Tracing end use of sanctioned equipment
Verification of end use in DPRK: uncovered a multilayered scheme with intermediaries and offshore agents.
Case overview
- Category
- Supply Chain Audit
- Client
- International equipment manufacturer
- Duration
- 50 business days
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
Results
TriTrace Investigations 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.