rights groups.

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