Joshua Ray of Financial Crimes Specialists Rahman Ravelli Assesses US Prosecution of Two Foreign Nationals Charged with Sanctions Violations – Export Controls and Trade and Investment Sanctions

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US prosecutors have charged a British national and a Spanish citizen with helping programmer Virgil Griffith evade US sanctions against North Korea.

Griffith, the creator of the Ethereum blockchain, was jailed for 63 months after pleading guilty to conspiring to violate the International Emergency Economic Powers Act; the legislation that is at the heart of the US sanctions regime. He was accused of helping North Korea by giving a presentation in 2019 in its capital Pyongyang on how digital currency could be used to both launder money and evade sanctions.

Alejandro Cao De Benos, 47, and Christopher Emms, 30, were accused of planning the Pyongyang conference with Griffith. They are charged with one count of conspiracy to violate and evade US sanctions imposed on North Korea in 2008 under the International Emergency Economic Powers Act (IEEPA). The charge carries a maximum sentence of 20 years in prison.

According to the indictment, Cao De Benos founded the Korean Friendship Association (KFA), a Spanish pro-North Korea group. Emms would be the KFA’s technology advisor.

Emms and Cao De Benos, who are on the run, allegedly helped North Korea with cryptocurrency and blockchain services after the conference.

Their current situation shows that the US Department of Justice (DOJ) is aggressively pursuing alleged sanctions violators with criminal charges.

The DOJ has even gone so far as to say that penalties are now the “new FCPA” – the Foreign Practices and Corruption Act, which prohibits bribery – in terms of enforcement priorities. Its pursuit of these foreigners shows that the DOJ takes a broad view of its jurisdiction. Griffith’s imprisonment highlights the grave risks faced by those involved in activities anywhere in the world that could be seen as facilitating violations of US sanctions.

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