United States Files Complaint to Forfeit More Than $3 Million from Companies Accused of Laundering Funds to Benefit Sanctioned North Korean Entities

            WASHINGTON - The United States has filed a complaint to forfeit $3,167,783 associated with a cooperating Singapore-based company (“Cooperating Company”); Apex Choice Ltd. (“Apex Choice”), a Chinese-based wax company; and Yuanye Wood Ltd. (“Yuanye Wood”), a Chinese-based wood company, announced U.S. Attorney for the District of Columbia Jessie K. Liu and Michael DeLeon, Special Agent in Charge of the FBI Phoenix Field Office. 

            The complaint alleges that these three companies laundered United States dollars on behalf of sanctioned North Korean banks.  According to the complaint, the North Korean banks used these laundered funds as part of a scheme to procure goods for the North Korean regime, as well as to illegally access the U.S. financial market. 

            The three companies allegedly were part of a scheme to launder payments to subsequently sanctioned entities, to include: Velmur Management Pte. Ltd. (“Velmur”), which the U.S. Treasury Department sanctioned for procuring Russian petroleum products for North Korea; Dandong Zhicheng Metallic Material Co. (“Dandong Zhicheng”), which the Treasury Department sanctioned for purchasing coal from North Korea, and then in turn laundering the proceeds of those sales to purchase items for North Korea, including nuclear and missile components; and Wee Tiong (S) Pte. Ltd. (“Wee Tiong”), which the Treasury Department sanctioned for laundering money through the U.S. financial system on behalf of North Korea.

            The complaint also seeks a civil monetary penalty against Apex Choice and Yuanye Wood for prior sanctions and money laundering violations related to this scheme.

            “This complaint alleges that parties in China and Singapore are part of a global money laundering network that coordinates with front companies to move North Korean money through the United States and violate the sanctions imposed by our government on North Korea,” said U.S. Attorney Jessie K. Liu. “This case demonstrates that we will seek significant remedies to address companies that violate U.S. national security, regardless of where they are doing business.”

            “The FBI has found numerous foreign companies participating in North Korea’s scheme to launder money,” said FBI Special Agent in Charge Michael DeLeon.  “As North Korea continues to find creative ways to circumvent international sanctions, we hope this investigation will compel foreign companies to do their due diligence when it comes to conducting business transactions and/or making third party payments using U.S. dollars. The FBI will continue to dedicate substantial resources to these types of investigations in order to stop illicit transactions. Companies engaging in deceptive banking practices may face criminal or civil action, and could be forced to forfeit funds.”

            The complaint was filed on Nov. 26, 2018, in the U.S. District Court for the District of Columbia. According to the complaint, designated North Korean banks use companies, including the “Cooperating Company,” Apex Choice, and Yuanye Wood, to make U.S. dollar payments to North Korean front companies, which are managed by sanctioned North Korean banks. 

            The United Nations Panel of Experts described in 2017 how North Korean banks have been able 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 that are staffed by foreign nationals making use of front companies. These broad interwoven networks allow North Korean banks to conduct illicit procurement and banking activity.

            The complaint alleges activity by the three companies that tracks this paradigm. The first company which is the subject of the complaint, the one identified as “Cooperating Company,” has agreed to the forfeiture of its funds.  As part of its agreement to cooperate with the government, this company acknowledged that it was directed by an unauthorized Chinese money remitter to send payments to North Korean companies, when this company was seeking discounted rates for exchanging currency.  Apex Choice, a wax company, is accused of paying numerous North Korean front companies with no relation to the wax industry.  In a submission to the government, Apex Choice claimed that the known North Korean financial facilitators were wax companies in China.  Chilbo, a North Korean wood exporting company based out of Equatorial Guinea, allegedly sold wood produced by North Koreans in forced labor camps to Yuanye Wood.  According to the complaint, Yuanye Wood paid known North Korean financial facilitators for these services.

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

            The FBI’s Phoenix Field Office is investigating the case. Assistant U.S Attorneys Arvind K. Lal, Zia M. Faruqui, and Brian P. Hudak are litigating the case, with assistance from Paralegal Specialist Brian Rickers, Legal Assistant Jessica McCormick and former Paralegal Specialist Toni Anne Donato, and Assistant U.S Attorney Ari Redbord.