2025 Outlook on the North Korean Sanctions Regime: A Needed Turning Point in Sanctions Enforcement?

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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[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.