On November 3, 2010, the Office of Foreign Assets Control (“OFAC”) announced that it issued the North Korea Sanctions Regulations (“Final Rule”) to implement Executive Order 13466 of June 26, 2008 (“Executive Order 13466”) and Executive Order 13551 of August 30, 2010 (“Executive Order 13551”) (collectively, the “Executive Orders”).

Executive Order 13466, among others, blocks all property and interests in property of North Korea or a North Korean national, that, pursuant to the President’s authorities under the Trading with the Enemy Act (50 U.S.C. App. 1 et seq), were blocked as of June 16, 2000 and remain blocked.

Executive Order 13551, blocks all property and interests in property that are in the U.S., that hereafter come within the U.S., or that are or hereafter come within the possession or control of any U.S. person, of persons that have, among others: (i) imported, exported or reexported to/from North Korea any arms or related materials; (ii) provided training, advice or other services or assistance or engaged in financial transactions related to the manufacture, maintenance, or use of any arms or related materials to be imported, exported or reexported to, into, or from North Korea; (iii) imported, exported or reexported luxury goods to or into North Korea; or (iv) engaged in money laundering or other illicit economic activity that involves or supports the Government of North Korea. The names of persons designated pursuant to Executive Order 13551 are published on OFAC’s Specially Designated Nationals and Blocked Persons List.

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