DoJ Aid to NK re Sanctions Evasion


On Nov. 29, DoJ made arrest re advice to NK to evade sanctions.


  • US citizen Virgil Griffith was arrested for a presentation in North Korea on evasion of sanctions using cryptocurrency and blockchain technology thereby violating the IEEPA.
  • Charges
  • Despite State Dept. denying him permission, in 2019, Griffith traveled to the DPRK to attend and present at the “Pyongyang Blockchain and Cryptocurrency Conference”.
  • At the conference, Griffith and other attendees discussed how the DPRK could use blockchain and cryptocurrency technology to launder money and evade sanctions.
  • Griffith explained the benefits of a “smart contract,” that could be utilized by the DPRK.
  • Several attendees who appeared to work for the government, asked Griffith specific questions about blockchain and cryptocurrency and aspects of those technologies.
  • After the conference, he began plans to facilitate the exchange of cryptocurrency between the DPRK and South Korea, despite knowing he was violating NK sanctions.
  • Griffith encouraged other US citizens to attend the same conference the following year.
  • Finally, he gave his intention to renounce US citizenship and buy one from elsewhere.
  • Enforcement
  • Maximum term of 20 years is prescribed by Congress and is provided here for information only, as any sentencing of the defendant will be determined by the judge.
  • Nov. 28, Griffith was arrested at LAX and will be presented in federal court on Nov. 29.
  • Dec. 2019 Criminal Charges
  • On Dec. 2, 2019, DoJ announced charges unsealed against Griffith for violating IEEPA.
  • Per criminal complaint, IEEPA and EO 13466 prohibit US persons from exporting any goods, services, or technology to North Korea; Griffith accused of conspiracy to violate.

Regulators DoJ
Entity Types Bank; Corp; MSB
Reference PR, 12/2/2019; LR, PR, 11/29/2019; IEEPA; EO 13466
Functions AML; Compliance; Financial; Legal; Technology
Countries North Korea (DPRK); United States of America; Cross-Border
Products Corporate; Cryptocurrency
Regions Am; AP
Rule Type Enforcement
Rule Date 11/29/2019
Effective Date 11/29/2019
Rule Id 68290
Linked to N/A
Reg. Last Update 12/2/2019
Report Section AML & Enforcement

Last substantive update on 12/02/2019