By Lim Yong-myong, Former HRNK Research Intern
Edited by Greg Scarlatoiu, President & CEO of HRNK

          North Korea and Turkmenistan are both widely considered amongst the most oppressive regimes in the world.[1] While North Korea’s oppression is more well-known due to their repeated threats against many countries, including the United States, Turkmenistan’s oppressive system is far less studied and understood. This piece will compare the authoritarian regimes of North Korea and Turkmenistan, examining how each maintains control over its population.
 
          Turkmenistan, a post-Soviet country of 6 million people in Central Asia, is routinely rated as one of the least free countries in the world by Freedom House and The Economist’s Democracy Index. For almost two decades, the country has been ruled with an iron fist by the Berdimuhamedov Family. Before the Berdimuhamedov family, Turkmenistan was ruled by Saparmurat Niyazov, who famously banned car radios, ballet, and video games.[2] Elections in the country are largely for show, Turkmen citizens are restricted from leaving the country, freedom of speech and expression are almost non-existent, and the ruling family demands complete support from the people. Similarly, North Korea has been ruled by the Kim Family since 1948, who have presided over some of the most horrific human rights abuses of the modern world. From imprisoning entire families, forced labor camps, and no freedom of speech, to severe restrictions on access to food, health care, and economic opportunity, North Korea’s human rights abuses are numerous. 
 
          The authoritarianism of Turkmenistan and North Korea have similar origins. Turkmenistan's relationship with communism and authoritarianism began after the Russian Revolution of 1917, when Bolshevik forces extended control over Central Asia. By 1924, Turkmenistan became a Soviet Socialist Republic, integrating Marxist-Leninist principles with local governance. Soviet rule imposed collectivization, atheism, and centralized planning, deeply shaping Turkmen society until independence in 1991.
 
          North Korean communism emerged after Japan’s defeat in World War II, when Soviet forces occupied the North and installed Kim Il-sung, a former guerrilla fighter. Influenced by Marxism-Leninism and Stalinism, Kim established a one-party socialist state in 1948, blending communism with Korean nationalism and developing the Juche ideology of “self-reliance.”
 
Restrictions on Movement
           A key similarity between Turkmenistan and North Korea is that both heavily restrict their citizens from leaving their respective countries, which is in violation of Article 13 of the Universal Declaration of Human Rights.[3] It is a crime for North Koreans to leave the country without permission.[4] Similarly, Turkmenistan seeks to restrict its citizens from leaving the country. It is believed that Turkmen authorities are worried about their declining population because of emigration and decreasing birth rates, so they have attempted to make it harder for people to leave the country and for their citizens to remain abroad for an extended period of time. Starting in 2023, Turkmenistan ceased to renew passports of its citizens living abroad. This was done to try to force Turkmens living abroad to have to return to Turkmenistan, since having invalidated passports would force them to live illegally in their new country.[5] Additionally, Turkmenistan has taken measures to prohibit its citizens from leaving the country to attend foreign universities. It was also reported in 2018, that “young women were banned from leaving the country, and then all citizens under the age of 40 were removed from flights en masse.”[6]
 
Religious Persecution
               In Turkmenistan, Muslims and religious minorities face systematic persecution under the guise of combating extremism and enforcing mandatory military service. The government has accused numerous Muslims of “Islamic extremism,” subjecting them to closed trials, long prison sentences, and severe torture. These accusations are usually untrue, and the government levies those accusations against those they view as a threat to the regime. At the notorious Ovadan-Depe and Seydi Labor Camps, prisoners endure routine beatings, solitary confinement, and inhumane conditions. In one 2013 case, at least 20 Muslims were arrested and later tortured, with several dying in custody. Followers of the Kurdish theologian Said Nursi and Turkish cleric Fethullah Gülen have also been targeted, particularly after the 2016 coup attempt in Turkey. Dozens of Gülen supporters were imprisoned, tortured, and given lengthy sentences, some of whom died under suspicious circumstances.[7]
 
        Jehovah’s Witnesses, though not banned, are persecuted for their refusal to perform military service. Lacking a civilian alternative, conscientious objectors are criminalized under Article 219(1) of the Criminal Code. Since 2018, at least 22 Jehovah’s Witnesses have been imprisoned, with eight still held in the harsh Seydi Labor Camp. The state’s hostility includes threats, physical abuse, and extended sentences, as seen in the cases of Bahtiyar Atahanov and Serdar Dovletov. Despite mass presidential pardons, Jehovah’s Witnesses are excluded, and penalties have grown more severe. Conditions in detention are dire, with overcrowding, poor sanitation, and widespread illness such as tuberculosis. These actions reflect a broader campaign of religious repression, where beliefs outside state-sanctioned Islam or the military ethos are met with violence and imprisonment.[8]
 
        A 2020 white paper by the Database Center for North Korean Human Rights (NKDB) documented 1,411 cases of religious persecution in North Korea between 2007 and July 2020, including 126 killings and 94 disappearances, based on defector testimonies and other sources.[9] While a few state-sanctioned religious institutions, such as churches, exist—mainly in Pyongyang—they are tightly controlled by the government and primarily serve as showcases for foreign visitors. Unauthorized religious activity is harshly punished, and citizens are encouraged to report anyone possessing religious materials or engaging in unapproved worship.
 
             Defectors report that religious practitioners live in fear, often hiding their beliefs even from close family, due to the risk of being labeled disloyal and subjected to arrest or worse. Some clandestine religious activity reportedly occurs, including the distribution of unapproved Christian materials, although the scope of underground churches remains uncertain.[10]
 
           The United States, which lacks diplomatic relations with North Korea, continues to raise concerns about religious freedom through multilateral forums and bilateral engagement with other nations. In December 2023, the U.S. co-sponsored a UN resolution condemning North Korea’s systemic and gross human rights abuses, including extrajudicial executions of individuals practicing religion or free expression. Since 2001, North Korea has been designated a “Country of Particular Concern” under the International Religious Freedom Act, with accompanying sanctions reaffirmed most recently in November 2022.[11]
 
Food Insecurity 
               Turkmenistan and North Korea both have issues with food insecurity; however, it appears that North Korea has worse food insecurity than Turkmenistan. According to Human Rights Watch, the average Turkmen family spends 70%-80% of their income on food. Additionally, many people “spend several hours a day waiting in lines for subsidized food, and the lines and unpredictability of food supply cause great stress.”[12] While food insecurity exists in Turkmenistan, it does not appear to be as severe as food insecurity in North Korea. Widespread famine has been documented in North Korea, while there are no reports of famine in Turkmenistan. In 2023, a BBC reporter interviewed a North Korean woman who said “she knew a family of three who had starved to death at home.”[13] Furthermore, a UN report from 2022 indicated that over 45% of North Koreans were undernourished.[14] A possible explanation for North Korea having more food insecurity is that Turkmenistan has immense natural gas wealth and has a rather small population, which likely makes it easier for the Turkmen regime to feed its people. At the same time, Turkmenistan appears more concerned about their international image than North Korea. Turkmenistan likely cares about its image because it needs markets to sell its natural gas, and if there were widely documented and publicized human rights abuses in the country, many Western nations may be less willing to import natural gas from the country.[15]
 
Censorship and Propaganda
          Another area where North Korea and Turkmenistan share many similarities is media and information. Media censorship and propaganda in North Korea and Turkmenistan serve as key tools for authoritarian control, yet they slightly differ in degree, strategy, and underlying ideology. In North Korea, the media is entirely state-owned and tightly regulated by the Korean Workers’ Party, with no access to foreign news or the global internet.[16] The regime maintains an isolated domestic intranet and uses propaganda to uphold the image of the Kim dynasty, promote Juche, and vilify foreign adversaries. Propaganda in Turkmenistan centers on the glorification of the president, especially under Saparmurat Niyazov and Gurbanguly Berdimuhamedov, often portraying them as wise, athletic, and powerful. The content emphasizes Turkmen identity, nationalism, and neutrality in global affairs rather than external threats. While both regimes suppress dissent and flood public space with leader-focused propaganda, North Korea appears to enforce a deeper level of information control. Civil society and political activism are nearly non-existent in Turkmenistan and North Korea. Both countries have a cult of personality based around the ruling families. Statues, memorials, and folklore glorifying the leaders are put on display throughout both countries. And yet, Turkmenistan allows slightly more exposure to the outside world and uses softer cultural messaging. Ultimately, both states use media to construct political legitimacy and suppress alternative narratives, but North Korea's approach is more totalitarian and militarized, whereas Turkmenistan’s is more symbolic and personality driven. 
 
        The authoritarian origins of North Korea and Turkmenistan stem from different historical contexts, yet both were influenced by the Soviet Union, and its Stalinist ideology. North Korea’s authoritarian system was established in the aftermath of World War II, when the Korean Peninsula was divided and the Soviet Union installed Kim Il-sung as the leader of the northern zone in 1945. Kim quickly consolidated power, eliminated rivals, and founded a one-party state under the Korean Workers' Party. By the early 1950s, after the Korean War, North Korea had become a tightly controlled totalitarian regime centered around Kim’s cult of personality, reinforced by the ideology of Juche. In contrast, Turkmenistan’s authoritarianism emerged after the collapse of the Soviet Union in 1991. Saparmurat Niyazov, the former Communist Party leader of the Turkmen SSR, declared himself president for life and rebranded himself as "Turkmenbashi" (Father of the Turkmen). Drawing on Soviet structures, he established a hyper-personalized dictatorship marked by extreme nationalism, heavy censorship, and a bizarre cult of personality. Niyazov wrote a book called the Ruhnama, which focused on ethics and Turkmen culture. For many years this book was treated as a religious text that was required to be taught in school. People even needed to pass an exam on their knowledge of the Ruhnama to get their driving license.[17] Unlike North Korea’s dynastic, militarized origins, Turkmenistan's authoritarianism grew out of a post-Soviet power vacuum and was less ideological, relying instead on personal loyalty, oil wealth, and state-controlled symbolism. While both regimes centralized power and suppressed dissent, North Korea’s origins are rooted in revolutionary communism and geopolitical division, whereas Turkmenistan’s stem from a post-colonial continuity of Soviet-style governance that has been transformed into a highly personalized autocracy.
 
Foreign Policy
          A key difference between North Korea and Turkmenistan is the way they approach foreign relations and security. Turkmenistan is an officially neutral state that seeks to maintain cordial relations with all countries. While Turkmenistan has been quite isolated for decades, it has maintained relations with all major countries. It also appears Turkmenistan is attempting to reduce its isolation from the world by increasing foreign investment and making it easier for tourists to visit the country.[18] This is in contrast to North Korea, which is hostile to many nations and poses challenges to global security. North Korea also supports various hostile actors that are opposed to the West, including Russia, Iran as well as Iran’s terrorist proxies.[19] The difference in how these two countries approach international relations is a key reason that North Korea is much more well-known on the global stage, albeit for sinister reasons. 
 
            In conclusion, North Korea and Turkmenistan represent two of the most repressive authoritarian regimes in the world, each of which has been shaped by distinct historical trajectories, but are regrettably united in their extreme curtailment of human rights and freedom. Both countries emerged from Soviet influence, with North Korea institutionalizing its totalitarianism in the wake of World War II and Turkmenistan developing its authoritarianism after the collapse of the USSR. Despite these different origins, both regimes rely on centralized power, personality cults, censorship, and brutal repression to maintain control. Their restrictions on emigration, suppression of religious freedom, and tight media control reflect systematic strategies to isolate their populations from external influences and crush dissent.
 
           However, key differences shape their global perception and internal dynamics. North Korea, with its militarized, dynastic dictatorship and aggressive foreign policy, is a constant source of international concern for many countries, including South Korea and the United States. Its severe food shortages, nuclear weapons program, and open hostility toward the West have placed it under intense global scrutiny. Turkmenistan, on the other hand, remains less visible on the world stage, partly due to its official neutrality, reliance on natural gas diplomacy, and softer approach to propaganda. Yet, beneath this quieter facade lies a similarly brutal system, where political opposition, religious minorities, and civil society are ruthlessly suppressed. 
 
          Ultimately, the comparison between North Korea and Turkmenistan reveals not only shared patterns of repression, but also how authoritarianism adapts to different political, economic, and cultural contexts. While North Korea exemplifies a closed, militaristic totalitarian regime, Turkmenistan illustrates how a resource-rich, personality-driven autocracy can maintain tight control without attracting the same level of international attention. Both cases serve as sobering reminders of the resilience and adaptability of authoritarianism, and the ongoing challenges facing efforts to promote human rights and freedom in deeply closed societies.
 
 

Bibliography
“Citizens of Turkmenistan Being Prevented From Flying Abroad”, Times of Central Asia, May 6, 2024,https://timesca.com/citizens-of-turkmenistan-being-prevented-from-flying-abroad/

Geigenberger, Laura. “North Korea ranks dead last in latest World Press Freedom Index”, Daily NK, May 4, 2023, https://www.dailynk.com/english/north-korea-ranks-dead-last-latest-world-press-freedom-index/

Gorokhovskaia, Yana and Cathryn Grothe. “Freedom in the World 2025,” Freedom House,  2025, https://freedomhouse.org/sites/default/files/2025-03/FITW_World2025digitalN.pdf  

Hassan, Tirana. “North Korea Events of 2023”, Human Rights Watch, 2024, https://www.hrw.org/world-report/2024/country-chapters/north-korea#:~:text=North%20Korean%20law%20states%20that,between%20January%20and%20September%202023.

Ibragimova, Galiya. “Could a Woman End Turkmenistan’s International Isolation?”, Carnegie Endowment, June 27, 2025, https://carnegieendowment.org/russia-eurasia/politika/2025/06/turkmenistan-internal-power-shift?lang=en

Kalder, Kalder.  “A dictator's guide to the universe” The Guardian,  December 29, 2006, https://www.theguardian.com/books/booksblog/2006/dec/29/adictatorsguidetotheunive

Kim, Ellen and Salamata Bah. “The DPRK-Hamas Relationship”, CSIS, March 27, 2024, https://www.csis.org/analysis/dprk-hamas-relationship

Mackenzie, Jean. “North Korea: Residents tell BBC of neighbours starving to death”, BBC, June 14, 2023,https://www.bbc.com/news/world-asia-65881803

Morton, Jason. “Religious Prisoners in Turkmenistan’s Gulag”, UNITED STATES COMMISSION on INTERNATIONAL RELIGIOUS FREEDOM, August, 2020, https://www.uscirf.gov/sites/default/files/2020%20Religious%20Prisoners%20in%20Turkmenistans%20Gulag.pdf

“Turkmenistan: Denial, Inaction Worsen Food Crisis”, Human Rights Watch, September 23, 2020, https://www.hrw.org/news/2020/09/23/turkmenistan-denial-inaction-worsen-food-crisis

“Turkmenistan is trying to come out of its shell”, Eurasianet, March 5, 2025, https://eurasianet.org/turkmenistan-is-trying-to-come-out-of-its-shell

Yeon-soo, Kwak. “46% of North Koreans undernourished, UN report says”,,The Korea Times, March 18, 2025, https://www.koreatimes.co.kr/foreignaffairs/northkorea/20250318/46-of-north-koreans-undernourished-un-report-says

“2022 Report on International Religious Freedom: North Korea”, U.S. Department of State, 2023, https://www.state.gov/reports/2023-report-on-international-religious-freedom/north-korea/

“2023 Report on International Religious Freedom: North Korea”, U.S. Department of State, 2024, https://www.state.gov/reports/2023-report-on-international-religious-freedom/north-korea/

UN General Assembly, “Resolution 217A (III), Universal Declaration of Human Rights, A/RES/217(III)”, December 10, 1948, https://www.un.org/en/about-us/universal-declaration-of-human-rights
 


[1] Yana Gorokhovskaia and Cathryn Grothe, “Freedom in the World 2025,” Freedom House,  2025, https://freedomhouse.org/sites/default/files/2025-03/FITW_World2025digitalN.pdf  
[2] Tom Parfitt, “Bizarre, brutal and self-obsessed. Now time's up for Turkmenistan's dictator” The Guardian, December 21, 2006,https://www.theguardian.com/world/2006/dec/22/tomparfitt.mainsection
[3] UN General Assembly, “Resolution 217A (III), Universal Declaration of Human Rights, A/RES/217(III)”, December 10, 1948, https://www.un.org/en/about-us/universal-declaration-of-human-rights
[4] Tirana Hassan, “North Korea Events of 2023”, Human Rights Watch, 2024, https://www.hrw.org/world-report/2024/country-chapters/north-korea#:~:text=North%20Korean%20law%20states%20that,between%20January%20and%20September%202023.
[5] “Citizens of Turkmenistan Being Prevented From Flying Abroad”, Times of Central Asia, May 6, 2024,
https://timesca.com/citizens-of-turkmenistan-being-prevented-from-flying-abroad/
[6] Ibid.
[7] Jason Morton, “Religious Prisoners in Turkmenistan’s Gulag”, UNITED STATES COMMISSION on INTERNATIONAL RELIGIOUS FREEDOM, August, 2020, https://www.uscirf.gov/sites/default/files/2020%20Religious%20Prisoners%20in%20Turkmenistans%20Gulag.pdf
[8] Ibid.
[9] “2023 Report on International Religious Freedom: North Korea”, U.S. Department of State, 2024, https://www.state.gov/reports/2023-report-on-international-religious-freedom/north-korea/
[10] Ibid.
[11] “2022 Report on International Religious Freedom: North Korea”, U.S. Department of State, 2023, https://www.state.gov/reports/2023-report-on-international-religious-freedom/north-korea/
[12] “Turkmenistan: Denial, Inaction Worsen Food Crisis”, Human Rights Watch, September 23, 2020, https://www.hrw.org/news/2020/09/23/turkmenistan-denial-inaction-worsen-food-crisis
[13] Jean Mackenzie, “North Korea: Residents tell BBC of neighbours starving to death”, BBC, June 14, 2023,
 https://www.bbc.com/news/world-asia-65881803
[14] Kwak Yeon-soo, “46% of North Koreans undernourished, UN report says”,,The Korea Times, March 18, 2025, https://www.koreatimes.co.kr/foreignaffairs/northkorea/20250318/46-of-north-koreans-undernourished-un-report-says
[15] “Turkmenistan is trying to come out of its shell”, Eurasianet, March 5, 2025, https://eurasianet.org/turkmenistan-is-trying-to-come-out-of-its-shell
[16] Laura Geigenberger, “North Korea ranks dead last in latest World Press Freedom Index”, Daily NK, May 4, 2023, https://www.dailynk.com/english/north-korea-ranks-dead-last-latest-world-press-freedom-index/
[17] Dan Kalder, “A dictator's guide to the universe” The Guardian,  December 29, 2006, https://www.theguardian.com/books/booksblog/2006/dec/29/adictatorsguidetotheunive
[18] Galiya Ibragimova, “Could a Woman End Turkmenistan’s International Isolation?”, Carnegie Endowment, June 27, 2025, https://carnegieendowment.org/russia-eurasia/politika/2025/06/turkmenistan-internal-power-shift?lang=en
[19] Ellen Kim and Salamata Bah, “The DPRK-Hamas Relationship”, CSIS, March 27, 2024, 
https://www.csis.org/analysis/dprk-hamas-relationship

By Sloane Thor
Edited by Diletta De Luca
​​
Introduction
          In recent years, dozens and hundreds of North Koreans have escaped their homeland and made the perilous passage across the Tumen River into China[1]. Many North Korean escapees flee from conditions defined by a chronic lack of food and rights due to the songbun system that leaves them disadvantaged and at risk of political persecution. Others leave to seek an income to maintain and support their families in North Korea (often to pay for medical treatment for a relative),[2] or to reunite with family that already left the country. Since the DMZ is full of landmines, the only way to reach freedom for these escapees is to go through China in order to eventually reach resettlement in South Korea.
          North Korean escapees are also vulnerable due to their status as illegal immigrants in China. The Chinese government does not grant refugee status or asylum to North Korean escapees, as it instead considers them illegal economic migrants.[3] This causes many North Koreans who cross the border into China to be subjected to exploitation due their undocumented status and the Chinese government’s refusal to implement the non-refoulement principle (outlined in the U.N.’s 1951 Refugee Convention), meaning that escapees who are caught will be forcibly repatriated back to North Korea where they will be heavily punished. They are often tortured and sent to prison camps for their defection, as it is seen as “treachery against the nation” by the North Korean Ministry of People’s Security.[4] North Korean escapees are not able to obtain working permits, or residency permits due to their “illegal”status in China.[5] This makes them dependent on Chinese citizens in order to obtain housing or work. Coupled with the lack of Chinese language skills, this leaves them extremely exploitable.
          North Korean female escapees are particularly easy targets for traffickers and brokers. They are easily manipulated due to age, status, risk of refoulment, and gender. The most prominent human rights abuses that befall North Korean women escapees are forced marriage, prostitution, and sexual slavery in the cyber realm.
 
The Vulnerability of North Korean Women
          The vulnerability of North Korean women makes them particularly easy targets for traffickers and brokers. Korean NGOs estimate that up to 80% of the female escapees become victims of human trafficking.[6] Victims are usually between the ages of 12 and 29 but some research reports victims as young as 9 years old.[7] Being undocumented and at the risk of refoulement makes it easy for traffickers to control them through threats of exposure to officials if they do not comply with their demands. The risk of refoulement means that victims of human trafficking are unable to ask for help or report to officials as they risk being sent back to North Korea and thus being treated worse than prior to escaping.
The undocumented status of North Korean women in China provides an environment where physical, sexual, mental, and emotional abuse are used to control the women to mold them into complaisant sex slaves. In a recent report published by Korea Future it is noted that North Korean women are subjected to “supplementary violence designed to induce compliance and delivered in the forms of starvation, physical beatings, and verbal threats of repatriation”.[8] This makes them easier to control and less likely to try to escape.

Arranged Marriages and the One-Child Policy
          30% of North Korean women who are trafficked in China are sold into forced marriages with Chinese men, often in rural areas.[9] This is because in China there is a high demand for young, sexually exploitable, and “marriage material” women as an effect of the “One-Child Policy”. This measure was enacted in 1979 and abolished in 2016, and it existed in a law that limited couples to only having one child as an attempt to curb a rapidly rising population. However, the policy resulted in a surplus of over 40 million boys[10] due to the male-dominated culture. The families tended to favor boys over girls as it was preferred to “have a male child to carry on the family’s name and inheritance.”[11] Thus, many Chinese women during this time were born in cities while few to none were born in rural areas as farm work was often carried out by men. This resulted in a high demand for brides in rural areas since the cities were far away and the Chinese women there were becoming educated and setting their sights on wealthier marriage partners This created a lucrative industry of “black-market brides” (trafficking victims from other countries) to remedy the vast gender imbalance, especially in rural areas of China.
Once a price is agreed upon by a broker and the soon-to-be Chinese husband, North Korean wives are relocated to the Chinese families who, fearing their escape,  heavily restrict their freedom of movement for weeks or months by withholding access to a mobile phone, the internet, or the ability to travel outside the property without a family member.[12] While in the village, North Korean women nevertheless are unlikely to be reported to the police or to other local authorities. Additionally, even if they are reported to local authorities, it remains highly unlikely that their presence is revealed to higher level officials. This can be due to bribes or the Chinese concept of guanxi, a system of social networks and relationships that facilitate deals and influence transactions. Guanxi, while an important part of Chinese culture, facilitates the trafficking industry by causing citizens to protect the illegal acts of others to gain favor or receive an advantage or benefit in return.
 
Prostitution and Brothels
          While forced marriage has long been the predominant fate for trafficked North Korean women, it has quickly been overtaken by prostitution. Korea Future estimates that prostitution in general accounts for about 6% of China’s GDP.[13] Currently, it is estimated that 50% of North Korean women who are trafficked in China are sold into brothels, karaoke bars, or other forms of forced prostitution.[14] Prostitution in China seems to be managed by criminal organizations who remain reliant upon the guanxi system and rarely operate nationwide as they prefer to opt for small regions or cities.[15] Many of these North Korean escapees work “in brothels masqueraded as entertainment or service venues, namely: bathhouses, saunas, karaoke bars, cafes, massage parlors, beauty parlors, barbershops, hair salons, small hotels, and restaurants”.[16] It is estimated that North Korean women engage with 2 to 4 men a night and are subjected to multiple forms of rape.[17] They are confined to the establishment and work under the instruction of a pimp or madam. In Shanghai, to avoid abduction by rival organizations and to signify ownership, some North Korean women are branded with tattoos, such as lions and butterflies.”[18] Criminal organizations work closely with corrupt or bribed officials to prevent the escape by the abducted North Korean escapees.[19]
 
The Chinese Cybersex Industry
          With the emergence of the internet, North Korean women who become trafficking victims have been increasingly sold into the cybersex industry. These women are trapped in small apartments with a handful of other women and are sexually assaulted or forced to perform graphic sexual acts via webcam online for paying male clientele.[20] “Unlike bars or brothels with a permanent address, cybersex trafficking victims can be moved to and abused in any location with an internet connection and a webcam, or just a mobile phone”.[21] The cybersex exploitation of North Korean victims takes place on platforms that can be “rudimentary, deliberately inconspicuous, or simply well-known and widely available video-chat services”.[22] The majority of clients utilizing these platforms, particularly chatrooms, tend to be from South Korea, where pornography and prostitution are illegal.[23]
          Off-camera, victims face “coercion, starvation, intimidation, and brutalization”.[24] They are forced to cover up bruises sustained from the acts performed or from abuse by their handler with makeup and cover up hair loss with wigs.[25] Many are often subjected to drug abuse in order to force them to work longer hours and “dull their shame”. [26] Their handlers often dangle the chance of freedom in front of them, telling them that they can go free once they have paid off their debt or the money it took to buy them. However, the women will never see a cent from their work and will not obtain freedom as they remain trapped in a vicious cycle of abuse.[27]

Concluding Remarks
          “Urgent and immediate action, which will run contrary to the prevailing politics of inter-Korean dialogue, is needed to save the lives of countless female North Korean refugees in China”.[28] China has been complicit when it comes to perpetrating and helping cover up human rights abuses against North Korean escapees within its own borders. It has notably become a hub and a destination country for human trafficking.[29] The usage of human trafficking, predominantly of vulnerable populations such as North Korean women, has been an unethical but easy remedy to the surplus of unmarried men left in the wake of the One-Child policy. China is notably a signatory of the 1951 Refugee Convention and 2003 Protocol to Prevent, Suppress, and Punish Trafficking in Persons put forth by the United Nations. Refusing to implement the non-refoulment principle violates the North Korean escapees’ fundamental human rights, from the right to a fair trial to protection from torture. By denying North Korean escapees the right to asylum and refusing to grant them the status of refugees, the Chinese government is directly responsible for the vulnerability and exploitation of North Korean people, particularly when it comes to women and children in their own country.
          As a signatory of multiple U.N. conventions to protect human rights and as a member of the U.N. Human Rights Council, it is of the utmost importance that China adhere to the bylaws it agreed to as it sets a precedent for other nations. The Chinese government should grant North Korean escapees the right to asylum in China as well as refugee status. Banning the practice of forced repatriation is imperative to implementing the non-refoulement principle.

Sloane Thor is a first-year graduate student in the Masters of Asian Studies Program at the Elliott School of International Affairs. As a recipient of the GWIKS Academy of Korean Studies Fellowship, she is excited to pursue her interest in North Korean human rights and inter-peninsular politics. Sloane Thor graduated cum laude from Wittenberg University with a major in East Asian Studies and minors in Mandarin Chinese language and Literature, Political Science, and International Studies. Her passion for North Korean human rights began after studying abroad in South Korea for a semester at Yonsei University in Seoul. During her time there she took a class on North Korean human rights and the U.N. taught by HRNK CEO Greg Scarlatoiu, which prompted her to write a  thesis style paper on North Korean humanrights for her senior capstone project when she returned  to the United States. She currently speaks,reads, and writes Korean at an intermediate level and has advanced proficiency in Chinese and French. As a second-year intern at HRNK she is excited to pursue the topic of North Koreans in China further along with studying North Korean propaganda. She hopes to bring her language skills into use whether it is through translating or cultural literacy when it comes to resources. 

[1] King, Robert R. “Number of North Korean Defectors Drops to Lowest Level in Two Decades.” CSIS, January 27, 2021. https://www.csis.org/analysis/number-north-korean-defectors-drops-lowest-level-two-decades.
[2] The Committee for Human Rights in North Korea. Lives for Sale: Personal Accounts of Women Fleeing North Korea to China. Washington, D.C.: U.S. (2009). https://www.hrnk.org/uploads/pdfs/Lives_for_Sale.pdf.
[3] The Committee for Human Rights in North Korea. Lives for Sale: Personal Accounts of Women Fleeing North Korea to China. Washington, D.C.: U.S. (2009). https://www.hrnk.org/uploads/pdfs/Lives_for_Sale.pdf.
[4] “World Report 2020: Rights Trends in North Korea.” Human Rights Watch, January 22, 2020. https://www.hrw.org/world-report/2020/country-chapters/north-korea.
[5] Ibid.
[6] Zaugg, Julie. “These North Korean Defectors Were Sold into China as Cybersex Slaves. Then They Escaped.” CNN, June 10, 2019. https://www.cnn.com/2019/06/09/asia/north-korea-defectors-intl-hnk/index.html.
[7] Ochab, Dr. Ewelina U. “Trafficking of North Korean Women in China.” Forbes, July 1, 2019. https://www.forbes.com/sites/ewelinaochab/2019/07/01/trafficking-of-north-korean-women-in-china/?sh=1777b7187af0.
[8] Yoon, Hee-soon. “Sex Slaves: The Prostitution, Cybersex & Forced Marriage of North Korean Women & Girls in China’.” (2019). Korea Future Initiative. http://web.archive.org/web/20190614191603/https://www.koreafuture.org/wp- content/uploads/2019/05/Korea_Future_Initiative-Sex_Slaves.pdf
[9] Ochab, Dr. Ewelina U. “Trafficking of North Korean Women in China.”
[10] Lisa Cameron, Dan-dan Zhang, and Xin Meng, “China’s One-Child Policy: Effects on the Sex Ratio and Crime.” Institute for Family Studies, December 19, 2018.
[11] Kathleen Davis, “Brides, Bruises and the Border: The Trafficking of North Korean Women into China.” SAIS Review of International Affairs 26, no. 1 (2006): 131-141, 133.
[12] Yoon, Hee-soon. (2019). “Sex Slaves: The Prostitution, Cybersex & Forced Marriage of North Korean Women & Girls in China’.”
[13] Ibid.
[14] Ochab, Dr. Ewelina U. “Trafficking of North Korean Women in China.”
[15] Yoon, Hee-soon. (2019). “Sex Slaves: The Prostitution, Cybersex & Forced Marriage of North Korean Women & Girls in China’.”
[16] Ibid.
[17] Ibid.
[18] Ibid.
[19] Ibid.
[20] Yoon, Hee-soon. (2019). Sex Slaves: The Prostitution, Cybersex & Forced Marriage of North Korean Women & Girls in China’. London: Korea Future Initiative. http://web.archive.org/web/20190614191603/https://www.koreafuture.org/wp- content/uploads/2019/05/Korea_Future_Initiative-Sex_Slaves.pdf
[21] “Cybersex Trafficking - International Justice Mission.” IJM, September 2016. https://www.ijm.org/sites/default/files/IJM_2016_Casework_FactSheets_CybersexTrafficking.pdf.
[22] Yoon, Hee-soon. (2019). Sex Slaves: The Prostitution, Cybersex & Forced Marriage of North Korean Women & Girls in China’. London: Korea Future Initiative . http://web.archive.org/web/20190614191603/https://www.koreafuture.org/wp- content/uploads/2019/05/Korea_Future_Initiative-Sex_Slaves.pdf
[23] Ji-an, Son Hyeon-yoo & Seo. “Attention for Digital Sex Crimes: A Push for Reform in South Korea.” 한양저널, June 1, 2020. https://www.hanyangian.com/news/articleView.html?idxno=992.
[24] Yoon, Hee-soon. (2019). Sex Slaves: The Prostitution, Cybersex & Forced Marriage of North Korean Women & Girls in China’. London: Korea Future Initiative . http://web.archive.org/web/20190614191603/https://www.koreafuture.org/wp- content/uploads/2019/05/Korea_Future_Initiative-Sex_Slaves.pdf
[25] Yoon, Hee-soon. (2019). Sex Slaves: The Prostitution, Cybersex & Forced Marriage of North Korean Women & Girls in China’. London: Korea Future Initiative . http://web.archive.org/web/20190614191603/https://www.koreafuture.org/wp- content/uploads/2019/05/Korea_Future_Initiative-Sex_Slaves.pdf
[26] Sang-hun, Choe. “After Fleeing North Korea, Women Get Trapped as Cybersex Slaves in China.” The New York Times, September 13, 2019. https://www.nytimes.com/2019/09/13/world/asia/north-korea-cybersex-china.html#:~:text=With%20nowhere%20to%20turn%20for,in%20a%20report%20in%20May.
[27] Zaugg, Julie. “These North Korean Defectors Were Sold into China as Cybersex Slaves. Then They Escaped.” CNN, June 10, 2019. https://www.cnn.com/2019/06/09/asia/north-korea-defectors-intl-hnk/index.html.
[28] Yoon, Hee-soon. (2019). Sex Slaves: The Prostitution, Cybersex & Forced Marriage of North Korean Women & Girls in China’. London: Korea Future Initiative . http://web.archive.org/web/20190614191603/https://www.koreafuture.org/wp- content/uploads/2019/05/Korea_Future_Initiative-Sex_Slaves.pdf
[29] Micallef, Etienne. “China, EU Work to Combat Human Trafficking.” International Organization for Migration, November 15, 2016. https://www.iom.int/news/china-eu-work-combat-human-trafficking.

By Max Smith
Edited by Diletta de Luca, HRNK Research Associate       

          On February 18, 2016, in response to North Korea’s fifth nuclear test, the Obama administration signed into law the North Korea Sanctions and Policy Enhancement Act (NKSPEA). The NKSPEA represented the first piece of comprehensive North Korea sanctions legislation in the United States, building on a series of U.S. executive orders and UN resolutions. In addition to mandating the designation of individuals involved in human rights abuses, the legislation set out the conditions under which sanctions may be lifted. These include the dismantling of North Korea’s weapons programs, the release of political prisoners, the lifting of censorship, the establishment of an open society, and the accounting for and repatriation of U.S. citizens.[1] In this way, the NKSPEA, as well as UN and other national sanctions regimes, are a means of coercing North Korea into improving its dismal human rights record. Additionally, by denying the North Korean military and security apparatus easy access to funds, sanctions inhibit the North Korean regime’s ability to easily perpetrate human rights abuses. However, almost ten years after the enactment of the NKSPEA, not only has no progress been made towards human rights benchmarks, but the situation has deteriorated. North Korea has been developing its military capabilities at an alarming rate,[2] it has further cracked down on human rights by instituting draconian punishments for cultural violations,[3] and its network of political prison camps remains operational.[4] Furthermore, despite the economic damage caused by the COVID-19 pandemic, North Korea is arguably at its most resilient.[5] The Kim regime has been amassing vast amounts of wealth through illicit trading, the dispatching of workers overseas, and cybercrime.[6] It is clear, therefore, that the sanctions regime imposed on North Korea is in urgent need of strengthening if progress on human rights is to be achieved.
 
          There are indications that 2025 could become a critical turning point for North Korean sanctions enforcement: the year marks both the inaugural meeting of the new Multilateral Sanctions Monitoring Team (MSMT), a group of nations who have volunteered to monitor the implementation of North Korea sanctions outside of the UN, and the first months of a new U.S. presidential administration. The creation of a new sanctions monitoring group could allow for more effective enforcement, as previous efforts under the UN Panel of Experts were obstructed by Russia and China.[7] Meanwhile, a new administration in the White House could mean a new direction for U.S. sanctions policy. However, caution is warranted. North Korea and its enablers, in particular Russia and China, have grown increasingly brazen in their violation of international sanctions making enforcement more complex. The Kim regime’s survival has been facilitated through illicit imports taking place in Chinese waters,[8] sales of weapons to support Russia’s war in Ukraine,[9] and access to the international financial system through Russian and Chinese banks.[10] Russia and China have also been vocal advocates for reducing sanctions against North Korea.[11] This culminated in Russia vetoing the renewal of the Panel of Experts’ mandate in 2024[12]. The challenge therefore not only lies in whether to expand sanctions, but also in ensuring they are effectively implemented amid widespread non-compliance and increasingly sophisticated evasion methods. Whether the MSMT and the Trump administration are equipped to meet this challenge remains uncertain, particularly given the possibility that the Trump administration’s attitudes regarding cryptocurrency and tariffs may make enforcement more difficult. The current White House’s relaxed stance on cryptocurrency regulatory enforcement may inadvertently discourage virtual asset service providers from adhering to their anti-money laundering responsibilities.[13] Meanwhile, the recent sweeping tariff announcements have threatened the United States’ position in the global economy and created space for less tightly monitored financial centers.[14] Finally, overshadowing all discussions on the direction of U.S. sanctions is the possibility of renewed negotiations between the United States and North Korea. While such talks could initially result in stricter sanctions, there is a risk that they could be lifted before any meaningful progress is achieved on human rights issues.
 
          Although sanctions have been extensive on paper, they have so far not been fully enforced. North Korea has continued to engage in illicit trade, dispatch overseas workers, and carry out cyberattacks with minimal consequences. On November 21, 2023, 55 countries submitted a report to the 1718 UN Sanctions Committee, the body established to oversee the implementation of sanctions on North Korea, stating that the cap on oil deliveries to North Korea had been breached, possibly by as many as one million barrels.[15] The ships involved in illicit trading have utilized a number of techniques to disguise their actions, such as transmitting false global navigation satellite systems signals, vessel identity laundering, “flag hopping,” and by using complex ownership and management structures.[16] Multilateral cooperation from all stakeholders is needed, to share information on, investigate, and enforce these sanction evasion attempts.[17] However, Russia and China rejected calls to take action, despite this trade occurring in Chinese waters and involving Russian and Chinese entities.[18] Alongside trading, North Korea also continues to maintain access to the international financial system. The 2024 report of the UN Panel of Experts found representatives of North Korean banks present in China, Russia, and Indonesia, in contravention of UN Resolutions 2270 and 2321.[19] This implies that North Korean banks, which manage funds for the country’s defense industry and security apparatus, as well as the Kim family, may be operating overseas.[20] The Panel of Experts also investigated several joint ventures involving North Korean nationals in Russia, as well as Chinese bank accounts maintained by an alleged North Korean Ministry of People’s Armed Forces subsidiary.[21] However, perhaps the most brazen example of enabled sanctions violations remains the infamous transfer of North Korean weapons to Russian forces in support of their war against Ukraine.[22] North Korea’s support for the Russian invasion has increased Moscow’s incentives to block or weaken sanctions against Pyongyang.[23] A clear example of this occurred last year, when Russia vetoed a resolution to extend the mandate of the Panel of Experts, effectively terminating their role in support of the 1718 UN Sanction Committee.[24]
 
          Now that the Panel of Experts has been disbanded, its functions have been assumed by the MSMT. The Panel of Experts was created to assist the 1718 UN Sanctions Committee through gathering information and making recommendations.[25] This means that whilst the UN sanctions regime against North Korea remains in place and is still enforced by the 1718 Committee, there is no longer a UN-mandated body providing expert reporting and advice on sanctions enforcement. Instead, South Korea, the United States, the United Kingdom, Japan, Australia, New Zealand, Italy, France, Germany, Canada, and the Netherlands have created a new body to monitor the enforcement of sanctions outside of the UN framework - the MSMT. While the MSMT introduces a new framework compared to the former Panel of Experts, the enforcement of sanctions will still pose substantial difficulties. Russia and China’s absence could give the MSMT greater freedom to report violations involving their entities, which otherwise may have been obstructed.[26] However, this comes at the cost of reduced international legitimacy.[27] MSMT recommendations will likely go unheeded by the 1718 Committee, as well as potentially other countries, as they originate from a non-UN and Western-dominated body.[28] Russia criticized the Panel of Experts for “kowtowing to Western powers,” and will almost certainly make a similar argument to disregard the findings of the MSMT whilst it sits on the 1718 Committee.[29] There is also the risk that MSMT members may exercise restraint to preserve diplomatic ties with countries found to be in contravention of UN sanctions.[30] This must all be taken into account alongside the fact that the MSMT will face the same challenges as the Panel of Experts regarding the sanctions evasion techniques used by North Korean agents. The MSMT must somehow curtail North Korea’s illicit trading and access to the financial system without the support of the UN framework. The MSMT will have to rely on its capacity to influence the national sanctions regimes of its members, as well as potentially engage with other states by offering a means of reducing exposure to costly UN sanctions violations.[31] This latter point is even more so the case with multinational corporations, who have a greater incentive to avoid the reputational and material risks of being found to have contravened UN sanctions.[32] Thus, crucial to the MSMT’s success will be the diplomatic initiative of its members to engage with both state and non-state third parties, as well as a willingness to embrace the principles of impartiality and inclusivity. In this way, the MSMT will be able to build trust, set standards, and establish itself as a legitimate successor to the Panel of Experts. However, the MSMT must go further in order to overcome the challenges the Panel of Experts faced. Targeting those culpable of knowingly evading sanctions lies with the individual members, the strength of their own sanctions regimes, and their ability to effect compliance among state and non-state actors. Though the MSMT cannot easily interdict illicit trade in the waters surrounding North Korea, it can designate vessels, companies, and individuals involved. Domestic legislation can then be utilized to seize the assets of designated entities, prevent them from doing business in certain jurisdictions, or even arrest them. The MSMT can take action against those facilitating North Korea’s access to the financial system in the same way. This impact will grow if the MSMT is able to gain the compliance of key financial and maritime hubs, potentially to the extent that it surpasses the influence of the Panel of Experts. Nevertheless, this depends on the efforts made by individual members of the MSMT.
 
          As the largest member of the MSMT, the United States is a key player. Even though the United States cannot directly prevent illicit trade between Russia, China, and North Korea, its ability to restrict access to the international financial system gives it significant influence in enforcing sanctions. In Donald Trump’s previous term, the number of new U.S. Treasury Department North Korea designations peaked at 137 individuals, vessels, and entities in 2017.[33] This had an observable effect on North Korea’s economy, with its GDP estimated to have fallen by 3.5%.[34] With Donald Trump once again in the White House, there are expectations for the tightening of the sanctions regime. Indeed, it appears as though the pace of designations is increasing, with six new designations as of May 12, five months into his presidency.[35] However, there are also several reasons to remain cautious. The Trump administration’s favorable attitude regarding cryptocurrency, tariffs, and potential United States-North Korea talks provide reasons to be wary about the prospect of a revived and strengthened sanction regime. Cryptocurrency has provided a source of illicit funds for the Kim regime, and virtual asset ‘mixers’ offer the means to launder illegally obtained virtual currency.[36] Easing off on the regulation of cryptocurrency and virtual asset service providers may therefore create vulnerabilities which North Korean cyber-actors can exploit to evade sanctions. Further issues are created by the Trump administration’s preference for tariffs as a form of coercive diplomacy, as the diplomatic backlash of excessive tariffs pushes nations to economically realign themselves away from the United States. Whilst these two factors potentially create vulnerabilities in the existing sanctions architecture, the prospect of U.S. negotiations with North Korea could alter it significantly as the Trump administration attempts to coerce the Kim regime. This could result in tightened sanctions in the short-term but may see them relaxed before they are able to have any meaningful impact on improving the North Korean human rights situation.
 
          The proliferation of cryptocurrency and other virtual assets has provided North Korea with a large source of illicit funds. The Panel of Experts’ 2020 midterm report found that North Korean cyber-actors were targeting the virtual asset industry to avoid sanctions.[37] Reinforcing the sanctions regime therefore requires tightening regulations and standards when it comes to cryptocurrency. This is all the more the case considering that the proceeds of cybercrime may be the Kim regime’s primary source of income.[38] The report found that North Korean cyber-actors were using loosely regulated virtual asset service providers and brokering services to convert illicitly obtained virtual assets into clean fiat currency.[39] The virtual assets industry is an ideal target for North Korean cybercriminals, as its rapid growth has often come at the cost of cyber security.[40] Government intervention, both in the form of designating and taking down platforms, and in the introduction of cybersecurity standards and best-practices, is needed to address these vulnerabilities. However, equally important is industry cooperation and acceptance of standards.[41] The Trump administration’s overhaul of cryptocurrency policies therefore has negative implications when it comes to the enforcement of sanctions, as it may discourage the stringent due-diligence needed to protect against cybercriminals, including those stealing and laundering funds on behalf of the North Korean regime.  A recent memo from the Department of Justice narrowed the scope of enforcement by directing prosecutors not to charge regulatory violations in cases involving digital assets.[42] Though exceptions are made for organized crime and terrorism, this directive may encourage firms to de-prioritize their anti-money laundering obligations, thus opening the door wider for malicious actors.[43] Also necessary to consider is the Trump administration’s interactions with figures in the industry, which signal a move away from enforcing much-needed standards. On March 27th, Trump granted pardons to three co-founders of the cryptocurrency exchange “BitMEX,” who had failed to properly implement anti-money laundering and know-your-customer programs.[44] These pardons arguably undermine the virtual asset regulatory framework by showing presidential support for industry leaders who did not fulfill their obligations. From the perspective of sanctions enforcement, it is crucial to ensure that virtual asset service providers do their part, by implementing the required programs, ensuring the robust cybersecurity of their platforms, and freezing coins they believe to be linked to crime. If virtual asset service providers de-prioritize their due diligence obligations, then more opportunities will be given to North Korea’s network of cybercriminals to conduct cryptocurrency theft and launder the proceeds of illicit activity. This would weaken the effectiveness of sanctions enforcement, by allowing the North Korean regime easy access to an alternative source of funds, and by making it harder for sanctions enforcement agencies to identify revenue generated by sanctioned activity.
 
          The Trump administration’s attitude towards tariffs is another reason to be cautious regarding the future of the sanctions regime. Thanks to the dollar’s status in the global economy, even many non-U.S. banks clear international transactions through correspondent accounts in U.S. banks.[45] The United States’ ability to exercise a large degree of control over access to the global financial system gives its national sanctions regime far more force than those of other countries.[46] However, the United States’ position in the global economy has been threatened by the tariff announcement on April 2, which harmed the United States’ diplomatic reputation and signified a reordering of the economic order.[47] Some countries have moved away from the United States in response to the tariff threat, and as a result have less incentive to comply with the U.S. sanctions regime.[48] This was the case in Southeast Asia, where particularly high tariffs have paved the way for China to exert greater influence.[49] Though nations there are moving to preserve ties with the United States, the tariffs have already damaged trust.[50] This means that as well as reducing economic incentives to follow U.S. diplomatic initiatives, these tariffs have negatively affected U.S. soft power in the region. Southeast Asia is an important region when it comes to the enforcement of sanctions, as nations in the region still maintain ties to North Korea.[51] Laos in particular, is a sanctions evasion hotspot, being home to numerous North Korean restaurants which generate cash for the regime.[52] The compliance of these nations is crucial for effective sanctions enforcement, but this will be difficult to achieve as the United States loses influence in the region. By reducing the United States’ influence globally, the tariffs have also created room for alternative financial centers, which lack either the capacity or will to enforce sanctions with the same intensity as the United States.[53] The EU is one such example. Though economically powerful and an important financial hub, the efficacy of its sanctions is undermined by uneven enforcement across Member States, and a relative lack of experience compared to the United States.[54] In this way the tariffs have inadvertently and indirectly relieved pressure on North Korea and its enablers. As the United States steps back from the center of the global economy, vulnerabilities are created which the Kim regime will be able to exploit.
 
          Finally, the direction of U.S. sanctions will undoubtedly be influenced by whether or not the Trump administration attempts to once again negotiate with North Korea. It has been reported that the White House and State Department are preparing for possible talks with the Kim regime.[55] In the event that the Trump administration decides to try and force North Korea to the table, it is likely that sanctions against North Korea will be tightened to impose maximum pressure before negotiations.[56] This approach is especially likely given that weakened sanctions enforcement in recent years has allowed North Korea to reach a stronger position than it held in 2019.[57] With Russia now acting as a strategic backer, North Korea may feel less compelled to enter negotiations at all.[58] Therefore, if the Trump administration is indeed seeking talks, stronger sanctions will be a prerequisite. However, there is no guarantee that, once implemented, sanctions will last. Historically, U.S. presidents have offered sanctions relief in exchange for commitments from North Korea.[59] For instance, prior even to the June 2018 Singapore summit, the Trump administration intervened to pause the enforcement of sanctions.[60] More worrying though is the fact that human rights issues are unlikely to be an agenda item. Human rights were not mentioned in the 1994 Agreed Framework, the 2007 Joint Statement of the Six Party Talks, the 2012 Leap Day Agreement, and, most significantly given that it resulted from Trump’s previous diplomatic efforts regarding North Korea, the Joint Statement of the 2018 Singapore summit.[61] This means that regardless of the direction the sanctions regime takes in relation to talks, it is unlikely to have any meaningful significance for human rights improvements in North Korea.
 
          Despite North Korean human rights being mentioned in the NKSPEA, the inconsistent and weak enforcement of the sanction regime means that North Korea has been able to continue to violate the human rights of its people. In theory, the conditions set out in the NKSPEA imply that there are legally enforceable human rights benchmarks which must be met before sanctions are lifted.[62] However, these conditions mean little if North Korea is able to evade sanctions with impunity. For this reason, the sanction regime against North Korea must be both extensive and well enforced. Even if formal North Korean commitment to improving human rights is essentially impossible, denying funds to the regime and its proxies could at least weaken its grip on the population.[63] The formation of the MSMT may be a reason to be optimistic in this regard, given its potential to more effectively report violations enabled by Russia and China. However, there are also reasons to be skeptical. On top of the existing challenges in sanctions enforcement, the MSMT will face issues with its legitimacy which may hinder its reporting and enforcement capabilities. In addition, the MSMT’s power is highly dependent on the national sanctions regimes of its members, in particular the United States. Consequently, whether 2025 will be the necessary turning point in sanctions enforcement depends upon the decisions of the new Trump administration, whose policies so far have created vulnerabilities in the international sanctions regime. To conclude, while 2025 may be described as a year of change in sanctions enforcement, it remains uncertain whether these changes will lead to the stronger sanctions regime needed to restrict the North Korean regime’s ability to conduct widespread human rights abuses, and pressure it towards improving human rights.

Max Smith, currently a research intern with HRNK, studied Korean for four years at SOAS University of London. During this time, he also spent a year abroad at Seoul National University. Whilst studying, he focused much of his independent research on South Korean foreign policy, including by analyzing different administrations’ approaches to North Korea.
In his final year at SOAS, Max cemented his interest in North Korean issues through a class on North Korean history, politics and society. After graduating, he built on this knowledge further through a two-month internship at the South Korean human rights organization PSCORE.
Max is currently doing a master’s degree in East Asian Studies at the University of Turku. For his master’s thesis, he plans on researching how foreign IGOs and NGOs can influence North Korean policy to improve the humanitarian and human rights situation there.
 
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The White House. “Joint Statement of President Donald J.Trump of the United States of America and Chairman Kim Jong Un of the Democratic People’s Republic of Korea at the Singapore Summit.” June 12, 2018. https://trumpwhitehouse.archives.gov/briefings-statements/joint-statement-president-donald-j-trump-united-states-america-chairman-kim-jong-un-democratic-peoples-republic-korea-singapore-summit/.
 
Tidy, Joe. “North Korean Hackers Cash Out Hundreds of Millions from $1.5bn ByBit Hack.” BBC, March 10, 2025. Accessed May 8, 2025. https://www.bbc.co.uk/news/articles/c2kgndwwd7lo.
 
U.S. Department of the Treasury, Office of Foreign Assets Control. “Recent Actions.” Last updated May 8, 2025. https://ofac.treasury.gov/recent-actions.
 
UN News. “General Assembly Debates Russia’s Veto of DPR Korea Sanctions Panel.” April 11, 2024. Accessed May 24, 2025. https://news.un.org/en/story/2024/04/1148431.
 
United Nations Security Council. “Work and Mandate.” Accessed May 21, 2025. https://main.un.org/securitycouncil/en/sanctions/1718/panel_experts/work_mandate.
 
United Nations Security Council. Final Report of the Panel of Experts Established Pursuant to Resolution 1874 (2009), S/2024/215. March 7, 2024.
 
United Nations Security Council. Midterm Report of the Panel of Experts Established Pursuant to Resolution 1874 (2009), S/2020/840. August 28, 2020.
 
United Nations. “Security Council Fails to Extend Mandate for Expert Panel Assisting Sanctions Committee on Democratic People’s Republic of Korea.” March 28, 2024. https://press.un.org/en/2024/sc15648.doc.htm. 
 
Vu, Khang. “North Korea and its Socialist Friends in Southeast Asia.” The Interpreter, April 12, 2024. Accessed May 27, 2025. https://www.lowyinstitute.org/the-interpreter/north-korea-its-socialist-friends-southeast-asia.
 
Watterson, Christopher J.“The New Face of North Korean Sanctions Monitoring: Can the MSMT Pick Up Where the Panel of Experts Left Off?” 38 North, April 16, 2025. Accessed May 8, 2025. https://www.38north.org/2025/04/the-new-face-of-north-korean-sanctions-monitoring-can-the-msmt-pick-up-where-the-panel-of-experts-left-off/.
 
Yoeli, Max. “Trump’s Tariff Policy Undermines His Own Agenda and the Foundations of US Economic Power.” Chatham House. April 16, 2025. https://www.chathamhouse.org/2025/03/trumps-tariff-policy-undermines-his-own-agenda-and-foundations-us-economic-power.


[1] 114th Congress of the United States, "Text - H.R.757 - 114th Congress (2015-2016): North Korea Sanctions and Policy Enhancement Act of 2016," February 18, 2016, https://www.congress.gov/bill/114th-congress/house-bill/757/text.
[2] Vibhu Mishra, “DPR Korea Ploughing Ahead with Nuclear and Ballistic Missile Programme,” UN News, May 7, 2025: https://news.un.org/en/story/2025/05/1163016.
[3] Robert Collins, Greg Scarlatoiu (ed.), “North Korea’s Lawfare Strategy,” HRNK Insider, October 30, 2024, https://www.hrnkinsider.org/2024/10/north-koreas-lawfare-strategy.html.
[4] See for example: Joseph S. Bermudez Jr., Greg Scarlatoiu, and Raymond Ha, “North Korea’s Political Prison Camp Kwan-li-so No. 25, Update 4,” Washington D.C.: The Committee for Human Rights in North Korea, 2024.
[5] Ruediger Frank, “The New North Korea: How Geopolitical Advantages and Growing Middle Class Prosperity Challenge the Next South Korean President,” 38 North, April 22, 2025, https://www.38north.org/2025/04/the-new-north-korea-how-geopolitical-advantages-and-growing-middle-class-prosperity-challenge-the-next-south-korean-president/; Daniel Sneider, “Is North Korea the Next Target of Trump’s Search for a Deal?,” Korea Economic Institute, April 30, 2025, https://keia.org/the-peninsula/is-north-korea-the-next-target-of-trumps-search-for-a-deal/.
[6] United Nations Security Council, Final report of the Panel of Experts established pursuant to resolution 1874 (2009), S/2024/215, March 7, 2024, pp. 49-54, pp. 59-61, pp. 64-65; See also: Joe Tidy, “North Korean Hackers Cash Out Hundreds of Millions from $1.5bn ByBit Hack,” BBC, March 10, 2025, https://www.bbc.co.uk/news/articles/c2kgndwwd7lo.
[7] Christopher J. Watterson, “The New Face of North Korean Sanctions Monitoring: Can the MSMT Pick Up Where the Panel of Experts Left Off?,” 38 North, April 16, 2025, https://www.38north.org/2025/04/the-new-face-of-north-korean-sanctions-monitoring-can-the-msmt-pick-up-where-the-panel-of-experts-left-off/
[8] The 2020 midterm report by the Panel of Experts recorded illicit coal trading taking place in the Ningbo-Zhoushan area: United Nations Security Council, Midterm report of the Panel of Experts established pursuant to resolution 1874 (2009), S/2020/840, August 28, 2020, p. 19, pp. 136-139; see also Ibid, p. 130; See also United Nations Security Council, Final report of the Panel of Experts, pp. 21-22.
[9] United Nations Security Council, Final report of the Panel of Experts, pp. 34-38, pp. 276-285.
[10] Ibid,  p. 53, and pp. 445-455.
[11] Kim Eun-Bin, “Korea’s Foreign Ministry Protests China and Russia’s Calls for Ending Sanctions on North,” Korea JoongAng Daily, May 14, 2025, https://koreajoongangdaily.joins.com/news/2025-05-14/national/northKorea/Koreas-Foreign-Ministry-protests-China-and-Russias-calls-for-ending-sanctions-on-North/2307281.
[12] United Nations, “Security Council Fails to Extend Mandate for Expert Panel Assisting Sanctions Committee on Democratic People’s Republic of Korea,” SC/15648, March 28, 2024. https://press.un.org/en/2024/sc15648.doc.htm.
[13] Sharon McCarthy and Victor Suthammanont, “DOJ’s New Crypto Guidance Muddies the Prosecutorial Waters,” Bloomberg Law, April 23, 2025, https://news.bloomberglaw.com/us-law-week/dojs-new-crypto-crime-guidance-muddies-the-prosecutorial-waters.
[14] Shilo Grayson, “Trump’s Tariffs are Replacing Sanctions,” Royal United Services Institute, April 29, 2025, https://www.rusi.org/explore-our-research/publications/commentary/trumps-tariffs-are-replacing-sanctions.
[15] United Nations Security Council, Final report of the Panel of Experts, p. 20 and p. 147.
[16] Ibid, pp. 23-24.
[17] Ibid, pp. 25-26
[18] United Nations Security Council, Midterm report of the Panel of Experts, S/2020/840, August 28, 2020, p. 19, pp. 136-139; see also Ibid, p. 130; See also United Nations Security Council, Final report of the Panel of Experts, pp. 21-22.
[19] United Nations Security Council, Final report of the Panel of Experts, p. 53, and pp. 445-455.
[20] The Korea Daesong Bank is affiliated with Office (Bureau) 39, which is notorious for its involvement in money-laundering and counterfeiting, see Joshua Stanton, “The Root of All Evil: Money, Rice, Crime & Law in North Korea,” Washington D.C.: The Committee for Human Rights in North Korea, 2023, p. 13; The Foreign Trade Bank was designated by the United States for facilitating transactions linked to weapons proliferation, see ibid, p. 47.
[21] United Nations Security Council, Final report of the Panel of Experts, p. 54.
[22] Ibid, pp. 34-38, pp. 276-285.
[23] Samuel Ramani, “From Reluctant Enforcer to Outright Saboteur: Russia’s Crusade Against North Korea Sanctions,” 38 North, June 24, 2024, https://www.38north.org/2024/06/from-reluctant-enforcer-to-outright-saboteur-russias-crusade-against-north-korea-sanctions/.
[24] United Nations, “Security Council Fails to Extend Mandate for Expert Panel Assisting Sanctions Committee on Democratic People’s Republic of Korea.”
[25] United Nations Security Council, “Work and Mandate,” accessed May 21, 2025,https://main.un.org/securitycouncil/en/sanctions/1718/panel_experts/work_mandate
[26] Watterson, “The New Face of North Korean Sanctions Monitoring: Can the MSMT Pick Up Where the Panel of Experts Left Off?”; Karl Dewey and Zuzanna Gwadera, “A New Mechanism for North Korean Sanctions,” International Institute for Strategic Studies, December 13, 2024, https://www.iiss.org/online-analysis/online-analysis/2024/12/a-new-mechanism-for-north-korean-sanctions-monitoring/.
[27] Hyonhee Shin, “US, South Korea, Japan Unveil New Team to Monitor North Korea Sanctions,” Reuters, October 16, 2024, https://www.reuters.com/world/us-south-korea-japan-unveil-new-team-monitor-north-korea-sanctions-2024-10-16/; Christy Lee, “New Body to Monitor North Korea Sanctions Enforcement Faces Doubts About Legitimacy,” VOA, October 17, 2024, https://www.voanews.com/a/new-body-to-monitor-north-korea-sanctions-enforcement-faces-doubts-about-legitimacy/7827082.html.
[28] Watterson, “The New Face of North Korean Sanctions Monitoring;” Nika Pasko, “Monitoring Without Mandate: Can Sanctions Succeed Outside a UN Framework?,” The Interpreter, March 18, 2025, https://www.lowyinstitute.org/the-interpreter/monitoring-without-mandate-can-sanctions-succeed-outside-un-framework; Christy Lee, “New Body to Monitor North Korea Sanctions.”
[29] “General Assembly Debates Russia’s Veto of DPR Korea Sanctions Panel,” UN News, April 11, 2024, https://news.un.org/en/story/2024/04/1148431. 
[30] Watterson, “The New Face of North Korean Sanctions Monitoring.”
[31] Ibid.
[32] Ibid.
[33] Go Myong-Hyun, “Not Under Pressure - How Pressure Leaked Out of North Korea Sanctions,” The Asan Institute for Policy Studies, June, 18, 2020, http://en.asaninst.org/contents/not-under-pressure-how-pressure-fizzled-out-of-north-korea-sanctions/. 
[34] Stanton, “The Root of All Evil: Money, Rice, Crime & Law in North Korea,” p. 59.
[35] U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent Actions,” accessed May 8, 2025, https://ofac.treasury.gov/recent-actions.
[36] Alex O’Neil, “Upholding North Korea Sanctions in the Age of Decentralised Finance,” London: Royal United Services Institute, 2024, pp.3-4.
[37] Panel of Experts, S/2020/840, p. 60.
[38] O’Neil, “Upholding North Korea Sanctions in the Age of Decentralised Finance,” p. 6.
[39] Panel of Experts, S/2020/840, p. 44.
[40] O’Neil, “Upholding North Korea Sanctions in the Age of Decentralised Finance,” p. 8.
[41] Ibid, p. 23.
[42] McCarthy and Suthammanont, “DOJ’s New Crypto Guidance Muddies the Prosecutorial Waters.”
[43] Ibid.
[44] Eamon Javers and Dan Mangan, “Trump Pardons Three BitMEX Crypto Exchange Co-Founders, and Ex-Employee,” CNBC, March 29, 2025, https://www.cnbc.com/2025/03/28/trump-pardon-bitmex-crypto-exchange-money-laundering.html?msockid=05e700f335bc642b29200fd934e465ce.
[45] Stanton, “The Root of All Evil: Money, Rice, Crime & Law in North Korea,” pp. 23-24.
[46] Erika Szyszczak, “Sanctions Effectiveness: What Lessons Three Years into the War on Ukraine?” Economics Observatory, February 19, 2025, https://www.economicsobservatory.com/sanctions-effectiveness-what-lessons-three-years-into-the-war-on-ukraine.
[47] Grayson, “Trump’s Tariffs are Replacing Sanctions.”
[48] Ibid; Max Yoeli, “Trump’s Tariff Policy Undermines His Own Agenda and the Foundations of US Economic Power,” Chatham House, April 16, 2025, https://www.chathamhouse.org/2025/03/trumps-tariff-policy-undermines-his-own-agenda-and-foundations-us-economic-power.
[49] Ben Bland, “Trump’s Tariffs will Push Southeast Asia Uncomfortably Close to China,” Chatham House, April 8, 2025, https://www.chathamhouse.org/2025/04/trumps-tariffs-will-push-southeast-asia-uncomfortably-close-china
[50] Ibid.
[51] Khang Vu, “North Korea and its Socialist Friends in Southeast Asia,” The Interpreter, April 12, 2024, https://www.lowyinstitute.org/the-interpreter/north-korea-its-socialist-friends-southeast-asia.
[52] Ibid.
[53] Ibid.
[54] Erika Szyszczak, “Sanctions Effectiveness: What Lessons Three Years into the War on Ukraine?”
[55] Barak Ravid and David Lawler, “Scoop: Trump Admin Game-Planning for Potential North Korea Talks,” Axios, April 27, 2025, https://www.axios.com/2025/04/27/north-korea-talks-kim-jong-un-trump; “Trump Says He Still Has Good Relations with Leader of ‘Nuclear Power’ North Korea,” Reuters, March 13, 2025, https://www.reuters.com/world/trump-says-he-still-has-good-relations-with-leader-nuclear-power-north-korea-2025-03-13/; Seung-ho Lee, “U.S. State Department, White House Reportedly Preparing for Talks with North,” Korea JoongAng Daily, April 28, 2025, https://koreajoongangdaily.joins.com/news/2025-04-28/national/northKorea/US-State-Department-White-House-reportedly-preparing-for-talks-with-North/2295309.
[56] Watterson, “The New Face of North Korean Sanctions Monitoring.”
[57] Sneider, “Is North Korea the Next Target of Trump’s Search for a Deal?”
[58] Hyun-Ju Park, “North Korea’s Ukraine War Admission May Have Potential Trump Talks in Mind, Experts Say,” Korea JoongAng Daily, April 28, 2025, https://koreajoongangdaily.joins.com/news/2025-04-28/national/northKorea/North-Koreas-Ukraine-war-admission-may-have-potential-Trump-talks-in-mind-experts-say/2295521; Song Sang-ho, “Russia-N. Korea Partnership Will Impact Trump’s Leverage in Diplomacy Toward Pyongyang: Expert,” Yonhap, May 3, 2025, https://en.yna.co.kr/view/AEN20250503000500315?section=national/diplomacy.
[59] Stanton, “The Root of All Evil: Money, Rice, Crime & Law in North Korea”, p. 78.
[60] Ibid, pp. 60-61; Vivian Salama and Ian Talley, “U.S. Holds Off on New North Korea Sanctions as Summit Talks Progress,” The Wall Street Journal, May 28, 2018, https://www.wsj.com/articles/u-s-prepares-sanctions-while-pursuing-revived-north-korea-talks-1527526255.
[61] Stanton, “The Root of All Evil: Money, Rice, Crime & Law in North Korea,” p. 77; The White House, “Joint Statement of President Donald J.Trump of the United States of America and Chairman Kim Jong Un of the Democratic People’s Republic of Korea at the Singapore Summit,” June 12, 2018, https://trumpwhitehouse.archives.gov/briefings-statements/joint-statement-president-donald-j-trump-united-states-america-chairman-kim-jong-un-democratic-peoples-republic-korea-singapore-summit/.
[62] Stanton, “The Root of All Evil: Money, Rice, Crime & Law in North Korea,” pp. 86-88.
[63] Ibid, pp. 102-103.

By Isabella Grace Packowski
Edited by Diletta de Luca, HRNK Research Associate

Introduction
The plight of North Korean refugees presents a complex and multifaceted challenge within the realm of international refugee law and human rights. This paper examines the legal status and survival migration of North Korean escapees, exploring the historical context of refugee law, specific case studies of North Korean refugees in China, the United States, the United Kingdom, and South Korea, and the broader implications of survival migration. By analyzing the institutional frameworks, national policies, and humanitarian efforts, this study aims to shed light on the critical issues faced by North Korean refugees and propose viable solutions to enhance their protection and resettlement.
 
Historical Background | Refugee Law
Before delving into the case studies and offering potential solutions, it is first crucial to analyze the institutional and legal history of the leading body in global governance concerning refugee aid, status, and protection – the United Nations (UN) High Commissioner for Refugees (UNHCR, hereafter). The emergence of refugees as an international concern dates back as early as the 17th century, when religious persecutions and wars in the Middle East and Europe were a concern.[1] This concern continued into the early 20th century, with provisions under the League of Nations and its Office of High Commissioner for Refugees (1921), following events such as the First World War and the Russian Civil War.[2] However, the grounds on which these provisions were built were shaky at best, with minimal legal aid provided and catering to only specific national groups.[3]
 
It wasn’t until the aftermath of World War II, and the founding of the UN in 1946, that global collaboration solidified and accelerated.[4] This was hastily supplemented by the birth of the UNHCR (1950) as one of its key sub-bodies, replacing the International Refugee Organization (IRO -1947) and its predecessor, the UN Relief and Rehabilitation Agency (UNRRA -1943).[5] However, it would not be without its own complexities. There was limited financial and governing autonomy amongst other UN bodies.[6] They also held only specific functions and strict definitions that constituted refugee status, limiting the scope to which such aid could apply (i.e., its mandate to provide international protection for refugees and to find durable solutions to their plight, not including material assistance, the inclusion of “internal refugees,” etc.)[7]
 
Representative of this ambiguity, the United States initially sought to establish a temporary international body with limited authority and a focus on international legal protection.[8] This was contrary to the varying perspectives of other Western States, who sought more operational cost and geographic considerations, and South Asian states, who fought for the permanency of the organization.[9] During the Cold War, international refugee law underwent shifts in its priorities and foundations within a context shaped by Eurocentrism, resolutions passed by the General Assembly expanding mandates, sovereignty and non-intervention, and the emerging concept of “moral authority.”[10] Consequently, after this era ended, contradictions within refugee law, particularly regarding its non-political foundations, attitudes toward interventionism, and emerging security threats such as the 9/11 attacks in the United States, profoundly shook the international sphere in the realm of human rights scenarios.[11]
 
North Korean Refugees Case Study
To better understand how refugee law operates in complex geopolitical contexts, the following section focuses on the resettlement process of North Korean refugees in South Korea, the United Kingdom, the United States, and China, and proposes considerations and solutions. Due to geographical vicinity, shared history, and cultural similarities, many North Korean escapees, desperate to flee the social inequalities and human rights abuses sustained by the Kim regime, often seek refuge in two of North Korea’s neighboring states: China and South Korea.[12]
 
Although South Korea has taken in over 34,000 refugees from the North – drawing on its constitution, which recognizes, with some limitations, that anyone born on the Korean Peninsula as a South Korean national is entitled to the protection of the Republic of Korea – many defectors still face significant discrimination and stark cultural and political differences.[13] As such, some will opt to be resettled to Western states.[14]
 
Under the 1951 Refugee Convention and its 1967 Protocol, North Korean defectors qualify as refugees sur place, meaning “...individuals who are not considered refugees upon leaving their country but become refugees later due to the persecution they are subjected to if they were to be deported.”[15] However, differences in how countries recognize North Korean refugees stem from the varying diplomatic relationships each nation maintains with North Korea, leading to ambiguities in their refugee status, asylum claims, and perceived legitimacy.[16] The United Kingdom, for example, with a higher refugee intake than other European nation, recognizes these difficulties but does not view them as grounds for asylum.[17] As such, North Korean secondary asylum seekers are subject to refoulement to South Korea under the 2012 UK-ROK Agreement on the Readmission of Persons.[18]
 
Furthermore, the UK aligns with the European Union's (EU) policies, engaging critically with North Korea via cultural exchanges and humanitarian aid.[19] As such, it makes its decisions based on its diplomatic approach to how South Korea handles relations with North Korea while adhering to the aforementioned EU protocols.[20] It is such that the UK Upper Tribunal Immigration and Asylum Chamber (UKUT) has made compromises in accepting asylum seekers, respecting the South Korean Constitution, correlating with the length of time (+/- 10 years) spent in or out of the Korean peninsula: “... if the appellant is known to not have resided outside of the Korean Peninsula for 10 years, they are sent to South Korea; if they are recognized to have been outside for over 10 years, they are accepted. For the latter, UKUT recognizes that if an appellant is not a national at the time of the case and ‘may be refused nationality’, they shall not be treated as a dual national.”[21] Thus, such arguments maintain that these national birthright interpretations remain only within the realm of South Korean domestic policies.[22]
 
Despite aspirations to resettle in Western nations, to date, a total of only 220 North Korean refugees reside in the United States.[23] The limited number is due to an extensive and time-consuming immigration process, which offers fewer benefits compared to South Korea, and mercurial American foreign policy affairs.[24] However, such decreasing trends are not only applicable to the United States, as, according to the South Korean Ministry of Unification, only 229 persons were resettled in 2020, a stark contrast to the 1,047 defectors aided as seen in 2018.[25] Both of these examples not only showcase stricter border controls implemented, especially under the Kim regime, reduced funding from aid countries, and the effects of Covid-19 on financial and physical flexibility.[26]
 
The primary legislation at play for asylum implementation of North Korean refugees in the United States is the North Korean Human Rights Act of 2004 (NKHRA), which was first signed into law by former President George W. Bush in 2004, then extended in 2008, 2012 and 2018.[27] Most recently, the NKHRA was submitted for reauthorization in May 2022, and, despite the House of Representatives having passed it in May 2024, the Senate failed to address it in time, leaving the Act in legal limbo.[28]
 
The US’s approach to this concern is argued to be highly reflective of President Bush’s aggressive and conservative stance on North Korea at the time and its proliferation of nuclear weapons.[29] This forward-leaning approach was maintained through its long-standing military alliance with South Korea, which dates back to the end of the Korean War, as well as through diplomatic affairs with North Korea.[30] Lastly, refugees’ asylum in the United States is not barred for those who have already accepted their South Korean citizenship, further exposing the complexity of foreign affairs and international refugee law.[31]
 
The exact number of North Korean refugees in China remains unknown, but estimates range expansively from 5,000 to 250,000 defectors.[32] This uncertainty and lack of documentation of North Koreans in China is caused primarily by China’s claiming they are “illegal economic migrants,” China’s refusing to grant them access to the process leading to acquiring political refugee status, Covid-19, and the precarious nature of legalities, citizenship, and violations of international law.[33] China, therefore, presents a much more complex and egregious view of North Korean defectors, their status, and the lack of protection outside of the discriminatory practices that refugees typically face. Most importantly, China blatantly violates the UN’s 1951 Convention on the Status of Refugees, infringing, in particular on Article 33.1 of the Convention:
 
“No Contracting State shall expel or return (“refouler”) a refugee in any
manner whatsoever to the frontiers of territories where his life or freedom
would be threatened on account of his race, religion, nationality, membership of a particular social group or political opinion.”[34]
 
Article 33.1 is violated by China as it, more often than not, willingly expels and forcibly repatriates North Korean refugees to North Korea despite the known persecution or harm that would await them once returned to their home country.[35] Those repatriated are imprisoned in the detention system of the country, either sent to labor camps, 교화소 “kyo-hwa-so”, or to political prison camps, 관리소 “kwan-li-so,” where they face a credible fear of persecution, harsh interrogation, torture, imprisonment, or even death.[36] North Koreans who tried to escape the Kim regime are obstinately sent to political prison camps for severe punishment, as these detention facilities are known for the inhumane conditions that are imposed on prisoners.[37] Since 2014, it is estimated that at least 2,000 North Korean refugees have been deemed illegal migrants and are at risk of being returned to North Korea while being held in Chinese detention centers.[38]
 
North Korean women in particular are subjected to human rights abuses in China. This can be mainly in relation to the conditions of China’s “Red Zone,” in which “... it is estimated that up to 500,000 female North Koreans, some as young as twelve, hide in this region. They are subjected to systematic rape, sexual slavery, forced marriage, unwanted pregnancy, forced labor, and cybersex trafficking.”[39] With women and girls being lured into China under the pretense of finding work, as many as 80% are instead forced into the sex trade, and such abuse has become common practice.[40] The trafficking of North Korean women and girls is reported to generate more than $105 million annually for organized crime networks in both China and North Korea.[41]
 
Moreover, North Korean women are often sold to Chinese men as wives.[42] Due to China’s one-child policy, children born in China to North Korean and Chinese parents remain undocumented/stateless children of illegal “mixed marriages.”[43] They are thus deemed “stateless” as they are not in possession of official Chinese citizenship and are born outside of North Korea.[44] In some cases, such as in rural Heilongjiang Province, women who have married Chinese men and have given birth to at least two children are more likely to be issued temporary identification papers.[45]
 
These children then become registered in the 户口 “hukuo” system, in which said practice is to place hardships on the father, especially if the mother is forcibly repatriated.[46] These human rights violations that North Korean escapees face are due to their labelling by China as “illegal economic immigrants.” [47] Escapees thus often remain undocumented without fundamental rights in education, welfare, and health services to avoid repatriation.[48]
 
Lastly, beyond any potential illicit financial gains through transnational crime networks, China’s strategic alliance with North Korea significantly shapes its approach to North Korean refugees.[49] Under a longstanding bilateral agreement and despite pressure by the international community, China continues to classify these individuals as illegal economic migrants rather than refugees and routinely repatriates them.[50] This practice not only contradicts the humanitarian principles of the 1951 UN Refugee Convention, in particular Article 33.1 and the principle of non-refoulement, but also raises serious concerns about complicity in human rights violations upon their return.[51]
 
The U.S. Committee for Human Rights in North Korea (HRNK) found that 90% of all forcibly repatriated North Korean refugees sent to detention facilities eventually die from the harsh conditions and violence they are subjected to.[52] Women are additionally routinely subjected to sexual and gender-based violence, from torture to forced abortions or infanticide if they became pregnant with Chinese men.[53]
 
Survival Migration
Throughout this policy analysis, a recurring theme has been the importance of fundamental human rights, comprehensive international law, and protection relative to the treatment of refugees. This leads to the next area of study, “survival migration.” This term refers to “Persons outside their country of origin because of an existential threat to which they have no access to a domestic remedy or resolution.”[54] While focusing primarily on cases in sub-Saharan Africa, Andrew Battes expresses how, in addition to the mass exodus example from Zimbabwe, “In Haiti, Iraq, North Korea, and Myanmar, for example, significant numbers of people have fled to neighboring countries not because of a well-founded fear of individualized persecution, but more often because of serious deprivations of socioeconomic rights related to the underlying political situation.”[55]
 
In the case of Myanmar, for example, the Rohingya people face similar disparities in legal status and discrimination after fleeing to India in response to a military junta’s rule and a 2017 genocide.[56] India, not being a signatory of the Convention, acknowledges the fervent prosecution of the Rohingya but national security trumps everything else. Thus, India stresses a ‘right to life’ vs. a ‘right to settle’ approach.[57] As an ethno-religious minority, survival migrants are now the world’s largest group stateless people, having become a serious global issue.[58]
 
The term “survival migration” itself is not mentioned in the 1951 Convention, and, although in theory those who fall under this category have rights under international law, there is no set framework for those who do not fit the rigid definitions that already exist.[59] This is most reflective of the way international bodies and states view the situation, a dichotomy of economic migrant and refugee, without consideration to other factors outside of generalized violence or individualized persecution, including environment, state fragility, and livelihood failure, in addition to socioeconomic deprivation of rights, as seen with North Korea.[60] It thus shows how the process of becoming and being classified as refugees is not monocausal, but is intertwined with these factors and institutional gaps, which, in turn, affect how refugees are assisted.[61] “Regime stretching,” as Betts describes, furthers this thought, in that institutions are not themselves “fixed,” but can be adaptive.[62]
 
Government Organizations
Domestic-based government organizations can also play a significant role in refugee resettlement.  For example, the 하나원 (hanawon), a South Korean government-regulated resettlement facility, established in 1999 by the Ministry for Unification of South Korea 통일부 “tong-il-bu.”[63] Situated in Seoul, the organization provides a place for North Korean defectors to “graduate” before joining South Korean society.[64] The facility consists of two facilities, a school and a hospital, and is heavily guarded. North Korean refugees who recently escaped North Korea participate in a 12-week program where they learn invaluable life skills and are exposed to concepts such as democracy, human rights, and religious freedoms in order to adapt to South Korean society.[65] After “graduating,” defectors receive financial resettlement support, and further facilitative aid can be provided by the South Korean government, such as the Elm House for women.[66] However, despite the success of this rigorous and involved program, discrimination, difficulties in securing full-time work, and losing connections with other North Korean refugees often plague the trainees.[67]
 
NGOs
Alongside formal governance, non-governmental organizations (NGOs) can also play a prominent and direct role in aiding refugees. An NGO that helps address topics of human trafficking prevention and rescue for women is the Nomi Network.[68] With over 20,000 aided since 2012, from India to the United States, the organization seeks to empower and protect victims by its mission statement, expressing how “Nomi Network aims to end human trafficking by creating pathways to safe employment, empowering women and girls to break cycles of exploitation in their families and communities.”[69]
 
Although no direct aid to North Korean defectors has been made so far, initiatives represented by global results similar to those provided by the Nomi Network could greatly help prevent or support those trafficked, especially in China. Refugees International, another organization based in Washington D.C., also works to advocate for “...lifesaving assistance, human rights, and protection for displaced people and promotes solutions to displacement crises.”[70] They have worked largely with the Rohingya people's crisis thus far.[71]
 
Proposed Solutions
In response to criticisms about the legalities, exclusions, and ambiguities in international refugee law, a multitude of solutions can be proposed, ranging from broader institutional reforms to specific policy adjustments targeting North Korean refugees. Betts suggests two different approaches: normative and institutional.[72] At the normative level, options include working with the existing legal framework, developing a “soft law framework,” consolidating human rights law through guidance from survival and migration principles, and, lastly, adding an additional protocol to the 1951 Convention.[73] The implementation of this method would incorporate “survival migration” into current legislation, pertaining to refugees, escapees, and defectors, such as those from North Korea.[74]
 
For institutional recommendations, Betts presents five ways forward: 1) applying a “cluster approach,” where “...the Inter-Agency Standing Committee (IASC) developed in the context of UN humanitarian reform,” 2) designating responsibility to a single agency, 3) creating a new, efficient body that could work on a temporary basis to help coordinate other agencies, 4) creating a special representative that can oversee these coordination, and finally, 5) “...creating an issue-based consultative process.”[75] Overall, Betts argues that such reforms are political in nature and would inevitably lead to disagreements and tensions between states.[76] As such, commitments to helping aid survival migrants should be achieved within existing frameworks, especially when also considering all the other interwoven factors as aforementioned.[77]
 
From a case-study approach, HRNK’s recommendations provide a plethora of solutions, including: 1) Clarifying the number, status and humanitarian situation of the North Korean refugees and workers in China. 2) The imperative for China to address its violations of international law, recognize North Korean escapees as refugees and respect the principle of non-refoulment. 3) The recommendation to the United States to seek more direct ways to reach refugees in China and to help with asylum in the USA. 4) North Korean refugee protection and rescue must become a pillar of the North Korean Human Rights Act. 5) The reauthorization of the NKHR Act, which expired in 2022.[78]
 
Ultimately, I recommend a hybrid solution, considering a mix of these proposed recommendations and results seen in current legislation and advocacy. This alternative would encapsulate Betts’ soft law framework, emphasizing the need to incorporate “survival migrants” and other factors not currently addressed in legislation, particularly the 1951 UN Convention, working more extensively with South Korea’s government-run organizations such as the Hanawon, NGOs such as the Nomi Network and Refugees International, and reauthorizing the NKHR Act, thereby securing a more prominent place in American foreign policy.
 
 
Conclusion
The legal status and survival migration of North Korean refugees underscore the urgent need for comprehensive reforms in international refugee law and humanitarian practices. The case studies of North Korean defectors in South Korea, the United Kingdom, the United States, and China reveal significant gaps and ambiguities in their protection and resettlement. Addressing these challenges requires a hybrid approach that incorporates normative and institutional reforms, enhanced collaboration with NGOs, and the reauthorization of the NKHR Act. By prioritizing the fundamental human rights of North Korean refugees and adopting adaptive frameworks, the international community can better support their survival and integration, ultimately fostering a more just and humane global refugee system.

Isabella Grace Packowski is a graduate student at Indiana University Bloomington pursuing a Master’s in International Affairs with a concentration in security, diplomacy, and governance. She holds a BA in Korean Language and Culture with a minor in Political Science, where her studies focused on U.S.–ROK/DPRK relations, foreign policy, and international security. Her research experience includes archival analysis of North Korea’s Juche ideology. As an intern at the Committee for Human Rights in North Korea (HRNK) in 2023, she contributed to the translation of publications. She also conducted international media monitoring supported the production of daily newsletters highlighting key developments in North Korean human rights and policy. With a strong foundation in cross-cultural engagement, political history studies, and policy analysis, Isabella aims to advance diplomacy and proliferation security through future work with the U.S. State Department or international NGOs.

 
Bibliography
 
“A Lifetime in Detention: Rohingya Refugees in India - Refugees International.” 2025. Refugees International. January 2, 2025. https://www.refugeesinternational.org/reports-briefs/a-lifetime-in-detention-rohingya-refugees-in-india/.

Betts, Alexander, Loescher, Gil, and Milner, James. 2012. The United Nations High Commissioner for Refugees (UNHCR): The Politics and Practice of Refugee Protection. Oxford: Taylor & Francis Group. Accessed April 27, 2025. ProQuest Ebook Central.

Betts, Alexander. “Survival Migration: A New Protection Framework.” Global Governance 16, no. 3 (2010): 361–82. http://www.jstor.org/stable/29764952.

“Global Voices for Rights and Refuge - Refugees International.” 2025. Refugees International. January 22, 2025. https://www.refugeesinternational.org/.

“Hanawon - North Korean Resettlement Facility in South Korea | Crossing borders.” (n.d.). Crossing Borders - Helping North Korean Refugees and Orphans. https://www.crossingbordersnk.org/hanawon
H.R.3012 - 118th Congress (2023-2024): North Korean Human Rights Reauthorization Act of 2023. (n.d.). Congress.gov | Library of Congress. https://www.congress.gov/bill/118th-congress/house-bill/3012?s=1&r=21

HRNK. (2025, January 27). Policy Recommendations - HRNK. https://www.hrnk.org/about/policy-recommendations/

Ryu, Eric. 2021. “Why the Number of North Korean Refugees in the United States Is so Low.” Edited by Sophia Hapin and Rosa Park. NKHIDDENGULAG. August 10, 2021. https://www.nkhiddengulag.org/blog/why-the-number-of-north-korean-refugees-in-the-united-states-is-so-low.

Scarlatoiu, Greg and U.S. Committee for Human Rights in North Korea (HRNK). 2023. “Written Statement for the Congressional Executive Commission on China.” https://www.hrnk.org/wp-content/uploads/2024/07/Scarlatoiu-CECC-Response-HRNK-FINAL-.pdf.

“Seeking Safer Shells: An Analysis of Interpretations, Justifications, and Rationales Behind Decisions on North Korean Defectors’ Right to Asylum.” n.d. Journal of Public and International Affairs. https://jpia.princeton.edu/news/seeking-safer-shells-analysis-interpretations-justifications-and-rationales-behind-decisions.

United Nations General Assembly & United Nations High Commissioner for Refugees. (n.d.). Convention and protocol relating to the status of refugees. https://www.unhcr.org/sites/default/files/2025-02/1951-refugee-convention-1967-protocol.pdf

“Year in Review | Nomi Network.” n.d. Nomi Network. https://nominetwork.org/year-in-review/.

Young Kim. 2024. “US Congress Fails to Extend North Korean Human Rights Act - Congresswoman Young Kim.” Congresswoman Young Kim - Representing California’s 40th District (blog). December 26, 2024. https://youngkim.house.gov/2024/12/26/us-congress-fails-to-extend-north-korean-human-rights-act/.


[1] Betts, Alexander, Loescher, Gil, and Milner, James. 2012. The United Nations High Commissioner for Refugees (UNHCR): The Politics and Practice of Refugee Protection. Oxford: Taylor & Francis Group. Accessed April 27, 2025. ProQuest Ebook Central. (pg. 7)
[2] Ibid, 8-9.
[3] Ibid, 9.
[4] Ibid, 8,10,13.
[5] Ibid..
[6] Ibid, 15.
[7] Ibid, 14.
[8] Ibid., 13-14.
[9] Ibid.
[10] Ibid., 2, 19-20, 28-29.
[11] Ibid., 55, 57, 62.
[12] “Seeking Safer Shells: An Analysis of Interpretations, Justifications, and Rationales Behind Decisions on North Korean Defectors’ Right to Asylum.” n.d. Journal of Public and International Affairs. https://jpia.princeton.edu/news/seeking-safer-shells-analysis-interpretations-justifications-and-rationales-behind-decisions.    
[13] Ibid.
[14] Ibid.
[15] Ibid.
[16] Ibid.
[17] Ibid.
[18] Ibid.
[19] Ibid.
[20] Ibid.
[21] Ibid.
[22] Ibid.
[23] Ryu, Eric. 2021. “Why the Number of North Korean Refugees in the United States Is so Low.” Edited by Sophia Hapin and Rosa Park. NKHIDDENGULAG. August 10, 2021. https://www.nkhiddengulag.org/blog/why-the-number-of-north-korean-refugees-in-the-united-states-is-so-low.
[24] Ibid.
[25] Ibid.
[26] Ibid.
[27] “Seeking Safer Shells…”; Young Kim. 2024. “US Congress Fails to Extend North Korean Human Rights Act - Congresswoman Young Kim.” Congresswoman Young Kim - Representing California’s 40th District (blog). December 26, 2024. https://youngkim.house.gov/2024/12/26/us-congress-fails-to-extend-north-korean-human-rights-act/.
[28] Kim, Young, 2024, “US Congress Fails to Extend North Korean Human Rights Act - Congresswoman Young Kim.”; H.R.3012 - 118th Congress (2023-2024): North Korean Human Rights Reauthorization Act of 2023. (n.d.). Congress.gov | Library of Congress. https://www.congress.gov/bill/118th-congress/house-bill/3012?s=1&r=21.
[29] “Seeking Safer Shells…”
[30] Ibid.
[31] Ibid.
[32] Scarlatoiu, Greg and U.S. Committee for Human Rights in North Korea (HRNK). 2023. “Written Statement for the Congressional Executive Commission on China.” https://www.hrnk.org/wp-content/uploads/2024/07/Scarlatoiu-CECC-Response-HRNK-FINAL-.pdf. (pg. 1, 4)
[33] Ibid., 4.
[34] Ibid; United Nations General Assembly & United Nations High Commissioner for Refugees. (n.d.). Convention and protocol relating to the status of refugees. https://www.unhcr.org/sites/default/files/2025-02/1951-refugee-convention-1967-protocol.pdf (pg. 30)
[35] “Written Statement for the Congressional Executive Commission on China,” 2.
[36] Ibid., 3,7.
[37] Ibid., 7.
[38] Ibid., 3-4.
[39] Ibid.
[40] Ibid.
[41] Ibid.
[42] Ibid.
[43] Ibid.
[44] Ibid.
[45] Ibid., 6-7.
[46] Ibid.
[47] Ibid., 2-3, 8.
[48] Ibid.
[49] “Seeking Safer Shells…”
[50] Ibid.
[51] Ibid.
[52] “Written Statement for the Congressional Executive Commission on China,” 7.
[53] Ibid., 2.
[54] Betts, Alexander. “Survival Migration: A New Protection Framework.” Global Governance 16, no. 3 (2010): 361–82. http://www.jstor.org/stable/29764952.
[55] Ibid.
[56] “A Lifetime in Detention: Rohingya Refugees in India - Refugees International.” 2025. Refugees International. January 2, 2025. https://www.refugeesinternational.org/reports-briefs/a-lifetime-in-detention-rohingya-refugees-in-india/.
[57] Ibid.
[58] Ibid.
[59] Ibid., 362, 364.
[60] Ibid, 361-362, 364.
[61] Ibid., 362.
[62] Ibid., 363.
[63] “Hanawon - North Korean Resettlement Facility in South Korea | Crossing borders.” (n.d.). Crossing Borders - Helping North Korean Refugees and Orphans. https://www.crossingbordersnk.org/hanawon
[64] Ibid.
[65] Ibid.
[66] Ibid.
[67] Ibid.
[68] “Year in Review | Nomi Network.” n.d. Nomi Network. https://nominetwork.org/year-in-review/.
[69] Ibid.
[70] Ibid.
[71] “A Lifetime in Detention…”
[72] Ibid., 377.
[73] Ibid.
[74] Ibid.
[75] Ibid.
[76] Ibid., 377-378.
[77] Ibid.
[78] Scarlatoiu, 8.

By Ada Trybuchowska, HRNK Research Intern
Edited by Diletta De Luca, HRNK Research Associate

Introduction
          Far from the public eye, North Korean workers labor in foreign lands under intense surveillance, stripped of freedom, and denied their earnings. Pyongyang sends tens of thousands of North Korean workers to countries like China and Russia to earn foreign currency for the regime, often under conditions amounting to forced labor.[1] They pack seafood, pour concrete, and sew garments, often receiving a fraction of the pay – if any.[2] What followed in Helong, China, was not merely a labor dispute but a rare assertion of human dignity. Echoing the legacy of Poland’s Solidarność – a trade union movement born from the 1980 Gdańsk Shipyard strikes that successfully challenged a communist regime – this piece examines the Helong protest and draws lessons from Solidarność.
 
A Factory Revolt: The Helong Uprising and Its Roots
          On a bitterly cold morning in January 2024, something extraordinary happened in the China-North Korea border city of Helong. That winter, hundreds of North Korean workers rose against their overseers, staging a rare protest to demand unpaid wages and repatriation. The unrest centered around factories in Nanping Town, a key industrial hub for food processing and garment production, which employed North Koreans.[3] Laborers from over ten textile and garment plants across Helong joined the action.[4] For three tense days, nearly 3,000 North Korean migrant workers staged a mass revolt.[5] They locked their Chinese and North Korean supervisors, halted production, and demanded the wages they had been denied for months, totaling approximately $10 million.[6] This was not a typical labor dispute; it directly confronted one of the world’s most repressive systems of labor control, where obedience stems not just from state coercion but from fear for one’s family, future, and life. Tensions climaxed when, amid confrontation, one of the detained North Korean officials (dispatched to monitor the workers) was beaten to death by the protesters.[7] North Korean state security agents agreed to pay several months’ worth of wages directly to the workers on-site, and the protesters ended the strike later that day. This concession temporarily defused the situation. No other known North Korean labor protest abroad had ever reached this scale.[8]  

          The Helong uprising ruptured Pyongyang’s carefully cultivated fear system. Officially, North Korea had sent young workers abroad under the pretense of patriotism and economic duty. In reality, they formed part of a vast state-run labor export system, which dispatched tens of thousands of North Koreans to factories and construction sites across Asia, Africa, and the Middle East.[9] As of 2024, an estimated 100,000 North Koreans continued working in foreign countries.[10] Although some deployments remain nominally legal, they often bypass international labor laws and violate UN Security Council Resolution 2397, which banned North Korean overseas labor and required all such workers to be repatriated by 2019, aiming to cut off the regime’s illicit income for its nuclear program.[11] Due to inconsistent enforcement, many remain abroad, creating a gray economy worth up to US $500 million annually for the North Korean regime.[12]

          The Helong protest began after workers discovered that colleagues repatriated to North Korea had never received their promised wages.[13] Pyongyang confiscates up to 70-90% of workers’ earnings, often only paying workers upon returning home, further ensuring their dependence and obedience.[14] This revelation shattered the fragile illusion that obedience might lead to reward. The workers occupied the factory, barricaded the gates, and refused to return to work. This collective defiance stood out for its scale and the immense risk involved.[15]

          North Korean overseas workers live under constant surveillance, their passports confiscated upon arrival, housed in cramped dormitories with poor living conditions, enduring shifts up to 16 hours daily, with monitored conversations and banned phones.[16][17] Any sign of dissent leads to punishment, including forced repatriation to North Korea, where imprisonment or execution, along with retribution against one’s family, often follows.[18] Within this brutal context, the Helong protest became a rare and radical assertion of human agency.

          By late January, Chinese and North Korean authorities responded. North Korean officials rushed to Helong and paid several months of overdue wages to placate the workers, temporarily defusing the situation.[19] They then quietly dispersed the workers, relocated them to other sites, or returned them home; however, most of them faced consequences.[20] Half of them were forcibly repatriated to North Korea, likely sent to political prison camp; the others were placed under heightened surveillance.[21] This response mirrored a longstanding pattern of punishment; Pyongyang uses overseas labor not only to earn revenue but also to test their loyalty, as many of the workers come from families considered politically loyal.[22]  

          Chinese and North Korean authorities suppressed the Helong protest. Still, the incident remains essential for exposing the limits of control in even most repressive labor systems. Helong matters as it shows that even tightly controlled workers can resist. It also raises questions about how long Pyongyang can contain such defiance. This case compares to another labor movement where workers challenged a regime claiming to speak for them. That movement began in Poland when shipyard workers launched a strike that changed the country’s future.
 
Lessons from Gdańsk: When Labor Became a Movement
          In the summer of 1980, Polish workers at the Gdańsk Shipyard launched a strike that reshaped the Cold War era and redefined labor resistance under authoritarianism. What began as a local protest over price hikes and deteriorating living conditions quickly became one of postwar Europe’s most consequential social movements. At the center stood an electrician named Lech Wałęsa, who later became Poland’s President and received the Nobel Peace Prize.[23] His leadership helped transform a single workplace dispute into Solidarność (Solidarity), the first independent trade union in the Soviet bloc.[24] Within a year, Solidarność grew into a nationwide force with nearly 10 million members, more than a quarter of Poland’s population at the time.[25]

          The movement did not function as an ordinary union. Solidarność became a civic movement that united workers, intellectuals, students, and clergy around a shared vision of rights, dignity, and political reform.[26] Members demanded more than wage increases or better working conditions; they called for freedom of speech, access to independent media, the release of political prisoners, and an end to censorship, demands that directly confronted the communist rule. The August 1980 Gdańsk Accords, signed after mass strikes, granted limited rights to strike and organize independently; that agreement marked a crack in the Iron Curtain, a breach the regime immediately tried to seal.[27]

          In December 1981, General Wojciech Jaruzelski imposed martial law, banned Solidarność, and imprisoned thousands of activists.[28] Nevertheless, underground networks of union members and supporters continued to publish clandestine newspapers, organize covert meetings, and stage sporadic strikes. The Catholic Church offered protection and moral legitimacy, while Western governments and labor unions provided material and symbolic support.[29] Aid arrived through smuggled printing presses, shortwave radio broadcasts, and public campaigns led by foreign trade unionists.[30] These networks served as lifelines and deterred harsher repression by signaling global awareness and solidarity.

          Throughout the 1980s, Solidarność challenged the communist establishment with persistent resilience. This effort culminated in 1988 when renewed strikes and an economic crisis forced the regime to negotiate. The 1989 Round Table Talks produced an agreement to hold partially free elections, where Solidarność candidates won by a landslide.[31] By August, Tadeusz Mazowiecki, one of the movement’s advisors, assumed office as the first non-Communist Prime Minister in the Eastern Bloc, initiating Poland’s peaceful democratic transition.[32] Solidarność demonstrated that organized labor backed by broad civic coalitions could successfully confront entrenched authoritarian rule.

          Several factors allowed for this transformation. Firstly, the organization was crucial. Solidarność emerged from earlier dissident groups like the Committee for the Defence of Workers (KOR), which provided the intellectual and logistical groundwork for collective resistance.[33] Secondly, pluralism played a key role. Solidarność transcended class and ideology, uniting blue-collar workers, urban professionals, students, and clergy. Thirdly, effective communication sustained momentum. Underground publications, leaflets, and word-of-mouth kept members informed and connected despite martial law.[34] Lastly, international solidarity made a significant difference. Labor unions from Western countries, including the United States and France, contributed funding, training, advocacy platforms, and international visibility.[35] The Vatican also provided moral support, and Western media highlighted the movement’s struggles.[36]

          The Polish experience provides valuable insights. Authoritarian regimes often claim to act in the name of workers. However, when workers rise up, they expose the regime’s most profound contradictions. Solidarność revealed how labor activism, fused with broader demands for justice and freedom, can evolve into a powerful national movement capable of influencing history. It proved that authoritarianism can be vulnerable to collective resistance under the right conditions. North Korean workers have already demonstrated immense courage. The crucial question remains whether conditions permit that courage to grow into a similarly impactful movement inside North Korea.
 
What Connects (and Divides) These Stories
          At first glance, Polish shipyard strikers and North Korean workers in China appear to come from opposite ends of history. They operated under different regimes, faced different constraints, and emerged in dramatically different geopolitical contexts. Yet their acts of defiance, separated by over four decades and thousands of miles, reveal parallels.

          In both cases, groups of ordinary workers took significant personal risks to protest exploitation. It takes immense bravery for any group of laborers, whether shipbuilders in Gdańsk or factory workers in Helong, to collectively say “no.” In both movements, the youth and a sense of injustice played an important role. In Poland, young workers and students joined Solidarność alongside veteran laborers. Teenagers held hunger strikes, wore Solidarność badges, and debated politics in schoolyards.[37] These acts revealed how deeply the movement captured the imagination of a new generation. Similarly, many of the Helong protesters were young women in their twenties, reportedly former Korean People’s Army (KPA) soldiers dispatched abroad through a trading company under North Korea’s Ministry of Defense.[38] Despite their background, they may have been less influenced by regime propaganda than older generations.

          The diffusion of information played a key role in both cases. The Polish movement benefited from established underground communication channels. Activists spread their message through pamphlets, church sermons, and foreign media broadcasts, allowing the strike to inspire solidarity nationwide. In contrast, North Korean workers lacked independent networks, and news of Helong reached the outside world through South Korean intelligence and defector testimonies.[39] Yet even within these limits, information traveled. Researcher Cho Han-bum and former diplomat Ko Young-hwan publicized the Helong protest through interviews and online commentary,[40] and major outlets soon picked up their accounts. Moreover, South Korea’s National Intelligence Service (NIS) confirmed “various incidents and accidents” involving North Korean workers, attributing them to poor labor conditions.[41] Although the NIS released few details, South Korean experts and former North Korean officials quickly amplified the story. The Helong protest sparked similar incidents among North Korean workers in other Chinese cities, including Dandong.[42] In Dandong, workers refused to return to their jobs and demanded to go home, citing long-term physical and emotional exhaustion. According to reports, some said they would rather die in North Korea than remain in China.[43] Although the Helong protest lacked the coordination and structure of Solidarność, it sparked visible unrest elsewhere, showing that even fragmented acts of resistance can carry influence beyond a single factory gate.

          The movements differed not only in scale but also in how they organized and sustained leadership. Solidarność became a formal movement with elected leaders and inter-factory coordination. Dissident advisers supported it, and the movement maintained solidified negotiation channels. The North Korean protests, however, were spontaneous and without a clear leader, and desperation rather than strategy drove them. In Helong, leadership emerged informally and remained anonymous. Authorities later identified around 200 individuals as “leaders” of the unrest and reportedly sent many to prison camps.[44] After the protest, officials increased ideological indoctrination sessions from weekly to daily, seeking to reassert control.[45] These mandatory sessions reinforce loyalty to Kim Jong-un and frame any dissent, even abroad, as betrayal. Workers must attend lectures, recite slogans, and submit written reflections affirming their ideological commitment each day.[46]

          These differing structures shaped each movement’s durability. Solidarność maintained pressure for nearly a decade and eventually helped lead Poland’s democratic transition. The Helong uprising lasted only a few days. Although some overdue wages were paid to ease tensions, authorities swiftly punished those held responsible. In Poland, the majority of leaders returned to public life by 1984.[47] The Helong protest exposed cracks in a system built to suppress dissent. Like the Gdańsk strikers who held their ground, Helong’s workers disrupted the illusion of total control. Their actions signaled to Pyongyang that even the most trusted laborers have limits that must be respected. Moreover, unlike Solidarność, which gained rapid international solidarity in the 1980s, the Helong workers count not receive public support from any foreign government. The global response remained limited to intelligence briefings and quiet diplomacy, likely to avoid worsening the risk to those involved. This silence further illustrates the isolation faced by North Korean workers.

          The severity of state reprisals also differed. While both regimes used crackdowns, North Korea responded more harshly. Martial law in Poland between 1981 and 1983 led to thousands of arrests but relatively few deaths; many of the prisoners later received amnesty.[48] North Korean authorities classify even non-violent strikes as acts of treason, and the Helong protesters likely understood that their actions could lead to execution or indefinite detention.

          North Korea’s system of collective punishment further magnifies these risks. Unlike in Poland, where repression often targeted individual activists, North Korean authorities apply yeon-jwa-je, also known as “guilt by association”.[49] Family members can face punishment for a relative’s perceived disloyalty. This hostage-like leverage discourages many from resisting, forcing them to consider not only their own safety but the fate of their loved ones back home. The regime’s use of collective punishment adds a uniquely cruel dimension to its repression. Workers often comply out of fear for their families and themselves. It stifles not just public voices but even the private thought of resistance.
 
The Role of International Society and What Comes Next
          The international response has not matched the scale of these abuses. No UN resolution or public statement has addressed the Helong protest, likely because China and North Korea concealed the incident, and verifying details remains difficult. The U.S. Treasury sanctioned Chinese and Russian firms in 2020 for violating a UN resolution on overseas labor.[50] These efforts suggest growing concern but limited enforcement. In March 2024, Russia blocked the UN Panel of Experts’ renewal, thus severely diminishing sanctions compliance.[51] Without oversight, violations will likely rise further. Furthermore, in 2024, the UN Human Rights Office described North Korea’s labor export system as state-sponsored forced labor and a potential crime against humanity.[52]

          The legacy of Solidarność reminds us that solidarity must cross borders. Since North Korean workers cannot speak freely, others must continue to do so in their place. NGOs, embassies, and legal advocates must help build secure communication channels for workers in danger. Supporting these workers remains both a moral duty and a practical strategy to weaken North Korea’s forced labor economy.

Concluding remarks
          Poland’s Solidarność movement and the Helong strike, separated by over four decades and vastly different regimes, reveal the power and limits of labor resistance under authoritarian rule. Each began with a basic demand for dignity: Polish shipyard workers sought independent unions, and North Korean laborers demanded their earned wages. Both demands challenged regimes that claimed to defend workers while exploiting their labor. Solidarność succeeded by building leadership, underground networks, and securing international support. North Korean workers, by contrast, continue to lack protection, communication channels, and the freedom to organize. The Helong protest nevertheless reflected extraordinary courage under extreme risk. The international community has taken some steps, but its efforts remain insufficient.
​
          Solidarność offers both an inspiration and a warning. It models how organized labor, civic unity, and international backing can challenge repression, but also warns of the risks when a movement lacks sustained support or fractures under pressure.

          Grassroots defiance can help topple rigid regimes, but only with unity and outside support. The Helong strike reflected that same spirit in one of the harshest conditions imaginable. These workers risk retaliation against themselves and their families. Their resistance calls for an international response. Repression grows stronger when courage meets silence. Small acts of defiance can become lasting movements only if sustained legal, diplomatic, and material support follows.

Ada Trybuchowska is a recent graduate of the Master of Global Affairs program at the University of Toronto's Munk School of Global Affairs and Public Policy. She is currently a Research Intern at HRNK, contributing to analysis and communications on North Korean human rights. Her research interests include cybersecurity, human rights advocacy, and the politics of Central and Eastern Europe, with a particular emphasis on populism and digital policy.

[1] Eugene Whong, “100,000 North Koreans Work Abroad, Earning US$500 Million a Year: UN,” Radio Free Asia, March 21, 2024, https://www.rfa.org/english/news/korea/workers-03212024162926.html.  
[2] Ju-min Park, “Signs of Rare Unrest among North Korean Workers in China, Researchers Say,” Reuters, February 8, 2024, https://www.reuters.com/world/asia-pacific/signs-rare-unrest-among-north-korean-workers-china-researchers-say-2024-02-08/.
[3] Seulkee Jang, “N. Korean Official’s Death in China Leads to Increased Ideological Reviews of Workers,” Daily NK, March 6, 2024, http://www.dailynk.com/english/north-korean-officials-death-china-leads-increased-ideological-reviews-workers/.
[4] Ju-min Park, “Signs of Rare Unrest among North Korean Workers in China, Researchers Say.”.
[5] Ibid.
[6] Ibid.
[7] Tae-jun Kang, “Enraged N Korean Workers in China Beat Factory Manager to Death: Report,” Radio Free Asia, February 19, 2024, https://www.rfa.org/english/news/korea/nkorean-workers-kill-manager-02192024003047.html#:~:text=when%20the%20hostage%20management%20representative,to%20death%20by%20the%20workers.
[8] Ju-min Park, “Signs of Rare Unrest among North Korean Workers in China, Researchers Say.”
[9] Philippe Pons, “North Korean Workers Abroad, a Financial Windfall for the Pyongyang Regime,” Le Monde, March 30, 2025, https://www.lemonde.fr/en/international/article/2025/03/30/north-korean-workers-abroad-a-financial-windfall-for-the-pyongyang-regime_6739654_4.html.
[10] Ibid.
[11] Min Chao Choy, “Last Year, North Korean Workers Were Banned Abroad. But Some Still Didn’t Leave.,” NK News, December 21, 2020, https://www.nknews.org/2020/12/last-year-north-korean-workers-were-banned-abroad-but-some-still-didnt-leave/.
[12] Chad O’Carroll, “100K North Koreans Still Earning Money for Regime Overseas: UN Report,” NK News, March 21, 2024, https://www.nknews.org/2024/03/100k-north-koreans-still-earning-money-for-regime-overseas-un-report/.
[13] Ju-min Park, “Signs of Rare Unrest among North Korean Workers in China, Researchers Say.”
[14] U.S. Department of State, 2021 Trafficking in Persons Report: North Korea, July 1, 2021, https://www.state.gov/reports/2021-trafficking-in-persons-report/north-korea/.
[15] Park Chan-kyong, “Could Reports of a North Korean Workers’ Riot in China ‘Pose Threats’ to the Regime?,” South China Morning Post, January 31, 2024, https://www.scmp.com/week-asia/economics/article/3250287/could-reports-north-korean-workers-riot-china-pose-threats-regime.
[16] U.S. Department of State, 2022 Country Reports on Human Rights Practices: North Korea, March 20, 2023, https://www.state.gov/reports/2022-country-reports-on-human-rights-practices/north-korea/.
[17] Greg Scarlatoiu, Raymond Ha, and Hyunseung Lee, North Korean Workers Officially Dispatched to China & Russia: Human Rights Denial, Chain of Command & Control (Washington, DC: Committee for Human Rights in North Korea, 2022), https://www.hrnk.org/wp-content/uploads/2022/11/Overseas_Workers_0926.pdf.
[18] Ibid.
[19] Tae-jun Kang, “Enraged N Korean Workers in China Beat Factory Manager to Death: Report.”
[20] Ibid.
[21] Ibid.
[22] Park Chan-kyong, “Could Reports of a North Korean Workers’ Riot in China ‘Pose Threats’ to the Regime?.”
[23] Gdańsk - The Gdańsk Shipyard, the Birthplace of Solidarity,” Zabytek, accessed May 3, 2025, https://zabytek.pl/en/obiekty/gdansk-stocznia-gdanska-miejsce-narodzin-solidarnosci.
[24] Maciej Bartkowski, “Poland’s Solidarity Movement (1980-1989),” International Center on Nonviolent Conflict, December 2009, https://www.nonviolent-conflict.org/polands-solidarity-movement-1980-1989/.
[25] Ibid.
[26] Mikołaj Gliński, “The Solidarity Movement: Anti-Communist, Or Most Communist Thing Ever?,” Culture, August 9, 2016, https://culture.pl/en/article/the-solidarity-movement-anti-communist-or-most-communist-thing-ever.
[27] Sebastian Ligarski, “Not Just Gdańsk. the August 1980 Accords,” Polish History, accessed May 3, 2025, https://polishhistory.pl/not-just-gdansk-the-august-1980-accords/.
[28] Wojciech Polak, “Different Faces of Martial Law,” Polonia Institute, June 17, 2024, https://poloniainstitute.net/current-events/different-faces-of-martial-law/.
[29] Rafał Łatka: Kościół Katolicki a Solidarność (1980–1981),” Instytut Pamięci Narodowej, April 15, 2024, https://ipn.gov.pl/pl/historia-z-ipn/archiwum/162937%2CRafal-Latka-Kosciol-katolicki-a-Solidarnosc-19801981.html#:~:text=Wpływ%20na%20etos%20.
[30] Tomasz Kozłowski, “Solidarity: A Trade Union as a Cold War Actor (1980–1993),” in The Palgrave Handbook of Non-State Actors in East-West Relations, ed. Péter Marton, Gitte Thomasen, Csaba Békés, and András Rácz (Cham: Palgrave Macmillan, 2024), https://doi.org/10.1007/978-3-031-05750-2_57-1, p. 3-4.
[31] Ibid., p. 10.
[32] Ibid.
[33] Colin Barker, “The Rise of Solidarnosc,” International Socialism, October 17, 2005, https://isj.org.uk/the-rise-of-solidarnosc/.
[34] Evans, Kristi S. “The Argument of Images: Historical Representation in Solidarity Underground Postage, 1981-87.” American Ethnologist 19, no. 4 (1992): 749–67. http://www.jstor.org/stable/644917.
[35] Arch Puddington, “Surviving the Underground,” American Educator, 2005, https://www.aft.org/ae/summer2005/puddington.
[36] Maciej Bartkowski, “Poland’s Solidarity Movement (1980-1989).”
[37] Kristi S. Evans, “The Argument of Images: Historical Representation in Solidarity Underground Postage, 1981–87.”
[38] Tae-jun Kang, “Enraged N Korean Workers in China Beat Factory Manager to Death: Report.”
[39] Ju-min Park, “Signs of Rare Unrest among North Korean Workers in China, Researchers Say.”
[40] Ibid.
[41] Ibid.
[42] Kim Soo-yeon, “N. Korean Workers Refuse to Go to Work in Dandong: Seoul Expert,” Yonhap, February 29, 2024, https://en.yna.co.kr/view/AEN20240229008500315.
[43] Ibid.
[44] Tae-jun Kang, “Enraged N Korean Workers in China Beat Factory Manager to Death: Report.”.
[45] Seulkee Jang, “N. Korean Official’s Death in China Leads to Increased Ideological Reviews of Workers.”
[46] Ibid.
[47] Maciej Bartkowski, “Poland’s Solidarity Movement (1980-1989).”
[48] Benedek Pál, “‘All the Telephone and Telex Lines Are Disconnected’ – RFE and the 1981 Martial Law in Poland,” Blinken OSA Archivum, December 13, 2021, https://www.archivum.org/entries/blog/all-the-telephone-and-telex-lines-are-disconnected---rfe-and-the-1981-martial-law-in-poland.
[49] David Hawk, The Hidden Gulag: The Lives and Voices of “Those Who Are Sent to the Mountains”, 2nd ed.,Washington, DC: Committee for Human Rights in North Korea, 2012, https://www.hrnk.org/wp-content/uploads/pdfs/publications/eng/HRNK_HiddenGulag2_Web_5-18.pdf, p. 29.
[50] Mathew Ha, “Treasury Sanctions Companies Exporting North Korean Labor to Russia,” Foundation for Defense of Democracies, November 23, 2020, https://www.fdd.org/analysis/2020/11/23/treasury-sanctions-north-korean-labor-russia/.
[51] Edith M. Lederer, “Russian Veto Brings an End to the UN Panel That Monitors North Korea Nuclear Sanctions,” AP News, March 28, 2024, https://apnews.com/article/un-us-north-korea-russia-sanctions-monitoring-72f8cbac116dea7c795d9a3357fc45f3.
[52] Tae-jun Kang, “Enraged N Korean Workers in China Beat Factory Manager to Death: Report.”.