ADVISORY: Guidance on the Democratic People's Republic of Korea Information Technology Workers; FACT SHEET: Guidance on the Democratic People's Republic of Korea Information Technology Workers

Date issued: May. 16 2022

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TURBOFAC Commentary (206 words)

Notes:

1) As is common with most "advisories," this advisory on North Korea Ballistic Missile Procurement 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. 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 that hire IT workers, especially remotely. The specific verification-based diligence measures suggested appear aimed specifically at freelance work and payment platform companies that serve as...