Advisory on the Cyber Threat Posed by North Korea

Date issued: Apr. 15 2020

TURBOFAC Commentary (131 words)

Notes:

1) As is common with most "advisories," this advisory on the North Korea-related cyber threat does not clarify the scope and operation of any OFAC-administered sanctions provisions. Instead, it serves to alert the regulated community to tactics used by sanctioned persons to evade sanctions (or in this case, worse). For practical purposes, the import of this document would be that, in the event that a person were investigated for engaging in prohibited or sanctionable conduct, OFAC would consider any such person to have been given notice as to the contents of this document, with the expectation that the contents were taken account of in the formation of a risk-based compliance program. In that regard, the guidance is particularly notable for U.S. persons involved in the cryptocurrency sector.