Key Learning Moments
- The DoS, and specifically analysts beneficiaries, would find it useful to have an internal wikipedia-like page compiling information related to sanctioned entities;
- The permeability of sanctions enforcement is not necessarily a negative thing: it can be a net positive for US strategic interests;
- US blacklisting practices are stricter than UN ones.
This week, we tested three hypotheses:
- Different governmental agencies conducting enforcement do not adequately share information related to their activity in this respect;
- Although a list of bad actors already exists, and it is managed by the US Treasury, the list it not comprehensive and under-inclusive: a less formal blacklist would facilitate impacting shippers involved in violations;
- Not all sanctions are created equal: some have a stronger impact than others. The government can and should prioritize their enforcement strategically.
Our interviewees this week involved people from State Department and Intelligence, as well as a wide range of experts in North Korea economy and markets. We also had the opportunity to interview a plurality of journalists and bloggers.
As to the first hypothesis, it was difficult for us to fully prove or disprove the lack of information sharing within different agencies. The issue is classified, and as such we were unable to get a clear-cut answer. We were able to find out that a task – force agency does exist for the purpose of information sharing. However, the actors that are not part of it do not benefit from this information sharing – for this reason, they should be the focus of our further research.
Secondly, we tested the possibility of creating a less formal lists of “bad actors” and its potential utility. Notably, there was no consensus between intelligence and other enforcement authorities, to whom we submitted the idea. The primary concern with the list is the costs it would bear: as such, further pursuit of this idea will require an attentive balance of its costs and its benefits.
Lastly, we discussed with our interviewees the differential impact of sanctions. We learned that, in some cases, sanction violation can be a positive outcome for the US strategy. Whether and how the US could better prioritize enforcement remains unclear, but we plan on engaging our sponsor and, potentially, other intelligence contacts to further elaborate a possible prioritization scenario.
Our Potential MVPs
Based on these findings, we started drafting three possible product directions.
First, to encourage better sharing of interagency information, we could develop an internal Government Sanctions Wikipedia. Having a centralized database, in fact, would significantly decrease the time necessary for State Department negotiators/desk officers to perform démarches, once intel is received regarding a sanction-evasion related activity. We know a similar, external tool, called Pyongyang Papers, already exists and is open sourced. The information is gathered from media outlets, or other public reports. However, we believe the database is flawed. We plan on digging in more deeply in the upcoming weeks to flesh out how it can be improved and effectively deployed.
Second, to increase barriers to ship-to-ship transfers for North Korean ships, we could build a government sponsored, yet informal “Watchlist” of “bad actors”. This product would achieve two goals: first, it would name and shame the companies that help with sanction evasion, leveraging the possibility of a deterrent effect; second, it would prevent shipping companies from claiming “ignorance” when conducting transfers to North Korea.
One idea we had is to rely on technology, such as automation, to help deploy a more effective product than the currently existing Treasury OFAC List. In fact, as it came up in one of our interviews:
“…if there were a way that was more dynamic in helping to understand who you are dealing with – that would give you a better shot at doing enforcement. Being able not to be manually update these tools could be extremely valuable. There might be ways to look at previous cases where we know that there was a network going on and train through AI a system to look for similar patterns. ”
Third, we will continue brainstorming on a potential prioritization tool. Before further focusing on it, we will discuss with our sponsor whether this direction might reveal itself to be useful or not.
This week, we focused on conversations with a wide range of North Korean experts, including former State Department and Intelligence officials, journalists and policy experts.
- William Brown, Former ODNI
- Alastair Gale, Wall Street Journal
- David Slayton, US Navy, Hoover
- Andy Kim, Former CIA
- Chloe Chung, Korean Foreign Ministry
- Todd Buchwald, Former Ambassador for Global Criminal Justice
- Richard Johnson, Nuclear Threat Initiative
- Kyle Ferrier, Korea Economic Institute of America
- Andray Abrahamian, Chosen Exchange
- Eddie Fishman, Former State
- Joshua Stanton, One Free Korea
- Sig Hecker, Stanford Nuclear Energy Expert
- Matt Prusak, Korean Institute
- Michael Matheson, Former State