Tracing end use of sanctioned equipment
Verification of end use in DPRK: uncovered a multilayered scheme with intermediaries and offshore agents.
Supply Chain Audit | International equipment manufacturer | 50 business days
Tracing end use of sanctioned equipment

Context

The client, an organization, requested analysis to determine whether specific goods were reaching sanctioned jurisdictions, in particular North Korea.

Objective

To investigate the final delivery routes of the goods and identify possible violations of the sanctions regime imposed on North Korea. Specifically, the task was to verify supplier compliance with UN Security Council Resolutions: No. 1718 (2006), No. 2270 (2016), and No. 2375 (2017).

Methodology

OSINT investigation of the supply chain

GEOINT route analysis

Checks using export-import databases

Corporate analysis of intermediaries and agents

Profiling of end recipients

Data Sources

National and international corporate registries
Social networks and open digital profiles
Court and financial reports
Commercial databases of companies
Interviews with insiders and HUMINT

Results

TriTrace analysts uncovered a complex, multilayered scheme involving:

  • Logistics and fuel companies whose goods were resold using forfaiting schemes
  • Intermediaries from three jurisdictions facilitating sanctions evasion via financial and logistics structures
  • Several North Korean recipient companies registered in Pyongyang
  • Mapping of transportation infrastructure in one jurisdiction used for physical delivery

Findings included:

  • Both direct and indirect supplies of goods to North Korea
  • Discrepancies between export and payment routes (indicating concealment of the true recipient)
  • Potential risk of secondary sanctions from the U.S. and EU authories against the client

Client Impact

The client was provided with a detailed map of their supply chain, exposing direct and indirect links to sanctioned entities. Leveraging this evidence, the client's counsel worked with regulators to confirm compliance.

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