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A guest post by my colleague Cameron Trainer:

Russia takes its commitment to enforcing United Nations sanctions on North Korea seriously. So seriously, in fact, that when Russian businesswoman Irina Tyan was listed in a NPR article as operating a banned joint venture with DPRK consulate Vladivostok, the government immediately took action to close the business.

Or, y’know, not that at all. Tyan’s business is fine. Its name has changed but nothing else. The North Korean shareholders remain on the paperwork. They are, however, the Korea General Corporation “Kumgang” and not the consulate as stated in the NPR article. But that’s still a violation of UNSCR 2375 (2017), which required all joint ventures with North Korean entities or individuals to be closed no later than January 2018. Moreover, NPR’s attribution of the joint venture to DPRK consulate Vladivostok, likely based on comments by Tyan, may indicate that North Korean investment in the joint venture was managed through the consulate. That would make it a violation of UNSCR 2321 (2016), which emphasizes that DPRK diplomats are not to engage in commercial activity and that prohibited DPRK-owned or -leased real estate from being used for any purpose other than diplomatic or consular affairs. This is what is known—professionally, of course—as “subtle”.

Other such “subtle” North Korean activities in Russia include the basing of three representations of DPRK companies at the address of DPRK consulate Vladivostok as shown on the accompanying network chart. The first of these representations was registered in March 2018, the second and third following in July. What activities these representations are actually engaged in is unclear, so there isn’t a clear sanctions violation on that front. But they are all registered as hiring foreign workers (25 in total). If these are DPRK nationals—plausible, given they’re employed by a North Korean company registered to the address of the DPRK consulate—then this would almost certainly be a sanctions violation. UNSCR 2375 banned states from issuing work permits to DPRK nationals after September 2017 unless they have received a special exemption from the 1718 Sanctions Committee to do so. No such exemption appears to have been made in these cases. Since the representations were only established in 2018, it’s hard to see how their employees could have received work authorizations prior to the September 2017 cutoff.

This isn’t exactly new behavior though. The old DPRK consulate in Nakhodka, for example, appears to have been collocated with a couple of companies before it moved to Vladivostok in 2016. Corporate records place one now-inactive company at the consulate’s address from October 2014 until the company’s closure in September 2017. Another company, Construction Company “Kansong”, is listed alongside the consulate’s address in the Russian Ministry of Labor’s records of foreign worker authorizations for 2015.

The collocation of both companies with the Nakhodka consulate predates the restrictions in UNSCR 2321, so there isn’t really a sanctions violation here. What’s notable is that the way North Korea’s consulates have been used in Russia hasn’t changed irrespective of the expanding scope of UN sanctions. That’s nuts. And it is a pretty clear sign that Russia’s implementation of UN sanctions leaves much to be desired.