September Busy for Congress CR and the Debt Limit Increase

Posted on August 28, 2017August 28, 2017 by Denise Simon

Developments in 2017 to learn more go here.

On March 7, 2017, CBO issued estimates that extraordinary measures could suffice to meet federal obligations until sometime in the fall of 2017.¹⁴¹ Such estimates are subject to substantial uncertainty due to changes in economic conditions, federal revenue flows, changes in the amounts and timing of federal payments, and other factors. On March 8, 2017, Treasury Secretary Mnuchin notified Congress that he would invoke authorities to use extraordinary measures after March 15, 2017, to ensure continued payment of federal obligations.¹⁴² On March 16, 2017, Secretary Mnuchin notified congressional leaders that he had indeed exercised those authorities.¹⁴³ The debt limit on that date was reset at $19,809 billion.¹⁴⁴

In testimony before Congress on May 24, 2017, Administration officials urged Congress to raise the debt limit before its summer recess.¹⁴⁵ Office of Management and Budget (OMB) Director Mick Mulvaney stated that the federal receipts were coming in more slowly than projected, which could imply that Treasury’s capacity to meet federal obligations could be exhausted sooner than previously projected.¹⁴⁶ A Goldman Sachs analysis found, however, that some major categories of tax receipts had shown stronger growth.¹⁴⁷

On June 28, 2017, Treasury Secretary Mnuchin sent a letter to Congress stating that extraordinary measures would be used until September 29, 2017.¹⁴⁸ Secretary Mnuchin’s letter did not state that Treasury’s cash reserves or borrowing capacity would be exhausted on that date, but he did describe the need for legislative action by that date as “critical.” Others have estimated that the U.S. Treasury would likely be able to meet federal obligations until sometime in early October 2017.¹⁴⁹ Treasury cash balances and borrowing capacity in mid-September, however, are projected to fall well below levels the U.S. Treasury has considered prudent to maintain operations in the face of significant adverse events.¹⁵⁰

The Constitution grants Congress the power to borrow money on the credit of the United States—one part of its power of the purse—and thus mandates that Congress exercise control over federal debt. Control of debt policy has at times provided Congress with a means of raising concerns regarding fiscal policies. Debates over federal fiscal policy have been especially animated in recent years. The accumulation of federal debt accelerated in the wake of the 2007-2008 financial crisis and subsequent recession. Rising debt levels, along with continued differences in views of fiscal policy, led to a series of contentious debt limit episodes in recent years.

The 2011 debt limit episode was resolved on August 2, 2011, when President Obama signed the Budget Control Act of 2011 (BCA; S. 365; P.L. 112-25). The BCA included provisions aimed at deficit reduction and allowing the debt limit to rise in three stages, the latter two subject to congressional disapproval. Once the BCA was enacted, a presidential certification triggered a $400 billion increase. A second certification led to a $500 billion increase on September 22, 2011, and a third, $1,200 billion increase took place on January 28, 2012.

Federal debt again reached its limit on December 31, 2012. Extraordinary measures were again used to allow payment of government obligations until February 4, 2013, when H.R. 325, which suspended the debt limit until May 19, 2013, was signed into law (P.L. 113-3). On that date, extraordinary measures were reset, which would have lasted until October 17, 2013, according to Treasury estimates issued in late September 2013. On October 16, 2013, enactment of a continuing resolution (H.R. 2775; P.L. 113-46) resolved a funding lapse and suspended the debt limit through February 7, 2014. On February 15, 2014, a measure to suspend the debt limit (S. 540; P.L. 113-83) through March 15, 2015, was enacted. Once that debt limit suspension lapsed after March 15, 2015, the limit was reset at $18.1 trillion. On October 15, 2015, Treasury Secretary Jacob Lew stated that extraordinary measures would be exhausted no later than November 3, 2015, although a relatively small cash reserve would be on hand. Lower tax receipts and higher trust fund inflows, however, reduced Treasury’s headroom more than had been expected. The Bipartisan Budget Act of 2015 (BBA2015; H.R. 1314; P.L. 114-74), which relaxed certain discretionary spending limits, suspended the debt limit through March 15, 2017.

On March 16, 2017, the debt limit was reset at $19,809 billion and Treasury Secretary Steven Mnuchin notified Congress that he had invoked authorities to use extraordinary measures. CBO estimated that those measures could meet federal obligations until sometime in the fall of 2017, although in May 2017, Administration officials said slower than expected growth in revenues could require earlier action. Some independent analysts still expect that the U.S. Treasury could meet federal obligations until sometime in early October 2017. On June 28, 2017, Treasury Secretary Mnuchin notified Congress that extraordinary measures would be used until September 29, 2017, and urged action before that date.

Total federal debt increases when the government sells debt to the public to finance budget deficits, which adds to debt held by the public, or when the federal government issues debt to certain government accounts, such as the Social Security, Medicare, and Transportation trust funds, in exchange for their reported surpluses—which adds to debt held by government accounts; or when new federal loans outpace loan repayments. The sum of debt held by the public and debt held by government accounts is the total federal debt. Surpluses reduce debt held by the public, while deficits raise it. This report will be updated as events warrant.

Hey Barcelona, ISIS Threatens Again

Posted on August 24, 2017August 24, 2017 by Denise Simon

New video message from The Islamic State: “The First Rain: The Raid of Barcelona – Wilāyat al-Khayr”

el Pais: A week after terrorist attacks in Catalonia which left 15 people dead and over 100 injured, the so-called Islamic State (ISIS) has released a video online warning of more attacks in Spain.

In the video two jihadists can be heard speaking Spanish with an Arabic accent and proclaiming: “Allah willing, Al Andalus will become once again what it was, part of the caliphate.” Al Andalus was the name given to the territory of southern and central Spain controlled for more than five centuries by Muslims.

“If you can’t make the hegira (journey or exodus) to the Islamic State, carry out jihad where you are; jihad doesn’t have borders,” says one of the men in the video whose face is uncovered and who is identified by a video title as Abu Lais Al Qurdubi, or Abu Lais “of Cordoba,” the southern Spanish city that was the capital of Al Andalus.

Later, the jihadist adds: “Spanish Christians: don’t forget the Muslim blood spilled during the Spanish inquisition. We will take revenge for your massacre, the one you are carrying out now against the Islamic State.”

According to police sources, the individual speaking is 22-year-old Muhammad Yasin Ahram Pérez from Cordoba. His father, the Moroccan Abdelah Ahram, 42, is currently in prison in Tangier for his active role in radical jihadism.

His mother Tomasa Pérez, from a Catholic family in Malaga, met Ahram in 1984. In 2014, she left Spain with her six children, including Muhammad, the oldest sibling, to go to Syria and live in territory controlled by the Islamic State.

The name of the other participant in the video is given as Abu Salman Al Andalus (Abu Salman ‘of Andalusia). His face is covered and only his eyes can be seen. He has a rifle on his shoulder.

“We hope that Allah accepts the sacrifice of our brothers in Barcelona. Our war with you will continue until the world ends,” he says.

The jihadist group ISIS declared a worldwide caliphate in 2014 with ISIS leader Abu Bakr al-Baghdadi named as the caliph, or leader of all Muslims worldwide. However, this declaration has been rejected by mainstream Muslims while ISIS has been designated a terrorist organization by the United Nations and many individual countries.

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Back in School, But is it Really About Education

Posted on August 23, 2017August 23, 2017 by Denise Simon

Children of all grades are being dropped off by parents, are walking in groups to school or you can find them at bus stops where a parent keeps a watchful eye until that big yellow thing on wheels shows up.

Another year of Federally managed education where school choice is a fragmented option in systems across the country while other counties are teaching CommonCore or International Baccalaureate. Other schools have failing systems with regard to meeting grade standards yet still other locations are just financially broke due to teacher unions like the Illinois system. The debate continues on homeschooling, charter schools, parochial systems, private systems of religious/church bases education centers, as to which is best for independent students and choices.

Try this video to grab your attention:

Visiting the Federal government website for education we see this:

Overview and Mission Statement

ED’s mission is to promote student achievement and preparation for global competitiveness by fostering educational excellence and ensuring equal access.

ED was created in 1980 by combining offices from several federal agencies. ED’s 4,400 employees and $68 billion budget are dedicated to:

Establishing policies on federal financial aid for education, and distributing as well as monitoring those funds.

Collecting data on America’s schools and disseminating research.

Focusing national attention on key educational issues.

Prohibiting discrimination and ensuring equal access to education.

Government agencies are assigned an inspector general to audit those departments for compliance. There is no recent report from the IG except one in 2014 that reviewed financial matters, data compliance and accounting systems.

While performing financial audits is laudable, reviews must be performed on the educators themselves, the student performance and reviews of textbooks and the syllabus. Exactly who is teaching your child or grandchild, what are they teaching and how is it taught?

How many foreign students are in your local system that require countless accommodations including translators? How is the affecting pace and subject delivery?

The chatter regarding education seems to circle around the notion of ‘school choice’ but what is the definition of that term? What is the menu of choices and does that menu have any valuable affect on the students’ quality of education?

Open house is a new school year event where parents or guardians meet the teachers, walk the halls of the building for orientation and talk about the plans for the school year. Sounds wonderful unless tangible answers and compliance are realized. Oh yeah, there are all kinds of fees that need to be paid for ridiculous items including parking, school supply funds, meal tickets, technology usage, medical supplies and library systems to mention a few.

What about school safety and access to non-school related visitors? What about after school activities and class size? Is there really a teacher with certification heading the class or is there some intern or teaching assistant?

Parents and students are in a permission society when it comes to education, meaning can my student participate in an advanced curriculum or is there additional help for reading or algebra?

Schools across the country have been adapting to social pressures rather than just structure and teaching.

Pew Research posted an academic fact sheet in February of 2017 showing in part the following:

One of the biggest cross-national tests is the Programme for International Student Assessment (PISA), which every three years measures reading ability, math and science literacy and other key skills among 15-year-olds in dozens of developed and developing countries. The most recent PISA results, from 2015, placed the U.S. an unimpressive 38th out of 71 countries in math and 24th in science. Among the 35 members of the Organization for Economic Cooperation and Development, which sponsors the PISA initiative, the U.S. ranked 30th in math and 19th in science. Go here for more details.

Quality academics in all grades requires attention by parents and guardians and for that matter all property taxpayers. It is the single most important investment in the future of this great nation and cannot be hijacked by special interest groups, unions or local politicians.

Have you volunteered at the local school? Have you asked the right questions? Do you even know the principal’s name?

Chinese Operative(s) Working for N Korea in New York?

Posted on August 23, 2017August 23, 2017 by Denise Simon

Primer:

Yesterday, this site published the FBI related story. If You Don’t Think the FBI is Busy, N Korea Investigation

Still, our State Department and White House appears to think that we can have honest dialogues with China regarding North Korea? Additionally, it was just reported a month ago that Beijing has a major spy network in the United States with up to 25,000 Chinese intelligence officers and 15,000 recruited agents.

Not feeling confident on this, are you? Perhaps some expulsions are in order…

Did Owner of Million-Dollar U.S. Home Help North Korea Evade Sanctions?

GREAT NECK, N.Y. — The five-bedroom house in New York’s Long Island suburbs — listed for nearly $1.3 million — boasts a southern exposure and proximity to a country club.

But here’s what’s more interesting: The seller, a Chinese national named Sun Sidong, has been linked by American security experts to a network of Chinese companies under Treasury sanctions for helping companies and individuals who support North Korea’s nuclear and ballistic missile programs.

According to Chinese corporate filings, Sun is the listed owner of Dandong Dongyuan Industrial Co., which has shared an email address with another Chinese company, Dandong Zhicheng Metallic Material Co., a coal exporter suspected of helping North Korea evade sanctions.

For the NBC video go here.

The coal company and “four related front companies” were targeted by a federal search warrant allowing prosecutors to secretly monitor their financial transactions at eight U.S. banks, seizing any funds stemming from illegal sanctions-busting, according to a May federal court ruling.

The ruling, by U.S. District Judge Beryl Howell of Washington, D.C., said the eight American financial institutions — Bank of America, Wells Fargo, BNY Mellon, Citibank, Deutsche Bank, HSBC, JP Morgan Chase, and Standard Chartered Bank — had already processed upwards of $700 million in prohibited transactions involving North Korea since 2009. The ruling does not allege any wrongdoing by any of the banks.

The Great Neck, N.Y., home purchased by Sun Sidong in December 2016. Google Maps

On Tuesday, the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Dandong Zhicheng Metallic Material Co. and its primary shareholder in response to “attempted evasion of U.S. sanctions.”

That shareholder, a Chinese businessman named Chi Yupeng, was also named in a civil complaint filed Tuesday by the Justice Department seeking a money laundering penalty against the firm, as well as the seizure of $4 million in funds allegedly laundered for North Korea’s ruling party. The complaint alleges that front companies controlled by Chi Yupeng comprise one of the largest financial facilitators for North Korea.

Chi Yupeng hung up on NBC News several times when asked for comment.

The Justice Department also moved to seize nearly $7 million from a Singapore firm over similar allegations, and Treasury levied sanctions against a number of other Chinese and Russian entities — 16 in total — it accused of helping North Korea evade sanctions.

WATCH: At China-North Korea Border, Business as Usual Despite Sanctions

The government’s investigation was supported by the Center for Advanced Defense Studies (C4ADS), a non-profit U.S. think tank, as part of a new get-tough approach to North Korean sanctions that began in the Obama administration and is accelerating under President Trump, current and former U.S. officials say.

Chi Yupeng is the majority owner of Dandong Zhicheng Metallic Material Co. A civil complaint filed by the Justice Department Tuesday alleges that companies he controls helped North Korea evade sanctions. Bohai University

While it’s widely assumed that North Korea has for years been subjected to punishing international pressure as it defied the world and advanced toward a nuclear missile capability, the sanctions against North Korea have been full of holes, experts say — far less restrictive, for example, than the measures that brought Iran to the nuclear bargaining table.

Sun’s Great Neck house is an example of how the alleged sanction-busting networks can stretch around the globe, even to the luxe suburbs of Long Island. “The fact that you have somebody who’s engaged in trade that is potentially not just sanctioned, but dangerous, and that individual then invests in real estate in the United States reflects that there are holes in the system,” NBC News National Security Analyst Juan Zarate said.

The North Korea sanctions targeted specific military technology, “but what you didn’t see until quite recently are these kind of broader sanctions to go after the North Korean economy as a whole,” said Peter Harrell, who was the deputy assistant secretary for counter threat finance and sanctions in the State Department from 2012 to 2014.

The Friendship Bridge crosses the Yalu River and connects Dandong, China with Sinuiju, North Korea. David Lom / NBC News

Nor was there an aggressive enforcement effort against banks and individuals doing business with Pyongyang. As a result, the North Korean economy has grown steadily over the last decade, analysts say. And while the country as a whole remains extremely poor, the elite live relatively well amid a building boom of gleaming skyscrapers in the capital.

“Until February of 2016, U.N. sanctions against North Korea were strong on paper but poorly enforced, and U.S. sanctions against North Korea were comparatively weak — weaker than our sanctions against Belarus and Zimbabwe,” said Joshua Stanton, a North Korea expert and former Army officer.

Now, that is changing — though it may be too late. North Korea tested a missile that many experts say could strike the U.S. mainland, and American intelligence officials say the country may be months away from being able to mount a nuclear warhead on such a missile.

Still, aided by new sanctions imposed in the past year, the Trump administration is moving to increase economic pressure on North Korea, by targeting the Chinese companies that have for years helped the North fund its military activities.

“Justice is stepping it up by going after the Chinese banks,” said Anthony Ruggiero, a senior fellow at the Foundation for Defense of Democracies, who served as the nonproliferation advisor to the U.S. delegation to the 2005 Six-Party Talks on North Korea.

In June, the U.S. Treasury Department designated China’s Bank of Dandong — based in a city on the North Korean border that serves as a center of trade between the two countries — to be a “primary money laundering concern.” It said the small bank “acts as a conduit for illicit North Korean financial activity.” Two Chinese individuals were also targeted in the government’s action.

Last September, the Justice Department charged Dandong-based businesswoman Ma Xiaohong with evading sanctions and laundering millions of dollars for North Korea. Ma has not made a court appearance and her whereabouts are unclear.

Sen. Cory Gardner, R-Colo., recently introduced a bill that would cut off entities that do business in North Korea, including the top ten Chinese importers of North Korean goods, from using the American financial system.

This photo taken July 5, 2017 shows the Bank of Dandong, a Chinese bank accused of laundering money for North Korea. Kyodo

In August, the U.N. Security Council unanimously passed new sanctions meant to pressure Pyongyang’s export revenue. They crack down on North Korea’s primary exports — including iron, iron ore, coal, lead, lead ore and seafood — and target banks and joint ventures with foreign companies.

C4ADS, which focuses on international security, uses sophisticated software and business records to map links between companies involved with North Korea.

In June, the group published a report — titled “Risky Business” — naming Sun, who owns the Great Neck house, as part of a network that may be exporting technology that could be used in North Korea’s missile program.

Chinese business records cited by C4ADS show Sun owns 97 percent of Dandong Dongyuan Industrial Co. Ltd., a general-purpose trading firm whose businesses include the sale of automobiles, machinery, natural resources, and general household products, the report says. NBC News confirmed that the records show Sun as primary shareholder.

Related: North Korea Already Has a Devastating Weapon: Cyberattacks

Customs records indicate the firm has exported to three countries: North Korea, the Democratic Republic of the Congo, and the United States. From 2013 to 2016, the company sent $28 million worth of material to North Korea, the records show.

For example, Dandong Dongyuan Industrial Co. sent North Korea a shipment of radio navigational aid apparatus valued at nearly $800,000 in June 2016, the C4ADS report said. Experts at the James Martin Center for Nonproliferation Studies concluded that “this category might contain guidance devices for ballistic missiles.”

NBC News reviewed shipment data from Panjiva, which tracks global trade. It shows more than 60 shipments of items by Sun’s company to North Korea that fall into the category of “nuclear reactors, boilers, machinery and mechanical appliances; parts thereof.” This broad category is set by the country of origin, in this case the Chinese government. Experts say dual-use items like these help the Kim regime evade sanctions that are explicitly designed to prevent its nuclear capability.

“The danger with the export of dual-use items is that they appear to be legitimate. These are things that could be used for normal purposes,” Zarate said. “You have parties that are willing to export what are really dangerous items to a regime that has been sanctioned, and trying to use the cloak of legitimate commerce in order to do that.”

Parts for approximately 30,000 rocket-propelled grenades, manufactured in North Korea and seized in Egyptian waters, hidden under 2,300 tons of iron ore. UN Security Council Panel of Experts

C4ADS also links Sun to a ship carrying arms from North Korea to an unknown destination. In August 2016, a cargo vessel flying a Cambodian flag was intercepted by Egyptian authorities entering the Suez Canal with parts for 30,000 rocket-propelled grenades aboard. The grenade parts were hidden under 2,300 tons of iron ore, which is one of the newly banned mineral exports targeted by the U.N.’s recent sanctions program.

According to shipping records reviewed by NBC News, one of Sun Sidong’s companies owned the vessel from April 2012 until August 2014, when ownership was transferred to a company controlled by Sun Sihong, who according to C4ADS is Sun’s sister.

In 2015, Sun registered a New York-based company called Dongyuan Enterprise USA. On March 2, it received a shipment of “used furniture” from Dandong Dongyuan Industrial Co., Sun’s Chinese company. Originally shipped from Dandong, the cargo traveled to the U.S. from Busan, South Korea, according to its bill of lading.

The real estate agent who brokered the sale of the Great Neck home to Sun recalled that the family was expecting furniture to arrive from China.

An assembled rocket-propelled grenade intercepted in the Jie Shun shipment. The ship’s bill of lading misidentified the parts as pieces of an underwater pump. UN Security Council Panel of Exp

Sun, whose U.S. company operates out of a New York City address he does not own, bought the Great Neck property near the country club for $1.1 million in December 2016.

The house is already on the market again. Sun’s U.S. real estate broker told NBC News that’s because Sun “doesn’t want to do business here.”

One lesson of Sun’s activities is that targeting a small number of key actors could put a severe dent in North Korean’s effort to evade sanctions, according to David Johnson, the executive director of C4ADS.

“The networks that perpetrate sanctions evasion for North Korea are limited, centralized, and vulnerable,” Johnson said. “That is, we can touch them, there are very few pressure points, and we can make a major impact.”

If You Don’t Think the FBI is Busy, N Korea Investigation

Posted on August 22, 2017August 22, 2017 by Denise Simon

Frankly, $11 million is not much considering what North Korea and the Kim regime are doing in the illicit activity realm.

Meanwhile Kim issued yet another threat to President Trump:

North Korea vows merciless retaliation in response to drills

FNC: President Trump is pictured looking out over a Guam graveyard cluttered with crosses in a photoshopped image from the newest propaganda film — and grim warning — from North Korea.

The regime followed the video with a statement posted through its KCNA news agency, saying Trump “spouted rubbish” and frequently tweeted about “weird articles of his ego-driven thoughts” and attacking South Korea’s “puppy-like” Defense Minister Song Young-moo for “pinning hope on that mad guy.”

But the picture of a graveyard believed to be in Guam may be the most rattling in the video, given dictator Kim Jong Un’s repeated threats to strike the U.S. territory with a missile. The video also features Vice President Pence engulfed in flames. More here.

FOR IMMEDIATE RELEASE

Tuesday, August 22, 2017

United States Files Complaints to Forfeit More Than $11 Million From Companies That Allegely Laundered Funds To Benefit Sanctioned North Korean Entities

WASHINGTON – The United States filed two complaints today seeking imposition of a civil money laundering penalty and to civilly forfeit more than $11 million from companies that allegedly acted as financial facilitators for North Korea, announced U.S. Attorney Channing D. Phillips, Michael DeLeon, Special Agent in Charge of the FBI’s Phoenix Field Office, and Michael J. Anderson, Special Agent in Charge of the FBI’s Chicago Field Office.

The actions, filed in the U.S. District Court for the District of Columbia, represent two of the largest seizures of North Korean funds by the Department of Justice. One complaint seeks $6,999,925 associated with Velmur Management Pte Ltd., a Singapore-based company. The other seeks $4,083,935 from Dandong Chengtai Trading Co. Ltd., also known as Dandong Zhicheng Metallic Material Co., Ltd., a company in Dandong, China.

The lawsuits follow a similar complaint, filed in June 2017, seeking more than $1.9 million from Mingzheng International Trading Limited, a company based in Shenyang, China.

The complaints allege that the companies have participated in schemes to launder U.S. dollars on behalf of sanctioned North Korean entities. According to the complaints, the companies participated in financial transactions in violation of the International Emergency Economic Powers Act (IEEPA), the North Korean Sanctions and Policy Enhancement Act of 2016, and federal conspiracy and money laundering statutes. Today’s complaints are the first filed actions based on the 2016 North Korean Sanctions and Policy Enhancement Act.

“These complaints show our determination to stop North Korean sanctioned banks and their foreign financial facilitators from aiding North Korea in illegally accessing the United States financial system to obtain goods and services in the global market place,” said U.S. Attorney Phillips. “According to the complaints, these front companies are supporting sanctioned North Korean entities, including North Korean military and North Korean weapons programs. Working with our law enforcement partners, we will vigorously enforce vital sanctions laws.”

“The complaints allege that these companies are assisting North Korea in evading sanctions, which is in direct conflict with our national security interests,” said Special Agent in Charge DeLeon, of the FBI’s Phoenix Field Division. “We will continue to use the necessary resources to expose these types of actions and investigate those who utilize the U.S. banking systems for illegal activities.”

U.S. v. Velmur Management Pte., Ltd. (Velmur) and Transatlantic Partners Pte. Ltd. (Transatlantic)

This complaint alleges that Velmur and Transatlantic Partners Pte. Ltd. (Transatlantic) laundered United States dollars on behalf of sanctioned North Korean banks that were seeking to procure petroleum products from JSC Independent Petroleum Company (IPC), a designated entity. The complaint also seeks a civil monetary penalty against Velmur and Transatlantic for prior sanctions and money laundering violations related to this scheme.

According to the complaint, designated North Korean banks use front companies, including Transatlantic, to make U.S. dollar payments to Velmur. The complaint relates to funds that were transferred through four different companies and remitted to Velmur to wire funds to JSC Independent Petroleum Company (IPC), a Russian petroleum products supplier. On June 1, 2017, the Department of the Treasury’s Office of Foreign Asset Controls (OFAC) designated IPC. The designation noted that IPC had a contract to provide oil to North Korea and reportedly shipped over $1 million worth of petroleum products to North Korea.

The United Nations Panel of Experts reported in 2017 on the methods used by North Korean banks to evade sanctions and continue to access the international banking system. Specifically, despite strengthened financial sanctions, North Korean networks are adapting by using greater ingenuity in accessing formal banking channels. This includes maintaining correspondent bank accounts and representative offices abroad which are staffed by foreign nationals making use of front companies. These broad interwoven networks allow the North Korean banks to conduct illicit procurement and banking activity.

An FBI investigation revealed that Velmur’s and Transatlantic’s activities mirror this money laundering paradigm. Specifically, companies identified in the complaint and Transatlantic act as front companies for designated North Korean banks.

The government is seeking to forfeit $6,999,925 that was wired to Velmur in May 2017. The U.S. dollar payments, which cleared through the U.S., are alleged to violate U.S. law, because the entities were surreptitiously making them on behalf of the designated North Korean Banks, whose designation precluded such U.S. dollar transactions. The government also is seeking imposition of a monetary penalty commensurate with the millions of dollars allegedly laundered by Velmur and Transatlantic.

U.S. v. Dandong Chengtai Trading Co., Ltd. (Dandong Chengtai), also known as Dandong Zhicheng Metallic Material Co., Ltd.

This complaint alleges that Dandong Chengtai and associated front companies controlled by Chi Yupeng, a Chinese national, comprise one of the largest financial facilitators for North Korea. According to the complaint, Dandong Chengtai conspired to evade U.S. economic sanctions by facilitating prohibited U.S. dollar transactions through the United States on behalf of the North Korean Workers’ Party, a sanctioned entity.

The complaint further alleges that the North Korean government relies on exports of coal as its primary means of obtaining access to foreign currency, and that the North Korean military controls the amount of coal produced and its subsequent export. The North Korean government uses proceeds of coal sales to fund its weapons of mass destruction program and missile programs. Coal generates more than $1 billion in revenue per year for North Korea. The investigation revealed that Dandong Chengtai is one of the largest importers of North Korean coal in China, and has continued to engage in illicit U.S. dollar transactions related to its coal sales to benefit North Korea.

The complaint alleges that Dandong Chengtai facilitated wire transfers denominated in U.S. dollars for purchases of goods that are well outside the scope of a mineral trading company. Financial records reveal that purchases of bulk commodities such as sugar, rubber, petroleum products, and soybean oil, among others, were in fact destined for North Korea.

As reported in findings by the Treasury Department and the United Nations Panel of Experts, North Korean financial facilitators frequently establish and maintain offshore U.S. dollar accounts for the purposes of remitting wire transfers denominated in U.S. dollars on behalf of sanctioned North Korean entities. These broad interwoven networks allow sanctioned North Korean entities to conduct illicit procurement and banking activity.

The government is seeking to forfeit $4,083,935 that Dandong Chengtai wired on June 21, 2017 to Maison Trading, using their Chinese bank accounts. The investigation revealed that Maison Trading is a front company operated by a Dandong Chengtai employee. These U.S. dollar payments, which cleared through the United States, are alleged to violate U.S. law, because the recent North Korean sanctions law specifically barred U.S. dollar transactions involving North Korean coal and the proceeds of these transactions were for the benefit of the North Korea Worker’s Party, whose designation precluded such U.S. dollar transactions.

This case relates to a previously unsealed opinion from Chief Judge Beryl A. Howell of the U.S. District Court for the District of Columbia, which found that probable cause existed to seize funds belonging to Dandong Chengtai.

The claims made in the complaints are only allegations and do not constitute a determination of liability.

The FBI’s Phoenix Field Office is investigating the case involving Velmur Management Pte Ltd. and Transatlantic Partners Pte., Ltd. The FBI’s Chicago Field Office is investigating the case involving Dandong Chengtai Trading Co. Ltd. Both investigations are being supported by the FBI Counterproliferation Center.

Assistant U.S Attorneys Arvind K. Lal, Zia M. Faruqui, Christopher B. Brown, Deborah Curtis, Ari Redbord, and Brian P. Hudak, all of the U.S. Attorney’s Office for the District of Columbia, are prosecuting both cases. Paralegal Specialist Toni Anne Donato and Legal Assistant Jessica McCormick are providing assistance.