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ARTICLE · 12 MAY 2023

Doing Business With North Korea Will Cost You BIG!

Barnes, Richardson & Colburn
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Earlier this week, the British American Tobacco p.l.c. (BAT) and its subsidiary, BAT Marketing Singapore (BATMS), one of the world's largest manufacturers of tobacco products agreed to pay $629 million...

GlobalInternational Law
Ashley J. Bodden
Ashley J. Bodden

Earlier this week, the British American Tobacco p.l.c. (BAT) and its subsidiary, BAT Marketing Singapore (BATMS), one of the world's largest manufacturers of tobacco products agreed to pay $629 million in combined penalties to resolve bank fraud and sanctions violations charges with U.S. authorities. These violations arose out of the companies' scheme to do business in North Korea through a third-party company in Singapore, in violation of the bank fraud statute and the International Emergency Economic Powers Act (IEEPA).

In addition to the settlement of the criminal charges brought against BAT, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), announced its civil enforcement action against the company for its violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations (WMDPSR) that arose from BAT's formation of a conspiracy to remit approximately $250 million in payments from a North Korean joint venture, through

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