US President Issues Executive Order Imposing Additional Sanctions on North Korea

The executive order expands the extraterritorial reach of existing North Korea sanctions by extending it to US persons' dealings with non-US actors that do business with North Korea.

On September 21, President Trump issued a new executive order (EO) with respect to North Korea. While US persons already were prohibited from all commercial dealings with North Korea under existing sanctions, the EO broadens to a new level the extraterritorial reach of these US sanctions' proscriptive jurisdiction in connection with non-US (or foreign) persons.

This impact occurs through certain key provisions of the EO:

• Section 1(a)(iii) authorizes the United States to block the property and interests in property within the United States or that may come into the possession or control of a US person, of any foreign person located anywhere in the world who the Secretaries of the Departments of Treasury and State have determined "to have engaged in at least one significant importatio