Foreign financial institutions have for some time been prohibited from engaging in most North Korea-related transactions that transit the U.S. financial system. In addition, as described in § 510.201(a)(3)(vi) of the NKSR, sanctionable activities of a foreign financial institution include, on or after September 21, 2017, knowingly conducting or facilitating any significant transaction:
- On behalf of any person whose property and interests in property are blocked pursuant to E.O. 13551, E.O. 13687, E.O. 13722, or E.O. 13810, or of any person whose property and interests in property are blocked pursuant to E.O. 13382 in connection with North Korea-related activities; or
- In connection with trade with North Korea.