The United States has filed a civil forfeiture complaint against $1.9 million that was destined for Mingzheng Intl Trading Ltd, a front company incorporated in Hong Kong that was used to funnel money to North Korea through correspondent bank accounts in the US, in violation of North Korean sanctions. The complaint alleges that the transactions were part of a pattern of using front companies to finance North Korea’s nuclear weapons and ballistic missile programs.
The complaint reflects 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 complaint in the Mingzheng case, a summary of a district court decision approving the use of a “damming warrant” to seize the funds destined for Mingzheng 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.