The United States has filed a series of civil forfeiture complaints against money that was destined for North Korea in violation of North Korea sanctions. The complaints allege that the money was being routed through front companies incorporated in Hong Kong and was being funneled through correspondent bank accounts in the US to finance North Korea’s nuclear weapons and ballistic missile programs.
The complaints reflect the Government’s increased use of the civil forfeiture laws to combat instances of international money laundering that include not only violations of international sanctions against rogue states, but also the proceeds of Russian organized crime, kleptocracy, and other offenses in which criminals seek to use the US financial system to launder criminal proceeds. Legislation pending in Congress, however, would severely limit the Government’s future ability to use this tool. See The Baby and the Bathwater: Forfeiture “reform” bill would undermine the Government’s ability to combat international money laundering and other serious crimes
The following documents include the Government’s civil forfeiture complaints, a summary of a district court decision approving the use of a “damming warrant” to seize the funds destined for one Chinese company through the US correspondent accounts, and an article on the utility of civil asset forfeiture in cases involving the proliferation of weapons of mass destruction.