·-' 


BarnabasTrading· , ~«...e.~40~~ 

Barnabas Trading Ltd. 

16748 E. Smoky Hill Rd., #107 

Centennial, CO 80015 

CONTAINS CONFIDENTIAL AND PROPRIETARY BUSINESS INFORMATION 

May 31,2011 

Ms. Jodi Kouts ,:~t! ~~~.' .....* 

-:.r . ,~~""""",,,,,;~._.,,, ~"~ 

,5 

Assistant Director for Licensing 

Office of Foreign Assets Control 

U. S. Department of the Treasury 

1500 Pennsylvania Avenue, N.W. -­ Annex 

Washington, D.C. 20220 

" f . ",I I • , ...... '. :.l,"· .. ,.... '­ " ...': " 

'. .: +'-"." . Dear Ms. Kouts:; :"" .' .. 


I 
 , . .,,' , I 

Barnabas Tra'ding Ltd. (UBT"), a limited liability company organize~ un(jer ~he laws of Colorado, , • t - < - '. ". :. ,;"'.' ~ • ~ ! . . . . . . (.' .. . I ~ • '1 . is seeking approvalftO'ril the Office of'Foreign Assets Control, ('~OFAC;") toirnport children's 

footwearttiat isman'uract'ured in' North Korea. 

We seek authorization to make multiple importations (initially small parcel shipments from 

China). 

As demonstrated by our responses to'the information requestsin 31 C.F.R. § SOO.S86(b)(2), we 

believe that the' im'portatiori of tn'ese shoes would 'not be Inconsistent with ,the policies 

,underlying the reg~lation" ,': ,"',,"',',","', .,.' 

Responses 'to Information Requests in 31 C.F.R. § SOO.S86{b)(2) 

31 C.F.R. § SOO.S86(b)(2}(ii) 'rH'os'E' SEEKING\O 'IM~ORT PR'O~OCrS:~R6MNORTH KbR~~'INTOTHdJl'iliED STATES MUST SUBMIT 

ALL AVAILABLE INFORMATION SATISFYING THE REQUIREMENTS OF PARAGRAPH (B)(2)(1) OFTHIS SECTION; THE NAME, ADDRESS, TElEPHONE 

NLJ~B.~R,>F,A\;~!.I\AIl:~.NUMBER,.,I\~D E-MAIL ADDRESS OF THE IMPORTER; • 

.',.,' 

2012-08-244:North Korea:JW:000001
Ms.Jodi Kouts 


May 31,2011 


Importer Information: 

Response 

Name of importer: Barnabas Trading Ltd. 

President: 

Address: 16748 E. Smoky Hill Rd., #107 

Centennial, CO 80015 

Telephone number: 

Fax number: None 

E-mail address: 

Web site: http://barnabastrading.com 

a description of the product to be imported, including quantity and cost; 

Response 


The children's footwear shall vary in size, raw ma~erial construction, and design . 


depending on the timing of OFAC's decision. Currently, a four-season children's shoe is 


in product development and targeted for production by Spring 2012: 


We seek authorization to import 1000 pairs of children's shoes. 

The cost of the shoe is estimated at $3/shoe. 

the name and address of the producer of the product; 

Response 

Name: Rason Industrial Company ("RIC") 

Legal Representative: 

Address: Rason City 

Rason Free Economic Trade Zone 

North Korea 

(Democratic People's Republic Of Korea of DPRK) 

the name of the location where the product was produced; 

Response 	 Rason City 

Rason Free Economic Trade Zone 

North Korea 

The North Korean producer of the product, RIC is under contract with Yanji'Sun Yang 

Shoe Company (hereinafter "SYC" or "Sun Yang China") to manufacture the shoes. SYC . 	 . 

- 2 ­

2012-08-244:North Korea:JW:000002

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) 
.-.j .. 

Ms. Jodi Kouts 

May 31,2011 

provides raw materials, equipment, expertise, and co-mana,ges ~he facility RIC for the 

production of these children's shoes. 

Name: Yanji Sun Yang Shoe Company 


Legal Representative: U.S. citizen). 


note: SYC.is in the midst of negotiations and by Spring' 

2012, the ownership of SYC may transfer to another U.S. 

corporation. If this event occurs, OFAC shall be promptly 

notified of any changes. 

Address: 	 Chang Bai Shan Street, # 2998B-1 


Yanji City, 133000, 


Jilin Province, PRC 


the name and address of the North Korean exporter. 

Response 


Name: Yanji Sun Ya'ng Shoe Company (DPRK branch office) 


~~ <21~~'&~ i?B-6A~ ~~.~AIA~ 

(hereinafter "SY-DPRK") 

Legal Representative: 	 U.S. citizen) 

Address: 	 Chung Kye Dong 

Rason City 

Rason Free Economic Trade Zone 

North Korea 

For purposes' of the informational request under § SOO.S86(b)(2)(ii), we believe that 

Yanji China Sun Yang Shoe Company (DPRK branch office) - hereinafter referred to as 

"SY-DPRK", would reasonably be considered the North Korean exporter. They shall 

make arrangements within North Korea for the export of the. shoes out of DPRK. 

SY-DPRK is a newly formed representative office (aka: branch office) in the DPRK of 

Yanji Sun Yang Shoe Company. 

31 C.F.R. § SOO.S86(b)(2)(i) THE IMPORTATION OF PRODUCTS INTO THE UNITED STATES FROM NORTH KOREA REQUIRES APPROVAL 

FROM THE OFFICE OF FOREIGN ASSETS CONTROL. THE PERSON SEEKING TO IMPORT PRODUCTS INTO THE UNITED STATES MUST PROVIDE 

INFORMATION RELEVANT TO THE DETERMINATION WHETHER THE PRODUCT WAS PRODUCED BY 

2012-08-244:North Korea:JW:000003

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)
.'.' 

.,.. / .. --'" 

Ms. Jodi Kouts 


May 31,2011 


(A) A FOREIGN PERSON WHOSE ACTIONS TRIGGERED IMPORT SANCTIONS UNDER SECTIONS 73 AND 74 OF THE ARMS EXPORT CONTROL 

ACT; 

(8) AN. ACTIVITY OF THE GOVERNMENT OF NORTH KOREA RELATING TO THE DEVELOPMENT OR PRODUCTION OF ANY MISSILE EQUIPMENT 

OR TECHNOLOGY; OR 

(e) AN ACTIVITY OF THE GOVERNMENT OF NORTH KOREA AFFECTING THE DEVELOPMENT OR PRODUCTION OF ELECTRONICS, SPACE 

SYSTEMS OR EQUIPMENT, AND MILITARY AIRCRAFT. 

Response 

'The chi'ldren's shoes are produced in North Korea pursuant to a contract .entered into 

between Rason IndustrialCompany and Yanji Sun Yang Shoe Company, an entity 

organized in China and owned by two U.S. citizens and

When SYC approached th~North Korean Industrial Department, orJ3ong Up Guk, in 

October of 2007 concerning its interest inmanufacturing shoes within North Korea, it 

was told that it would need to work with Rason Industrial Company ("RIC'). It is the 

understanding of Sun Yang and Barnabas that RIC is controlled by local North Korean 

authorities, apparently with some degree of oversight from Pyongyang, and that, in I 

addition to shoes, it also produces clothing and paper products such as boxes, . 

notebooks, and toilet paper. As'previously stated, RIC is located in the Rason Free 

Economic Trade Zone. 

The official with whom SYC and SY-DPRK has dealt in connection with the manufacture 

of the shoes is the head of the North Korean Industrial. Department and 

alsothe legal representative of RIC. 

Name checks using commercially available software have been undertaken with respect 

to Rason Industrial Company, and None were found to 

appear on various lists of sanctioned individuals, including OFAC's list of speCiaJly 

designated f!ationals. Additionally, Mr is an individual who BT has 

been working 'closely with. since the beginning of this enterprise and is personally known 

to the board and officers of Barnabas Fading Ltd. 

To the best knowledge of SYC, SY-DPRK and of Barnabas Trading Ltd., the children's 

shoethat are the subject of this importation request were not produced by: 

(1) A foreign person whose actions triggered import sanctions under sections 73 

and 74 of the Arms Export Control Act; , 

(2) An activity of the government of North Korea relating to the development or 

production of any missile equipment or technology; or 

(3) An activity of the government of North Korea affecting the development or 

production of electronics, space systems or equipment, and military aircraft. 

2012-08-244:North Korea:JW:000004

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)
Ms. Jodi Kouts 

MaV 31, 2011 

Conclusion 

As demonstrated by the inform~~ion furnished above, the importation by Barnabas Trading of 

die described children's shoes produced in North Korea would not be inconsistent with the 

p01icy concerns underlying 31 C.F.R. § 500.568{.b)(2). The children's shoes are simple, low-tech 

consumer goods that do not rela~e to missile equipment or technology or to the development 

0r production of electronics, space systems or equipment, or military aircraft. 

Barnabas respectfully requests that a decision on this request be taken promptly and that it be 

notified of OFAC's decision as soon as practicable. 

Thank you for your attention to this matter. 

Very truly yours, 

Counsel for Barnabas Trading Ltd. 


Enclosures: 


Tab A: 	Articles of incorporation of Barnabas Trading, as administratively filed with the 

Secretary of State 9f Colorado 

This submission contains commercial and fjnancial information regarding the business of the 

submitter that is confidential and:is therefore exempt from the public access provisions of the 

Freedom of Information at 5 USc. § 552. Such information, if disclosed, could adversely affect" 

the submitter's financial and competitive position and the normal conduct of business 

operati0ns. Accordingly, the submitter requests that this information be withheld in the event 

of a demand for disclosure and thpt,in the event of such a demand, OFAC give the submitter 

prompt notice and an opportunity to be heard prior to taking any action to disclose. 

-5­

2012-08-244:North Korea:JW:000005

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C) (b)(6) 
Colorado Secretary of State ". Date and Time: 04128/20 I I II: 12 AM 

Document must be filed electronically. 

Paper documents will not be accepted. 

Document processing fee $50.00 

Fees & forms/cover sheets Amount Paid: $50.00 are s4bjecf to change. 

To access other info'rmation or print 

. copies of filed documents, 


visit Www.SOs.state.co.us and 


select Business Center. 
 ABOVE SPAce fOR OfFICE'USE ONLY. 

Articles Of Organization 

filed pursuantto § 7.. 80~r03 and § 7·80 .. 204 of the Colorado Revised Statutes (C.R.S.) 

I 

t. The dOllJestjc entity narne of the 1 iinited liabi Ii!:)' company is 

. • Bar:qab.as, Trading l!.td. '!-' .~ ...' 

(The name ofa limited liability cumpany !n1lS1 contain Ihe term or abbreviation 

"limited liability company", "lid. liability company ", "limiled liabiliry co. ". "lid . .. liabiliry co, ". "limiled", "l.l.e. ", "lIe ", or ""d. ", See §7.90.601. CR.S) I 

(Caution: The lise ofcertain terms or akbreviations are restricted by law. Readinslructionsfor more information.) 

i . 2. The principal office address of the"imited liability company's initial principal office is 

',. , ...... /':.: . ':; 

Stteet address 167481tSfuOky Hill Rd., #107

\ .•.'i....•. r' .~.' "l."·!·.\:~.-J')tl' ""'::'r 

Mail iog address 


(leave blank ifsame as street address) 


" ..:::'. 


. ', 
 . (ZIPIPosral Co<Ie) 

. (Province:- ifapp/ieab,le) .' (Collnlry) 

. 3, The registered ~~.;!nt ri~me and registered" agent address ofthe limited liability cO~Pimy's iilitia/'registered 

agent are'" . .. ...' :...."~ : . 

Name 


. (ifan individual) 


OR 

. ~{ifa!l,e~tjiy) ';:. '··t ."'.. ,,::"., _B,-a_r-:;-na_b_a_:s,-·:T_··'_ra_d_·jn....:"9:....··_L_td_·;_"··_·_'_""__ \_"_'_;"_,,,-_ ..:,_..._..; ____

/Cautiolf: Do not provide both an individual alld an entity name.) 

Street address 

,t ~ :.! , 

...', . 

,\/ " \:':'.' 

2012-08-244:North Korea:JW:000006

(b)(4) (b)(4) 
Mailing address 

(leave blank ifsame as s!reet addre~s) Box 

\. 

CO 

(State) '. 

/I!!..efollowing statement is adopted by marking the box.} 	 . 

l{J The person appointed as regis'!ered age!,!! has consented to being so appointed.. 

4. The true name and mailing address of the person forming the limited liability company are 

Name 


(if an individual) 


(Middle) 

OR 

(if an entity) (Caution: Do nO( provide both an i~d'ivi,1u-;..~';d-;;;;e;',;itv~;;eT----------:-_-C..._-----"'-

16748 E. Smoky Hill Rd., #107 Mailing address 

(S:reet nllmber and nilme or Posl.Qffice Box informalion) 

Centennial 	 CO B0015 

(Stale) (ZIPIPoslQ/ Code) 

United States . '. 

. (Province - ifapplir:able) (CO/Jfury) 


(Ifthe following staleme~l ppplies. adopt the stotement by marking lhe box a~d include an al/achme';t.) 


o The limited liability compa!ny has on~ or more additi'onal persons foooing the limited liability 

company and the name \ln~ mailing address of each such person are stated in an attachment. 

5. The management of the limited liability company is vested in 

(Mark Ihe applicable box.) . 

D one or more managers. 

OR 

[{] the members. 

6. (T1.e follOWing slUlement is adopted by marking the box.) 

III There is at least one member of the limited liability company. 

7. (Ifthe fallowing stOl€meni app/i.s. adoplthe stolement by marking lire box and include an attachment.) 

D This document contains additional' information as provided by law. 

8. 	(Caution: ·Leove bionic if/he docu.I1Ient does not have a delaye'd effecfive date. Sla/ing a delayed effective date has 

significant legal consequences. Read ins/ructiolls before entering a date.) 

(If Ihe folfowing statement ~pplies. adopt the staiement by entering a dale and. ifapplicable. lime /ISing Ihe required/ormal') 


The delayed effective date and, if.applicable, time of this document is/are _--;--:-:-:-;-_;--~:--_--:--:-_ 

(mm/ddlyyyy haur.:minlJl€ am/pm) 

Page 2 on 	 Rev. 0112812008 

...' .­

2012-08-244:North Korea:JW:000007
'. 

Notice: 

Causing this document to be d'elivered to the Secretary of State for filing shall constitute the affinnation or 

acknowledgment of each individual ¢ausing such delivery, under penalties of perjury, that the document is the 

individual's act and deed, or that the individual in good faith believes the document is the act ana deed of the 

person on whose behalf the individual is causing the document to be delivered for filing, taken in conformity 

with the requirements of part 3 of article 90 of title 7, C.R.S., the constituent documents, and the organic 

statutes, and that the individual in good faith believes the facts stated in the document are true and the 

document complies with the require~ents of that Part, the constituent documents, and the organic statutes. 

This 'perjury notice applies to each individual who causes this document to be delivered to the Secretary of. 

State, whether or not such individuaf is named in the document as one who has caused it to be delivered. • , t 

9. The trLie name and mailing addres~ of the individual causing the document to be delivered for filing are 

--~~------~=-~----~~~- (Lnsf).. (First) (Afiddle) (SlIff~) . 

16748 E. Smoky Hill Rd., #107 . 

. (Streef"nllmber and name or Post Office 80x information) 

Centennial CO 80015 

(Province ­ ifapplicable) 

(S/aIe) 

United States 

(Country) 

. . (If/he/allowing statement applies, adopt/he statement. by marking the box and include an al/achme,,/.) 

o This document contai~s'the t~ue name and mailing address of one or ~ore additional individuals 

causing the document tobe ~elivered for filing. . 

Disclaimer:. 

T.his form/cover sheet, and any related instructions, are not intended to provide legal. business or tax advice. 

and are furnished without representation or warranty. While this fonn/cover sheet is believed to satisfy 

minimum legal requirements as of it$ revision date, compliance with applicable law, as the same may be 

amended from time to time, remains the responsibility of the user ofthis form/cover s~eet. Questions should 

be addressed to the user's fegal, business or tax advisor(s). 

Page 3 of. 3 Rev. 0212812008 

"', . "', :,.;,:' '. 

2012-08-244:North Korea:JW:000008
Carbon Development 

and Trading Ltd. 

Kemp House, SUite 520 

152-160 City Road 

London, EC1V 2NX 

United Kingdom 

Tel. +44 207 125 0385 

Email: Info@carbon-development com 

Office of Foreign Assets Control 

U S Department of the Treasury 

Treasury Annex 

1500 Pennsylvania Avenue, NW 

Washmgton , DC 20220 

Attn. Llcensmg DIvIsion 

25 January 2012 

General License Application for Trading of Certified Emission Reduction Credits originating 

from North Korea 

Dear Sir or Madam, 

In accordance with the document Issued by the Office of Foreign Assets Control (OFAC) tl,tled 

"North Korea An overview ofSanctIOns WIth Respect to North Korea" dated May 6,2011, a US 

Person pursuant to E.O 13570 IS prohibited from Importmg goods, servIces and technology from 

North Korea into the Umted States, dIrectly or indirectly, without a hcense from OF AC 

In 1992, countnesJoined an international treaty, the United Nations Framework ConventIOn on 

Climate Change (UNFCCC), to cooperatIvely consIder how they could hmlt average global 

temperature mcreases and the resulting climate change, as well as to cope WIth the impacts of climate 

change The Umted States of Amenca IS a sIgnatory to tillS treaty . 

On 11 December 1997, the Kyoto Protocol was adopted in Kyoto, Japan. The Kyoto Protocol is an 

internatIOnal agreement linked to the Umted NatIOns Framework Convention on Climate Change, 

binding 37 industrIalized countnes and the European CommunIty for redUCing greenhouse gas 

emiSSIons 

Under the Kyoto Mechamsms, the Clean Development Mechanism (CDM) was created In order to 

allow emIssIon-reduction projects (CDM ProJects) 10 developing countnes to earn certIfied emIssIon 

reduction (CER) credIts, each equivalent to one tonne of C02 These CERs can be traded and sold, 

and used by Industriahzed countnes to a meet a part oftheIr emISSIOn reduction targets under the 

Kyoto Protocol. 

Benefits ofCDM Projects Include Investment in climate change mItigation projects in developing • countries, transfer or dIffUSIOn oftechnology In the host countnes, as well as improvement 10 the 

livelihood of commumtles through the creatIOn of employment or Increased economIc actIvity 

More infonnatlOn about the Kyoto Protocol, CDM and CERs can be found on www unfccc int 

CERs are issued and traded In electronic fonnat uSing the CDM RegIStry, which is operated by the 

UNFCCC ' 

Registered office: Kemp House, Suite 520, 152-160 City Road, London, EC1V 2NX, Umted Kingdom 

Registration Number. 07772243 

2012-08-244:North Korea:JW:000009
< 


...,r-" ---

Carbon Development Kemp House, SUite 520 

152-160 City Road 

and Trading Ltd. london, EC1V 2NX

United Kingdom 

o. Tel. +44 207 125 0385 

Email mfo@carbon-development com 

, I would like to pomt out that all CERs are Issued by the COM ExecutIve Board and that COM 

Projects are validated and CERs venfied by mdependent DeSignated OperatIOnal Entities 

As the Umted States of Amenca has not ratified the Kyoto Protocol, It IS not currently possible to 

transfer CERs into the Umted States phYSically, whether directly or mdirectly While It is not possible 

to transfer· CERs to the United States, It IS possible for US entities, such as banks or trading houses, to 

open a registry account (Carbon Account) m a country that IS a Party to the Kyoto Protocol, such as 

Switzerland, the Netherlands or the Umted Kmgdom Consequently, It IS possible for a US entity to 

receive CERs mto such a Catbon Account 

As the Democratic People's Republic of Korea (DPRK) has Signed and ratified the Kyoto Protocol, It 

is entitled to participate ill the Kyoto Mechamsms, which allows them, as a developmg country, to 

host COM Projects that can earn CERs· . 

us entitles havmg opened a Carbon Account have the possibility to purchase or sell CERs that 

originate from a CDM Project located In the DPRK In order to ensure that US entities, Includmg 

banks, trading houses, individuals, companies, and regulated exchanges, do not VIOlate the sanctIOns 

currently m force in relatIOn to the OPRK, I would be grateful if you could either' . 

a) confinn that the purchase and sale and clearing of CERs by US entities, mcluding banks, 

tradmg houses, mdlvlduals, companIes, and regulated exchanges, IS not a violation of the 

sanctions currently m place, or 

b) Issue a general license for US entities, including banks, trading houses, mdivlduals, 

compames, and regulated exchanges, engaged m the tradmg and cleanng of CERs to both 

purchase and sell, as well as clear, CERs from COM Projects located m the OPRK 

I thank you for your efforts and look forward to recelvmg your response Please do not hesItate to 


contact me should you reqUire more mfonnatlOn. 


Kmd regards, 

For and on behalf of Carbon Tradmg and Development Ltd 

Director . 

Registered office: Kemp House, SUite 520, 152-160 City Road, london, EC1V 2NX, United Kingdom 

Registration Number: 07772243 

2012-08-244:North Korea:JW:000010

(b)(6) & (b)(7)(C)
VIA OVERNIGHT MAIL 

Office of Foreign Asset Controls 

Licensing Division - North Korea UOit 

U.S. Department of the Treasury 


1500 Pennsylvania Avenue, N.W. 


Annex 


,Washington, D.C. 20220 

'September 22, 2010 

Re; Permission Request to Import {rem North Korea. 

To Whom It May Concern: 

In accordance with the Foreign Asset Controls Regulations against North Korea, CMC 

'Cometals, a division of Commercial Metals Company ("CMC") is requesting permissiQn to import 

from North Korea to the U.S. CMe's contact information is: 

6565 N. MacArthur I3lvd. 

Suite 800 

Irving, TX 75039 

Tel.: 

Fax: 214-689-4326 

E-mail;

\YIc wish to import no more than for use in the 

manufacture of proppants used in the oil and gas industry. The price is between per 

metric ton CIF New Orleans. There are two producers and two exporters that we will use in this 

transaction. Their names and addresses are as follows: 

1. . Kaeson-shi, 

P'yongan~naindo, North Korea. 

, 

Pyongyang wanjiang 2-dong Jiang, North 

Korea. 

2. 

T'aech'on-gun, Pyeongbuk, North Korea. 

Letter [0 OFAC - Page 1 of2 

September 22, 2010 

P.O. Box 1046 6565 N. MacArthur Blvd. Phone 214.689.4300 www.cmc.com 

Dallas, TX 75221-1046 Suite 800 Fax 214.689.5886 

Irving, TX 75039 

2012-08-244:North Korea:JW:000011

(b)(6) (b)(6) & (b)(7)(C) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) 
Exporter: Pyongyang Datongjiang dongmen 1­

dong, North Korea

There is a Chinese firm that has invested in both Of the producers listed above. 

has invested in new equipment for the producers and is responsible for our business 

discussions. They are setting up a new company named 

who will be the contract party for future mports. 

We will not use any firm, individual, or vessel that violates the U.S. sanctions against North 

Korea. We have no information relevant to the determination of whether the produc't was produced 

by any of the parties or activities described in 31 CFR 500.586(b)(2)(i). Please provide us with the 

necessary permission. to import the If you have any questions, or if you heed any 

additional infonnation, do not hesitate to contact me ... Thank you for your consideration. 

Sincerely, 

Senior Counsel 

Corporate and Compliance 

Letter to OFAC - Page 2of2 

September 22, 2010 

2012-08-244:North Korea:JW:000012

(b)(6) & (b)(7)(C)

(b)(6) (b)(6) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) 
. .~ 

1001 Pennsylllllnia Avenue. NW. Washington. DC 20004-2595 • p 202 624-2500 • f 202 628-5116 


crowellrClmoring August 30, 2011 

Via Federal Express and Facsimile 

Office of Foreign Assets Control' 

U.S. Department of the Treasury 


Treasury Annex 


1500 Pennsylvania A venue, N W 


Washington, DC 20220 ' 


Attn: Licensing Division 

Dear Assistant Director Gacki: 

This firm represents the EugeneBell Foundation ("The Foundation,,)l and on its behalf 

we seek authorization to import non-commercial medical samples from North Korea as part of 

the FO\:lndation's efforts to address Multiple-Drug Resistant Tuberculosis ("MDR-TB") among 

citizens in North Korea. The Foundation needs to have sputum samples imported for testing as 

part of the diagnosis and treatment process. 

, The Foundation seeks this authorization, and authorization for any transaction incident to 

thi's ,authorization (such as that for transportation, brokerage services, and other related 

transactions) pursuant to Executive Order ("E.O.") No. 13570. This Executive Order prohibits 

the "importation into the United States, directly or indirectly, of any goods, services, or 

technology from North Korea." Accordingly, to be sure that the Foundation can continue to 

provide MDR-TB medications in North Korea and can undertake the use of labs in the United 

States, it seeks either confirmation that its proposed activities are not prohibited by the Executive 

Ordef or authorization for such activities in the form of a license. 

Background 

The EugeneBell Foundation is the parent foundation for two humanitarian organizations. 

oundeq EugeneBell U.S., a U.S. 501(c)(3), in 1995 and EugeneBellKorea, 

a sister organization serving as a medical not-for-profit and registered in the Republic of South 

Korea, in 2000. The Fou~dation is named after Rev. Eugene Bell, a Presbyterian missionary in 

Korea in the late 1800s and early 1900s. 

Tuberculosis affects as much as 5 percent of the North Korean population and, aside from 

starvation, is one of the Jeading causes 0f death in the country. Sipce 1997, the Foundation has 

, focused on providing tuberculosis treatment for the citizens ofNorth Korea. Basic tuberculosis 

,treatment using the Directly Observed TreatmentSystem ("DOTS") usually takes between six . . 

I' More information is available on the Foundation at http://www.eugenebeILorg/eng/. 

This leiter cOlltaim cOl/fidel/tial busillessilijormatioll volulltarily provided to 

tile Office of Foreign As~·et~· COlltrol and protectedfrom disclosure 

Crowell & Moring LLP • www.crowell.com • washin~{g~~~/ ~ We~·f6r~ 19~~ ~i!«jsM'~' ctbPiJ~~ (iJ"Orange County • Anchorage • London • Brussels 

2012-08-244:North Korea:JW:000013

(b)(6) & (b)(7)(C)
August 30, 2011 

"

. Page 2 . 

and eight months and costs between $20 and $40 per person. The Foundation's work in this area 

was so successful, that in2005, the North Korean Ministry of Public Health asked the 

Foundation to expand its work to provide some TB support. for North Korea's public hospitals. 

By the end ·of that year, the Foundation was coordinating the delivery of TB medicatio'n to an 

area which included one third of the North Korean population and over forty North Korean 

hospitals and care centers. Since its estabJisbJ:nent, the foundation has provided basic TB 

treatment to over 2.50,000 North Korean citizens: 

In 2007, a group ofNorth Korean doctors and care givers working at the long-term care 

centers approached to complain that many of their patients were not responding to the 

DOTS treatment. They asked if and EugeneBell would be ~illing to begin treating 

multiple-drug resistant tuberculosis ("MDR-TB"). The World Health Organization ("WHO") 

had also recently moved into North Korea to begin providing basic TB treatment. Realizing that 

North Koreans now had an optioh for basic TB treatment but still had no providers of MDR-TB 

~edication, shifted the Foundation's focus in late 2007 to providing MDR-TB 

medication . 

. MDR'::TB is a rapidly expanding problem in North Korea. As basic TB medication' 

becomes more widely available, the problem of MDR-TB comes increasingly to the fore. 

Patients who receive TB medication but who fail to rigorously abide by the regime further 

catalyze the natural development of drug-resistant TB strains .. 

No reliable data exists confirming the exact extent of the epidemic but North Korean 

health authorities list tuberculosis as North Korea's most serious health challenge. After decades 

of Soviet-style treatment, many patients have developed resistant strains of tuberc~losis that 

cannot be treated with regular tuberculosis medications. To make matters worse, second-line 

drugs are now available through China and Russia outside the medical system. Because 

tuberculosis bacilli are quick to develop additional resistance when treated improperly, North 

Korea.is noW facing an explosion of multi-drug resistant tuberculosis. EugeneBell's MDR-TB 

program is the only one available in North Korea.2 

The principal impediment to MDR-TB treatment is cost. According to the WHO, MDRTB drugs cost an average of $5,000 per treatment cycle, 250 times more than the average $20 

cost fodirst-line non-drug resistant TB medication.3 Nevertheless, despite the extra expense, 

established a pilot program of 19 patients in 2007. 

MDR-TB treatment requires a multi-step process. First, doctors from the Foundation 

must travel to North Korea and take sputum tests from the patients. Those samples must then be 

exported (no lab in North Korea is capabJe of testing and analyzing the samples). Based on the 

results of those tests, the Foundation then tailors a course of treatment for the patient The entire 

treatment process takes 2.5 years. 

2 SeeJ?:xhibit A, Executive Sutri~ary or'EugeneBell's MDR~TB Program. 

3 http;//www.cgdev.org/contentJgeneralldetaiIl1423993/. 

This leller COJllains cqlljidelllial business information voluntarily provided to 

" "tile Office of Foreign Assets COl/trol alld protectedfrom disclosure 

under i8 V.S.c. § 1905 and 5 V.S.c. §551(b)(4). 

Crowell & Moring llP • www.crowell.com • Washington, DC • New York • S~n Francisco • Los Angeles • Ora~ge County -' Anchorage • London • Brussels 

2012-08-244:North Korea:JW:000014
August 30, 2011 


.:. P{lge 3 


Despite the cost and time constr~iilts, the Foundation has seen its pilot grow from 

in the last three years. At the Foundation's suggestion, the Ministry of Public 

Health has converted six regular TB centers into MDR-TB treatment centers. These patients are 

objectively identified. 

Those tests must be submitted to a laboratory for analysis, and 

only those patients who are ,confirmed by the laboratory as suffering from MDR-TB, begin to 

receive treatment. ' 

Once the MDR-TB diagnosis has been confirmed by the labonitory, the patients receive 

an MDR-TB medication regimen. These medications are brought into the country by the 

Foundation's staff during their biannual visits. 

The medication is then 

dispersed by local North Korean health officials directly to the identified patient at the MDR-TB, 

center. The'Foundation only operates through

arid are scattered throughout the northwest part of North Korea. 

The Foundation rigorously controls the medications it brings into the country. To control 

its medications in rural North Korea, the Foundation relies upon both its doctor who travels witl} 

the team anq. regular photographs it takes of its patients. 

>,' MDR-TB treatmen~ is therefore solely reliant on the initial diagnostic tests which can not 

only identify whether an individualhasMDR-TB, bilt to which drugs they are resistant. The' 

;" Foungation staff therefore collects sputum samples from potential patients during the staff's. 

biannual visits. Traditionally, the Foundation has had its sputum samples tested in South Korea. 

Sputum samples are 'only medically useful Jor a limited period: Relying on the proximity of the 

South Korean lab therefore, ensured that the' highest percentage of the ,sample remained viable for 

testing. 

EugeneBell traditionally has good access to South Korean labs and plans to continue 

having samples tested and purchasingMDR-TB medications in South Korea . 

. As the program has grown,

However, the recent Executive Order's blanket import ban 

4. See Exhibit B, Email from Desk Officer fodhe U,S. State Department's 

Office of Korean Affairs'- DPRKUnit, conveying the Treasury Department's Office of Foreign 

Assets·Control's determination that a license was not necessary. 

This letter cOl/taills cOlljidefllial busilless in/ormatio,1I volulltarily provided to 


tile Office ofForeig" Assets O;J11lrol alld protected from disclosure 


IIl1der'IS V.S.C§ 1905 and 5 V.S.c. §552(b)(4). 


Crowell & Moring LLP " www.croweLL.com " WaShington, DC II New'York II San Francisco II Los Angeles II Orange County II Anchorage II London II Brussels 

2012-08-244:North Korea:JW:000015

(b)(6) & (b)(7)(C) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4)

(b)(4)

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, : ....,.; 

August 30, 2011 

,Page 4 ' .. . 

would prevent this activIty without a license. Therefore, the Foundation seeks authorization to 

similarly import sputum samples in the future, as needed. 

In general, the Foundation needs authorization for the import of approximately

sputum samples from North Korea. 


Specific Request for Authorization 

The Foundation seeks authorization to engage in the import and testing of up to 

sputum samples from MOR-TB patients as described above from North Korea to the United 

States, as well as all activities incidentthereto, including the transfer back to medical 

professionals administering the course of treatment in North Korea of information generated by 

the laboratories in the United States. These samples would be imported, immediately following 

the Foundatien's representatives (eturn from their trips to North Korea. The Foundation's 

doctors minimizing any 

opportunity for tampering. Further, no payment is made to North Korea, or to any North Korean 

officials, for the taking or export of these samples. They are used solely for the development of 

.individualized treatment regimens for each North Korean MDR-TB patient. " 

If you have any questions about this application, please contact at

or at

Crowell & Moring, LLP 

1001 Pennsylvania Ave, N.W. 

Washington, D.C. 20004 

Counsel to EugeneBeli 

Foundation 

cc: Chairman EugeneBell 

This leller cOlltaillsCOllfidel1tial busilless ill/ormatioll voluntarily provided 1o 


tile Office 0/ Foreigll Assets COlltrol and protected/rom disclosure 


Ullder 18 U.S.c. § 1905 ami 5 U.S.c. §552(b)(4). 
 . .' . 

Crowell & Moring UP • www.croweU.com • Washington, DC • New York 8 San Frandsco • Los Angeles _ Orange County _ Anchorage _ London _ Brussels 

2012-08-244:North Korea:JW:000016

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Sep 08 2010 6:27PM HP LASERJET FAX page 1 

(!) 


EugeneBell 


FOUNDATION 

North Korea Unit 

Office of Foreign Assets Control 

U.S. Department of the Treasury 

1500 Pennsylvania Avenue, NW, Annex 

Washington, DC 20220 

Tel (202) 622-2500, (202) 622-2480 

F~ (202) 622-1657 

Tuesday, September 7, 2010 

Re: Urgent request for import review and'ietter regarding items of North Korean origin 

The is the combination of two non-profit organizations, one 

located in the Republic of Korea (ROK or South Korea) and one in the United States. 

For the past fifteen years, we have been working in the Democra1ic People's Republic of 

Korea (DPRK or North Korea) as a humanitarian aid organization, delivering vital 

medications to tuberculosis patients in North Korea. 

This year, we would like to try to test our specimens using a lab in the United States, 

instead of in South Korea. We were told that this was an import that would require a 

letter from OFAC, so we are submitting our written answers to your questions on the 

following page. 

As our request for a letter is urgent, 

and need to start shipping the speCimens as soon as 

possible. We hope you will contact us if we can help you in any way. Our website is 

and you can find much information about our work there. 

Thank youl 

Best regards, 

2012-08-244:North Korea:JW:000017

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The name and address of the location of where the product was produced: North 

Pyongan Province MDR Center, South Pyongan Province MDR Center, Nampo City 

MDR Center. Pyongyang City MDR Center 

The name and address of the North Korean exporter: Same as above 

Whether the products to be imported were produced by 

(a) A foreign person designated by the SecretarY of State as having engaged in 

missile technology proliferation activities; 

a. No, all the specimens are produced by MDR-TB tuberculosis patients, 

. usually isolated from the population in TB sanitaria in North Korea. 

(b) an activity of the North Korean Government relating to the development or 

production of any missile equipment or technology, or 

a. 	 No, the specimens are produced by patients and supplied to us with the 

help of the North Korean Ministry of Public Health. 

(p) An activity of the North Korean Government affecting the development or 

production of electronics, space systems or equipment, and military aircraft 

a. 	 No, the specimens are produced by patients and supplied to us with the 

help of the North Korean Ministry of Health. 

Answers provided in response to: 

BUYING FROM NORTH KOREA - Goods of North Korean origin may not be Imported Into the United 

States either directly or 1I1rougll tl1ird countries. witl'lout prior notification to and approval at the 0ff1ce of 

Foreign Aaaats Control. Imponera must provide OFAC with written information as to whether lhe 

products to be imported were prodlJC9d by (8) a foreign person designated by the Secretary of State as 

having engaged in missile technology proliferation activities; (b) an activity ot the North Korean Government 

relating to the develOpment or production of any missile equipment or technology; or (c) an activity of the 

North Korean Government affecting the development or pl'!)duction ot electronics, apace systems or 

eqUipment, and military aircraft. In addition to the infonnalion just described, importers seeking an approval 

letter from OFAC must provide lIlalr name, address, telephone. fax, and a-mail addresses; a description of 

the product to be imported, including quantity and 0081; the name and address of the producer of the 

product; the name of 1I1e location Ylhere the product was produood: and the name and address of the North 

Korean exporter. Requests for if1l,)ort review must be submitted by mall to North Korea Unit. OffIce of 

Foreign Assets Control. U.S. Department of the Treasury, 1500 Pennsylvania Ava., NW. Annex, Washington, 

DC 20220. After reviewing the InfOlTl'lation, OF.A.C will issu& I!I letter indicating the results of the review to the 

person seeking to import the product. U.S. depository institutions handling letters or oredit or documentary 

collections Involving Imponsfrom North Korea must oblaln a copy of OFAC's appl'OY81 letterrrom the 

importer before proceeding with such tran8actlons. The letter muat also be provided to the U.S. Customs 

Service before Imports from North Korea will be allowed Into the United States. 

2 

2012-08-244:North Korea:JW:000018

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Hogan


. Lovells 


Hogan Lovells US LLP 

Columbia Square 

555 Thirteenth Street, NW 

Washington, DC 20004 

T +1 2026375600 

F +12026375910 

www.hoganlovells.com 

July 25, 2011 

Confidential- FOIA Exempt· 

BY HAND DELIVERY 

Mr. Adam Szubin, Director 

Office of Foreign Assets Control 

U.S. Department of Treasury 

Treasury Annex 

1500 Pennsylvania Avenue, N.W. 

Washington, D.C. 20220 

Attn: Licensing Division 

Re: 	 Requestfor License to Import Services from North Korea in Order to Protect 

Intellectual Property 

Dear Mr. Szubin: 

Hogan Lovells requests that the Office of Foreign Assets Control ("OFAC") issue a license, to 

the extent required, in order to provide legal services to our clients in connection with protection of 

intellectual property in North Korea. We request that the Ii'cense be issued to Hogan Lovells as 

described in Section I below. 

I. 	 Description of Hogan Lovells 

"Hogan Lovells" refers to the international legal practice comprising Hogan Lovells 

International LLP, Hogan Lovells US LLP, Hogan Lovells Worldwide Group (a Swiss Verein), 

and their affiliated businesses, each of which is a separate legal entity. Hogan Lovells 

International LLP is a limited liability partnership registered in England and Wales with 

registered number OC323639. Registered office and principal place of business: Atlantic 

House, Holborn Viaduct, London EC1A 2FG. Hogan Lovells US LLP is a limited liability 

partnership registered in the District of CoI,umbia. Their addresses are as follows: 

Hogan Lovell US LLP 


Columbia Square 


555 Thirteenth Street, NW 


Washington, DC 20004 


Hogan Lovells International LLP 


Atlantic House 


Holborn Viaduct 


London, EC1A 2FG 


United Kingdom 


, "DC • O~03341000551 . 3258855 v2 

2012-08-244:North Korea:JW:000019
II. Description of Services to be Provided 

Protecting copyrights, patent.s, trademarks and domain names is a core business interest of 

global companies and clients of Hogan Lovells. The firm provides legal advice to clients on the full 

range of inteUectual property issues. 

In order to register, renew, maintain, and protect from infringement copyrights, patents, 

trademarks, and domain names of clients in North Korea, Hogan Lovells must, in some instances, 

retain local agents and/or counsel to provide services incidental to such activities. Examples of 

activities local agents and counsel would perform include the payment of filing fees and the 

preparation of certain required local documentation. Our U.S. and global clients wish to maintain 

their intellectual property protection in all countries including, as needed, sanctioned countries such 

as North Korea. 

III. Legal Analysis 

Executive Order 13570 of April 18,2011 states that, "the importation into the United States. 

directly or indirectly, of any ... services ... from North Korea is prohibited." Moreover, the NKSR do 

not currently address the protection of intellectual property in North Korea. In light of the breadth of 

the language in the executive order, we request authorization to the extent required to engage in 

legal matters involving the protection of intellectual property, including, but not limited to engaging 

and paying local agents and counsel in North Korea for services to register, renew, maintain, and 

protect from infringement copyrights, patents, trademarks, and domain names. 

OFAC should issue a license to Hogan Lovells to engage local agents and counsel in North 

Korea to allow for the protection of clients' intellectual property in North Korea in line with the general 

licenses issued in other sanctions programs permitting transactions relating to intellectual property 

protection. See the Burmese Sanctions Regulations (BSR) (31 CFR § 537.522), the Iranian 

Transaction Regulations CITR") (31 CFR § 560.509), and the Sudanese Sanction Regulations 

("SSR") (31 CFR § 538.514). 

The general license in the ITR, 31 CFR § 560.509 "Certain transactions related to patents, 

trademarks and copyrights authorized," provides that: 

(a) All of the following transactions in connection with patent, trademark, copyright or other 

intellectual property protection in the United States or Iran are authorized: . 

(1) The filing and prosecution of any application to obtain a patent, trademark, copyright 

or other form .of intellectual property protection. including importation of or dealing in 

Iranian-origin services, payment for such services, and payment to persons in Iran 

directly connected to such intellectual property protection; 

(2) The .receipt of a patent, trademark, copyright or other form of intellectual property 

protection; 

(3) The renewal or maintenance of a patent, trademark, copyright'or other form of 

intellectual property protection; and 

(4) The filing and prosecution of opposition or infringement proceedings with respect to a 

patent, trademark, copyright or other form of intellectual property protection, or the' 

.entrance of a defense to any such proceedings. 

"'DC· 090334100055 J • 3258855 v2 

2012-08-244:North Korea:JW:000020
- 3 ­

With respect to domain names, OFAC darified in the cover letter to License MUL-314 (see 

attached), issued to Hogan Lovells on April 30, 2010, that domain names composed of existing 

trademarks a're "other forms of intellectual property" for purposes of the ITR and SSR. Specifically, 

OFAC stated that. "To the extent that domain names are composed of existing trademarks, such 

domain names are considered 'other intellectual property' pursuant to section 560.509 of the ITR 

and section 538.514 of the SSR. Accordingly, transactions in connection with the registration aod 

renewal of such domain names are authorized pursuant to those general licenses." As such, OFAC 

should authorize transactions relating to the registration, renewal, maintenance. and protection from 

infringement of domain names to the same extent as copyrights, patents, and trademarks. 

We are not aware of a policy reason to prohibit companies from fully protecting their 

intellectual property in North Korea while at the same time permitting them to protect their intellectual 

property in Iran and Sudan. As such, OFAC should take the view that the rationale for protecting 

intellectual property from infringement in Iran, Sudan, Burma, and Cuba applies equally in North 

Korea. . 

IV. . Request 

We respectfully request that OFAC grant authorization to Hogan L0vells to provide legal 

services to our ciients in connection with the protection of intellectual property in North Korea akin to 

the Qen~rallicense in the ITR, as further clarified by OFAC: 

Certain transactions related to patents, trademarks and copyrights authorized with respect to 

North Korea: All of the following transactions in connection with pa~ent, trademark. copyright 

or other intellectoal property protection in the United States or North Korea are authorized: 

(1) The filing and prosecution of any application to obtain a patent. trademark. copyright 

or other form of intellectual property protection, including importation of or dealing in 

North Korean-origin services, payment for such services, and payment to persons in 

North Korea directly connected to such intellectual property protection; 

(2) The receipt of a patent, trademark, copyright or other form of intellectual property 

protection; . 

(3) The renewal or maintenance of a patent. trademark. copyright or other form of 

intellectual property protection; and 

(4) The filing and prosecution of opposition or infringement pro~eedings with respect to a 

patent, trademark, copyright or other form of intellectual prrJperty protection, or the 

entrance of a defense to any such proceedings. 

Enclosed is the following: 

1. Copies of the April 30, 2010 letter from OFAC and license MUL-314. 

* * * 

\ \ \DC . 090334/000551 ·3258855 v2 

2012-08-244:North Korea:JW:000021
, - 4­

Thank you in advance for your response to this request Please contact the undersigned if 

there are any questions regarding this license application, 

Respectfully submitted, 

HOGAN LOVELLS 

(202) 637-5740 

(202j 637-5837 

\ \ \DC 090334/00055l - 3258855 v2 

2012-08-244:North Korea:JW:000022

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UNITED ST A TJ::S DEPARTMENT OF THE TREASURY 

OFFIC'E OF FOREIGN ASSETS CONTROL 

REPORT OF BLOCKED TRANSACTIONS 

INSTITUTION INFORMATION 

INSTITUTION TYPE PF INSTITUTION ADDRESS 

!ktWDI'K. service. Cer"dre., 

HsBC BANk P""j'rt'ent 51U. 8ft • Tovsel';L 

H.se. c Ce'ltlC:. i .$b,..... t\oVl~ ~"" 

CITY STATE CONTACT PERSON TELEPHONE NUMBER 

kow \00" 

POSTAL CODE COUNTRY E-MAIL ADDRESS FAX NUMBER 

4? lo -sttf H'~ 

TRANSACTION INFORMATION 

AMOUNT BLOCKED DATE OF TRANSACTION DATE OF BLOCKING PROGRAM OR REASON 

FOR BLOCKING FUNDS 

$, SEP. )'0/0 22. . NOV.. :2Q/{J OFAC IiCet1s'il\3. 

ORIGINATOR NAME & ADDRESS ORIGINATING FINANCIAL INSTITUTION NAME & 

C\TICHANP rN1EI2-NftTloN~l CO,) LTD, ADDRESS 

I t...tN11 .u.o~ }:ll/Fi , (o.qse.w~ 8o..yP~2~ ~~,~()~ Htc:6tA~ Il'\teho.n, BLDC!l. 1>:'1-1 

Z I Locl<.ho.ri ~o.d H.",!t I<or) 'i k:wo.nyo.'lI- o..f)B' AII'I~"!:l-..sh' I k)'\l~~ I" Pc , l<..o\2r::A : 

INTERMEDIARY FINANCIAL INSTlTUTlON(S) NAME & BENEFICIARY FINANCIAL INSTITUTION NAME & 

ADDRESS ADDRESS 

BE!'IEFICIARY NAME & ADDRESS ADDITIONAL RELEVANT INFORMATION (USE PAGE 2 

IF MORE SPACE IS NEEDED) 

ADDITIONAL DATA FOUND IN ORIGINATOR TO BENEFICIARY INFORMATION OR BANK TO BANK 

INFORMAliON 

'. 

PLEASE ATTACH A COpy OF PAYMENT INSTRUCTIONS AS PAGE 3 OF THIS FORM 

PREPARER INFORMATION 

SIGNATURE NAME OF SIGNER TITLE OF SIGNER DATE PREPARED 

CEO :tl . :::lfVJ ' 201 \ 

t

V 

2012-08-244:North Korea:JW:000023

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IORIGINAL 1 


ADDITIONAL INFORMATION 


(PLEA'SE INCLUDE PAYMENT INSTRUCTIONS AS A SEPARATE ATTACHMENT TO THIS DOCUMENT) 


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2012-08-244:North Korea:JW:000024

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(b)(6) & (b)(7)(C)

(b)(6) 
PRGE 4;/S 

Advice sending date: 

Advice reference no: 

Payment Advice Page: 	 1/1 

HSBCID 

ceo@citichamp.net 


Transaction type: 	 Remittance 

Beneficiary's name: 	

Beneficiary's bank: 	 OVERSEA-CHINESE ·BANKING CORP LTD 

SINGAPORE 

SINGAPORE 

SINGAPORE 

Beneficiary's account:

(Part of the account number is shown 

as ••••• for security reasons.) 

TT reference number: 

Message from remitter: 

<No details are provided> 

Debit amount: 

Remit tance amount: 

Local and overseas Remitting bank charges are collected 

charges: from Remitter. Beneficiary pays 

Beneficiary bank charges 

Value date: 25 Sep 2010 

Remitter's name: CITICHAMP INTERNATIONAL COMPANY 

Remitting bank: The Hongkong and Shanghai Banking 

Corporation Limited 

Ins'truction reference: 

Important not"es i 

This Advice is issued 'at the request of our customer. It purports to set out ct:rtain dt:tails of the transaction that Qur Bank ¥las in6tructed 

to effect. This is NOT a cpnfirmation that the transaction has been Of \4'i11 be effected. You should conduct. your attn verification and 

confirmation regarding the information Get out in this Advice inclUding, ....ithout limitation, the status of the tra!",saction menti(;lned tn it. 

This Advice is for your reference only and is not to be relied upon by you or any on~ for any purpuse. We have not verified the content of 

this Advice and bear no responsibility therefor. Where this Advice is sent by facsimile or over the internet, you should take note that 

communication by facsimile or over the internet may be interrupted, delayed or fail. In particular, e-mail messages· sent via the internet 

cannot be guaranteed to be secllre I error or virus-free as information could he intercepted) corrupted I lost, arrive late or cuntain viruses. 

The Bank shall bear no liability whatsoever for any direct, i.ndirect or consequential loss ar~sing out of this Advice being sent by facsimile 

or over the internet whether caused by the Bank or other third parties. The information contained in this Advice is confidential. It may also 

be legally privileged. If you arc not the add ressee you may not copy forward! disclose or use any part of it. 

ISsued by The Hongkong and' Shanghai Banking Corporation Limited 

2012-08-244:North Korea:JW:000025

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Business Internet Banking llHOIXI 1/2 

HS·BC ID Thewortd~ locar bank 

Email from HSBC 

Subject Re: Case1076627 Payments 

Dear

Thank you for your email of 17 November 2010 regarding our Payment 


services. 


Please accept our sincere apology for this belated reply due to a huge 


volume of incoming emails received recently. 


I understand your concern on the status of an effected payment under 


ref. in amount remitted on 25 $eptember 


2010 and would like to provide you with relevant information. 


Having checked with the Payment Services Department, it is advised that 


we received cable from the beneficiary bank requesting for additional 


details. A notification letter was sent to you on 2 October 2010. 


Please find the details as follow . 


II quote/! 

PLEASE PROVIDE, IN COMPLETE DETAIL,THE FULL NAME AND ADDRESS OF THE 

INDIVIDUAL GENERATING THE HIT (INCLUDING CITY AND COUNTRY DOB, 

POB, CITIZENSHIP, FULL NAME AND ADDRESS OF THIS INDIVIDUALS EMPLOYER 

(INCLUDING CITY AND COUNTRY), A DETAILED PURPOSE OF PAYMENT,A COpy OF 

ALL RELATED INVOICES AND A COpy OFOFAC LICENSE 

/I unquoteJl 

Although we have received your amendment request on 27 October 2010 and 


cabled the beneficiary bank on the same day, the beneficiary bank 


advised us on 30 October 2010 that they are unable to amend the 


beneficiary name unless remitter provide the requested information. 


Regarding the above situation, notification letters were sent to the 


mailing address of the company on 1 November 2010 and 18 November 2010 


asking for your further disposal instruction. 


Please kindly provide your instruction duly signed by the authorised 


signatory (ies) and bearing company chop (if any), and send it to our 


Payment Services Department at 1/F, Tower Two HSBC Center, 1 Sham Mong 


Road, Kowloon, Hong Kong for action. 


For further information on our business products and services, you are 

. welcome to call our Customer Services Hotline at (852) 2748-8288 and 


press option #, 0, 1, 1 after language selection and input account 


number. All our Customer Services Officers are more than happy to offer 


help and other assistance. 


I hope this information is useful and am pleased to be of service. 

I Yours sincerely 

httm:·IIW'WW' r.('Immp.rr.i::l1 h"hr. (".('Im hk/ll?lIl1t/nikr..... mI104 ~iQ~Pvk.,,"v(h{PT .MnM'7()v ,)011_0l_') 1 

2012-08-244:North Korea:JW:000026

(b)(6) & (b)(7)(C)

(b)(4) (b)(4) 
Business Internet Banking illI01 XlIII 

HSBC' The Wor1d\l()ca~ bank 

Email from HSBC 

Subject case

Dear Sir 

i

IRE OUR DATED 25SEP10 FOR IFlO 

IFurther to ,our E-mail of 22NOV1 0 concerning the above payment. 

We confirm have today received cabled message from HSBC Bank 

USA NA, New York and we append below their message for your 

information. 

lquote! 


Be advise funds have been blocked by the Bank of New York 


pursuant to sa,nctions against Korea and they advised "placed 


the funds in a blocked entity account pursuant to U.S sanction' 


regulations. We are unable to consider your payment order null 


and void and return the funds to yourselves unless you obtain 


I a .license from the U.S treasury department's office of foreign 

assets control (OFAC) to request a license contact OFAC licensing 

division 1500 PENNSYLVANIA AVE, WASHINGTON D.C. 

20220, telephone 202-622-2500, fax number: 202-622-1657. 

!unquote! 

IWe are pleased to be of service,: 

I 

I Yours faithfully 

Assistant Man~ger 

4:t!ilt 1m. 


https:!lwww.commercial.hsbc.com.hk/] 121!ut/p/kcxmJl04 Sj9SPykssyOxPLMnMzOv... 2011-01-21 

2012-08-244:North Korea:JW:000027

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----------------

--------------- -------------

---------------

--------------------

--------------- -----------------------------------------

--------------------

--------------------------------------------------------------

.. 


APPLICATION FOR THE RELEASE OF BLOCKED FUNDS 

It IS strongly recommended that you use the computer to complete thiS form 

TYPE OF APPLICATION New Application PreVIous Case Number (Ifapphcable) _______ 

11 Blocked Amount 2 Currency Type CHF 3 Dale Blocked (mm/dd/yyyy) 0510811993 

63391076 

APPLICANT/CONTACT INFORMATION 

4 BUSiness N~me (If applicable) _IF_S_CA_P_IT_A_L_A_SS_E_TS_P_TE_L_TD____________________________ 

5 Last Name 6 First Name 

------------- .., Middle Name 8a Streel Address 1 7 TEMASEK BOULEVARD #10-01 


8b Streel Address 2 SUNTEC TOWER ONE 9 City SINGAPORE 
 --------~---------

10 Singapore 11 PrOVInce 12 Postal Code 038987. 

--------~~~~~====~ 

IX:" 13 Inft 14 Phone 1--~--1--'----J'-;-,-u;-;-3-:09-5-5---I! ~-~ I rx 15 Inl'l 16 Fax 

i 17 E·mail Address 18 Pnnclpal Place'of BUSiness Singapore 

19 Stale or Country Where BUSiness IS IncoIporated Singapore 

-~~---------~------------------

20 Transfer Blocked Due to the FollOWing OFAC Sanc!lons Program 

IF BLOCKING OCCURRED BECAUSE THE NAME OF ANY PARTY TO THE TRANSACTION APPEARS TO MATCH A NAME ON THE' 

SPECIALLY DESIGNATED 1':11\TlONALS (SDN) LIST, PLEASE PROVIDE INFORMATION RELATED' TO THE NAME MATCH (e g' copy 

of onglnalpayment or transfer Instructions, inVOiceS, bills of ladl~g, passport, temporaryfpennanent reSident card, birth certificate, -,. 

Employ~r Identification Number, passport, natlonallD card, Incorporation document or other government-Issued Identlfymg 

docul)'lentatlon) 

FINANCIAL INSTITUTION THAT BLOCKED'FUNDS 

21 InsbtutJon Name CITIBANK N A. SINGAPORE 

22 Street Address 3 TEMASEK AVENUE 11:12-00 CENTENNIAL TOWER 23 City Slngapo", 

.24 25 Province 26 Postal Code 039190 

REMmER'S INFORMATION 

27 BUSiness Name (If applicable) COMMUNICAllON COMPUTATION BUREAU PYONGYANG 

28 Last Name 29 First Name 30 Middle Name ----~---~ 

31 Street Address 32 City 

33 Korea, North 34 ProVince 35 Postal Code -~----~ 

, '/ REMITTING FINANCIAL INSTITUTION 


36 InsIJMon Name KUMGANG BANK 


37 Street Address POBOX 726 PYONGYANG 38 City PYO~GYANG 

Page 1 of3 Total Barcode Characters 652 

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2012-08-244:North Korea:JW:000028

(b)(6) & (b)(7)(C) (b)(4) 
--

- -

- -

OMS No 1505-0170. 

I APPLICATION FOR THE RELEASE OF BLOCKED FUNDS (cant'd) . ­

INTERMEDIARY FINANCIAL INSTITUTION 

42 Insbtulron Name emBANK ZURICH 


43 StreetAddress BLEICHERWEG 10 ZURICH CH8002 44 City ZURICH 


45 Switzerland 46 Province 47 Postal Code 

I BENEFICIARY FINANCIAL INSTITUTION ~ 'i. " ~: II 

48 Insbtubon Name emBANK N.A •SINGAPORE ,./. 

49 Street Address 3TEMASEK AVENUE #12..00 CENTENNIAl. TOWER 50 City Singapore ;;-

' i I

1: 

?f" , 

51 Singapore 52 ProVInce 53, PoslalCode 039190 .~'- :! , 

BENEFICIARY'S INFORMATION J

,. 

J.. • _ 54 BUSiness Name (If apphcable) IFS CAPITAL ASSETS PTE LTD(INTERNATlONAL FACTORS MARINE SPL) " 

_'J" ~ 

55 Last Name 56 FIrst Name 57 Middle Name 

58 Street Address 7 TEMASEK BOULEVARD #10-01 SUNTEC TOWER ONE 59 City Singapore 

60 Singapore 61 Province 62 Postal Code 038987 

63 DETAILED EXPLANATlON OF THE TRANSACTION, INCLUDING THE PURPOSE OF THE PAYMENT (Addlbonal space proVided on next page-) 

This is due to U.S. Regulations which prohibit U.S. persons from handling Commercial transactions involving North 

Korea. - ­

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Page 2 or3 Total Barcode Characters 407 

2012-08-244:North Korea:JW:000029
,; 

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t' 

OMS No 1505-0170' , 

. APPLICATION FOR THE RELEASE OF BLOCKED FUNDS (conrd) 

64 DETAILED EXPLANATION OF THE TRANSACTION (cont'd) 

II' '., ' 

I Jil 

- '~~ it; 1'1,­

: l; 

65 APPLICANT CERTIFICATION: I. THE UNDERSIGNED. HEREBY DECLARE THAT. TO THE BEST OF MY KNOWLEDGE,THE INFORMATION r 

PROVIDED ON THIS APPLICATION AND ANY ACCOMPANYING DOCUMENTATION IS TRUTHFUL AND COMPLETE . I n_n_nn_n__ nnn......_. _n_.nn......._._n..._..n_._.n.n.nn_n__ ..__ .n...__ ._.._.__ :_n__ ------~-~-~~~t 

66 SIGNATURE . 67 DATE 'Iff~ ,tr ," l i

68 SIGNATORY NAME 69 SIGNATORY TITLE GENERAL MANAGER/.GROUP CFOll, : - '1 

Total Barcode Characters 146 

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I 

2012-08-244:North Korea:JW:000030

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)
CorpqraJe 

MariEtlng 

Group 

.~ . $ Sh~nton WO) T~l 224 2611 

107-00 UlC BUilding TlJ. RS 24$84 

Smgapor/: 0106 Tf' 2251584 

/ 

08/05/1993 CITIBAN(C 

Dear 

Further to my phone conversation, this Is to advise that we are 

unable to process this transaction • the Incoming payments of 

SF order of Communlcatlon Computation Burreau Pyongyang. 

This Is due to U.S. Regulations which prohibit U S. persons from 

handling commercial transactions involving North !<orea. 

We have, therefore. placed the funds In US$ Asian Dollar Tme Deposit 

as agreed with you. 

PJease call me at if you need further clarification. 

Yours sincerely 

Account Manager 

Ene 	 Asian Dollar Time Deposit Advice 

Copy of cable 

/It 

/ 


2012-08-244:North Korea:JW:000031

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(4) (b)(6)
;r 

FORM 13 


THE COMPANIES ACT 


(CHAPTER 50) 


SECTION 28(2) 


Company No. 


198700828M 


.............. " . 


CE~TIFICATE OF INCORPORATION ON CHANGE OF 


NAME OF COMPANY 


This is to certify that INTERNATIONAL FACTORS 

KARINE (SINGAPORE) PTE LTD incorporated under the 

Companies Act on 28· March 1987 did by a spe.c ial 

rssolution resolve· to change its name to INTERNATIONAL 

FACTORS LEASING PTE LTD and that the company which is a 

private company 11mited by shares is now known by its 

new name with effect from 18 February 1993. 

Given under my hand and seal on 18 February 1993. 

ASST REGISTRAR OF C MPANIES AND BUSINESSES 

SINGA ORE 

/sg-d2 

2012-08-244:North Korea:JW:000032

(b)(6) & (b)(7)(C)
JPMORGAN CHASE & CO. 


Executive Director 

Legal and Compliance OFAC 

Confidential Treatment Requested 

July 24. 2012 

Adam J. Szubin 

Director 

Office of Foreign Assets Control 

U.S. Department of the Treasury 

Treasury Annex 

1500 Pennsylvania Avenue. NW. 

Washington, DC 20220 

Re: 	 Request for a Specific License to Cover Commodities Trades on Futures 

Exchanges in China 

JPMorgan Chase is making this submission on behalf of itself and its global subsidiaries, 

directors and employees of the foregoing, including JPMorgan Cha~e Bank N.A.., J.P. Morgan 

Broking (Hong Kong) Limited and J.P. Morgan Futures Co., Ltd. ("F&O"), and all affiliated 

entities, agents and independent contractors who are persons subject to the jurisdiction of the 

U.S. (collectively uJPMC"). JPMC requests authorization pursuant to the Iranian Transactions 

Regulations, 31 CFR Part 560 (the "ITR") and the North Korean Sanctions Regulations, 31 CFR 

Part 510 (the "NTSR") to engage in or facilitate trading on three futures exchanges in China, the 

Dalian Commodity Exchange (DCE), the lhengzhou Commodity Exchange (lCE) and the 

Shanghai Futures Exchange (SHFE) (the "Exchanges") through F&O in commodity futures 

contracts which, without JPMC's knowledge or ability to know, can be settled through 

transactions in warrants representing physical delivery of commodities sourced from sanctioned 

jurisdictions. To the best of JPMC's knowledge, the commodities that could potentially be 

sourced from sanctioned jurisdictions are aluminum (Iran) and gold (North Korea) on the SHFE.' 

As of date, JPMC has not identified any involvement in any deliveries involving commodities 

sourced from OFAC-sanctioned jurisdictions.2 Nevertheless, because the three Exchanges 

1 To the best of our knowledge. SHFE (gold, aluminuni) is currently the only affected exchange. However, contract 

specifications on the other exchanges, including specifications as the type and quality ofunderlying commodity 

acceptable for delivery purposes, are subject to change. 

1 JPMC has not traded in, and therefore not settled, any gold contracts. Th'e JV has traded approximately? total of 

19.354 lots of aluminum, with a total of 1,070 being physically settled .•IPMC does not have any knowledge of where 

601 Pennsylvania Avenue NW, Floor 07-STE 700 


Washington, DC, 20004 


Telephone

2012-08-244:North Korea:JW:000033

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) 
JPMORGAN CHASE &CO. 

pose a risk of transactions involving commodities sourced from sanctioned jurisdictions, ..IPMC 

seeks a license to cover trades and any incidental activities involving commodities sourced from 

sanctioned jurisdictions on these exchanges In the future. 

Background 

F&O is a Sino-Foreign Joint Venture3 futures commission merchant established in China with 

regis~ered capital of RMB460,OOO,OOO. The shareholders in F&O are Shanghai Mal Lan De 

Enterprise Development Co Limited, a limited liability company incorporated in China with 50% 

ownership; JP Morgan Broking (Hong Kong) Limited, a limited liability company incorporated 

under the laws of Hong Kong with 49% ownership; and Jiangsu Weiwang Venture Capital Co . 

Ltd., a limited liability company incorporated in China with 1 % ownership.4 

F&O is a member of all four futures exchanges that exist in China. 5 All the exchanges ~re 

regulated by the China Securities Regulatory Commission. DCE offers futures contracts on 

corn, soybeans, soybean meal, soybean oil, palm olein, polyethylene, polyvinyl chloride and 

metallurgical coke; ZCE offers futures contracts on wheat, cotton, white sugar, pure terephthallc 

acid, rapeseeq oil. methanol and long-grain rice; and SHFE offers futures contracts on gold, 

silver, copper, aluminum, lead, steel, wire rod, natural rubber, fuel oil and zinc. 

Futures trading ali the Exchanges involves the purchase and .sale of standardized contracts that 

create a future obligation upon the seller of the contract to sell, and a future obligation upon the 

buyer of the contract to buy, at a specified future date a'specified quantity of the underlying 

commodity at a specified price that is agreed upon at the time that the parties enter into the 

contract. Upon expiration of the contract, settlement between the parties is usually effected by 

way of cash settlement rather than physical delivery of the underlying commodity. However, to 

the extent that such physical delivery is requested, it will be effected by a transfer of warrants 

representing good delivery of the physical coml'!l0dity. It is possible that certain of the physical 

commodities for which such warrants are issued may be sourced from a sanctioned jurisdiction. 

To the best of JPMC's knowledge, the commodities that could potentially be sourced from 

sanctioned jurisdictions are aluminum (Iran) and gold (North Korea). Under the current contract 

specifications, aluminum can be sourced from 29 countries and gold can be sourced from 24 

countries, except for China .. 

the physical was sourced and has no information which would cause it to suspect that any physically settled 


aluminum was sourced from Iran. 


3 A Sino-Foreign Cooperative Joint Venture refers to a joint venture between a Chinese and a foreign company within . 


the territory of China. 


4 Due to China's Company laws governing foreign direct investment. foreign investors can only operate through 


Chinese limited liability companies. 


5 The 4th exchange, China Financial Futures Exchange (CFFE). only offers futures contracts over financial indices. 


CFFE does not offer futures contracts over commodities. 


601 Pennsylvania Avenue NW, Floor 07-STE 700 

. Washington, DC. 20004 

Telephone

2012-08-244:North Korea:JW:000034

(b)(6) 

(b)(6) & (b)(7)(C)
.. 
 JPMORGAN CHASE & CO. 


As a member of each of the Exchanges, F&O acts solely in the capacity of a futures 

commission merchant effecting the execution and clearing of transactions in futures contracts. 

over the underlying commodities for its Chinese clients. In this role, F&O and other brokers 

have no way of knowing, at the time of executing a transaction on behalf of a client, the origin or 

location of the particular underlying commodity that may be delivered in connection with a 

particular futures contract. F&O would not be able to determine prior to the receipt or delivery 

.by its client of a warrant whether F&O had brokered rights to comm09ities sourced from an 

OFAC-sanctioned jurisdiction. In addition, in the event that a transaction in a commodity 

sourced from a sanctioned jurisdiction were effected, the rules of the Exchanges do not permit a 

purchaser or its 'broker to refuse acceptance of particular warrants. 

Given the historically minimal trading in commodities sourced from Iran or North Korea in 

making or taking delivery pursuant to contracts transacted on the Exchanges, the chances of . 

brokering commodities targeted by the ITR or NKSR is small. To the best of our knowledge, 

such commodities would not likely be directly sourced from a sanctioned jurisdiction and no 

sanctioned entity would be a party to a transaction on the Exchanges or benefit directly from 

such transactions. Only Chinese local residents and entities are permitted to trade on the 

Exchanges. 

Section 560.S26(a)of the ITR provides for the issuance of specific licenses for "certain 

commodities trading by a [U.S.] person in Iranian-origin goods, or transactions incidental to such 

trading, wh~re: (1) [n]o party to the transaction with the [U.S.] person is a person in Iran or the 

Government of Iran, and (2) lilt is impossible for the [U.S.] person to determine at the time of 

entry into the transaction ... that the goods would be of Iranian origin or would be owned or 

controlled by the Government of Iran." We believe that both conditions are fully met by JPMC 

trades on the Exchanges. First, as noted previously, only Chinese local residents and entities 

are permitted to trade on the Exchanges. Second, Iranian-origin aluminum and North Koreanorigin gold constitute only two among many interchangeable sources of aluminum or gold 

whose warrants would constitute "good delivery" in fulfilling a contract on the Exchanges, and it 

is not'possible to determine what origin aluminum or gold will be allocated to an open contract. 

We understand that it has been OFAC's policy to issue specific licenses under the ITR and 

other sanctions programs to allow disposal of target-country goods or commodities where a 

commodities or other trading contract entered into by a U.S. person results or will result in the 

delivery of commodities or other goods of target-country origin, so long as the U.S. person has 

no ability to foresee or control the origin of the commodities goods and did not enter the contract 

with a sanctions target. 

601 Pennsylvania Avenue N'!'J. Floor 07-STE 700 


Washington

Telephone 

2012-08-244:North Korea:JW:000035

(b)(6) & (b)(7)(C) (b)(6) 
JPMORGAN CHASE &CO. 

Request for Authorization 

Because JMPC cannot predict whether its trading activity on any of the Exchanges will involve 

Iranian or North Korean commodities, JPMC seeks authorization, in the circumstances stated in 

Section 560.526(a)(1) and (2) of the ITR, to engage in transactions involving, including receipt 

and disposal of, warrants representing right to Iranian or North Korean commodities traded on 

the Exchanges .. 

This letter contains confidential proprietary commercial information of JPMC covered by 

applicable exemptions from public release under the Freedom of Information Act, 5 U.S.C. § 

552 ("FOlAn), or otherwise, none of which information has been publicly released. We request 

that you provide notice to the undersigned, and an opportunity to contest disclosure, in 

accordance with 31 C.F.R. § 1.6(b)-(d), if any portion of this submission is or becomes the 

subject of a request for disclosure under FOIA or any other law or claim of right. 

We would be glad to provide additional information upon request in support of this submission. 

Respectfully submitted, 

cc: 	 Andrea Gacki, licensing 

Davis Polk 

601 Pennsylvania Avenue NW, Floor 07-STE 700 


Washington. DC. 20004 


Telephone 

2012-08-244:North Korea:JW:000036

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) 
KIRKLAND &. ELLIS LLP 


To Call Wnter Directly 


AND'AffILIATED'PARTNERSHIPS 

655 Fifteenth Street, N W 

Washington, DC 20005 

(202) 879-5000 i .:. 

www kirkland com 

August 3, 2012 

VIA FACSIMILE & HAND DELIVERY 

'\ 	 Adam J Szubm 

DIrector 

Office 6fForeign Assets Control 

U S Department of the Treasury 

Second Floor Annex 

1500 Pennsylv,ama Ave, NW 

Washmgton, DC 20220 

Attn Llcensmg DIVIsIOn 

Fax 202-622-1657 

Facsimile 

(202) 879-5200 

CONFIDENTIAL 

Re 	 Request for Specific LIcense to Effectuate Certam Transact/on Related to 

ProteCtion ofIntellectual Property m North Korea Pursuant to 31 CF R 

§501 801 (b) 

Dear Mr. Szubm, 

ThIS ·IS further to the

KIlpatnck Townsend & Stockton LLP ("KTS") by and through Its counsel, Kirkland & EllIs 

LLP ("Kirkland") hereby seeks authOrIzation from the U S Department of the Treasury, Office 

of ForeLgn Assets Control ("OF AC"), to effectuate transactIOns related to protection of patents, 

trademarksandlor copynghts With respect to Its clIent KTS understands 

that IS simultaneously submlttmg an authonzation request by and through Its counsel 

With respect to Similar transactIOns Further to KTS's 

KTS seeks authonzatlOn to conduct With respect to North Korea transactIOns on behalf of 

related to mtellectual property ("IP") protectIOn that are authOrized under other of 

OFAC' s economIC sanctIOns regulations I In vIew of these general lIcenses and the general 

favorable polIcy toward authonzmg IP protectIon-related activities they mdlcate, as well as 

OFAC's general favorable polIcy toward authonzmg many legal services and the fact that 

See e g , 31 C F R §560 509 (Iran TransactIOns regulatIOns, 31 C F R 538 514 (Sudan Sanctions Regulations), 

31 C F R §S515 527 & 515 528 (Cuban AssetConrrol Regulations), Syna General LIcense No 15 

I 

2012-08-244:North Korea:JW:000037

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) 
KIRKLAND &.. ELLIS LLP 


Director Szubln 

8/3/2012 

Page 2 

protectIOn of Intellectual property nghts of US compames IS consIstent WIth Important US 

economic Interests, KTS requests OFAC's expedIted approval of thIS request Undue delay In 

provldll1g such authOrIzatIon could result In loss of Important IP protectIOn and related negative 

consequences for

1. 	 BACKGROUND;- PAST AND PROPOSIW TRANSACTIONS 

~ a. GENERAL IP PROTECTION ACTIVITIES 

KTS IS one of the premIer U Slaw finns In the area of Intellectual property protectIOn, 

representing many leading U S and overseas-based companIes whose Intellectual property needs 

~pan the globe These compames' not only manufacture, dIstrIbute and sell theIr products and 

services throughout much of the world, but also are the victIm of predatory practIces by 

counterfeiters and pIrates seeking to misapproprIate the value of such companIes' Intellectual 

property Accordingly, KTS IS charged With securing, maintaining and enforCing the Intellectual 

property nghts of Its chents throughout many, If not most, of the countnes of the world 

Includmg countnes subject to U S economIC sanctIOns adminIstered by OFAC 

Protecting those nghts reqUires KTS to Interact, dIrectly or Indirectly, With prIvate parties and 

relevant governmental entItles In sanctIoned countnes As OFAC IS aware; many of ItS 

regulatIons contaIn speCIfic authOrIzatIons for the transactIOns necessary to protect'lntellectual 

property rIghts In sanctIOned countl'les 2 Hlstoncally, KTS has conducted. such transactIons on 

behalf of chents, In many such countrIes With the understandmg that thIS. 

actlVlty was explICItly authorized III OFAC's regulations 

h. 	 NORTH KOREAN SANCTIONS DEVELOPMENTS 

UntIL 2008, trade With North Korea was regulated under the TradIng With the Eriemy Act 

("TWEA") 3 ThIS Act Included a prOVISIOn explICitly authOrIZing actIVIties aimed at the 

2 	 31 C F R §560 509 (Iran Transactions regulatIOns, 31 C F R 538 514 (Sudan Sanctions Regu latIOns), 31 

C F R §SS 15527 & 515 528 (Cuban Asset Control Regulations), SYria General License No 15 

3 	 ActofOctober 6, 1917,ch I06,40Srar 411 

2012-08-244:North Korea:JW:000038

(b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) 
KIRKLAND &. ELLIS LLP 


DIrector SzubIn 

8/3/2012 

Page 3 

prqtectlOn of US persons' Intellectual property rIghts 4 On June 26, 2008, under ProclamatIOn 

8271, PresIdent George W Bush determined that sanctIOns against North Korea would no longer 

be regulated under TWEA On the same day, In ISSUIng Executive Order 13466, the PresIdent 

declared a natIOnal emergency to deal wIth the threat of nuclear weapons prolIferatIOn In North 

Korea and Issued new restrIctions under the authorIty of the InternatIOnal Emergency Economic 

Powers Act (lEEPA) 5 The Order establIshed a block agaInst "all property and Interests In 

property ofNorth Korea or a North Ko~ean natlOnal that under the TWEA were blocked as of 

June 16, 2000" On November 4, 2010, OFAC Issued regulatlOns Implementing Executive 

Orders 13446 and 13551, which blocked property With respect to certain persons In North 

Korea 6 

On AprIl 18,2011, Executive Order 13570 was Issued,prohibltlng the ImportatIOn of servIces 

from North Korea OFAC Issued the North Korean SanctIons RegulatIOns to Implement thiS 

Executive Order, which were publIshed Hi June 20 II 7 Concurrently, OFAC annoullced t~e 

removal of the prIor sanctIOns targetIng North Korea, Ie, 31 C F R Parts 500 and 505, the 

Foreign Asset Control RegulatIOns and TransactIOn Control RegulatIons, respectively, based on 

the 2008 ProclamatIOn and Executive Order on North Korea g 

c. 	

4 	 ld at SectlOn IO(b) 

5 50 USC ~170H706 

6 	 75 Fed Reg 67912 

7 	 See3l CFR510, 76 Fed Reg 35740 

8 	 See 76 Fed Reg 35739 

Korean-OrigIn services 

2012-08-244:North Korea:JW:000039

(b)(4), (b)(6) & (b)(7)(C) (b)(4) 

(b)(4) 

(b)(4) 
KIRKLAND &.. ELLIS LLP 


DIrector SzubIn 

8/3/2012 

Page 4 

i. 

2012-08-244:North Korea:JW:000040

(b)(4) (b)(4) (b)(4) 

(b)(4) 

(b)(4) 

(b)(4) 

(b)(4) 
KIRKLAND &. ELLIS LLP 


DlreGt0r Szubm 

8/312012 

Page 5 

2. PARTIES 

a) KILPATRICK TOWNSEND & STOCKTON LLP 

KTS IS a major US-based law firm located at 1100 Peachtree Street, Atlanta, Georgia 30309 

One of the firm's core practice areas IS mternatlOnal mtellectual property protect10n, and It 

provides such services for a global array of leadlllg compames, lllcludlllg The firm's tax_ 

Identification number IS 

KTS is represented by Kirkland, an InternatIOnal law firm headquartered at 300 North LaSalle, 

Chicago, IL 60654 

b) 

NORTH KOREA TRANSACTIONS 

c) . NORTH KOREA TRADEMARK, INDUSTRIAL DESIGN AND GEOGRAPHICAL 

INDICATION OFFICE 

The North Korean Trademark Office IS the governmental authonty responsible for authorizatIOn 

of trademarks, patents and copynghts In North Korea It IS located at Inhung I Dong, Moranbong 

DiStrict, Pyongyang, DPR Korea 

d) 

2012-08-244:North Korea:JW:000041

(b) (4) (b)(4) (b)(4) 

(b)(4) 

(b)(4) (b)(4) (b)(4) (b)(4) 

(b)(4) 

(b)(4) 
(KIRKLAND &.. ELLIS LLP) 

Director Szubin 

8/3/2012 

Page 6 

3. REQllEST FOR SPECIFIC AUTHORIZATION 

i·equests authorization to effectuate the intellectual property protection activities necessary 

to protect intellectual property in North Korea, including as described above" 

Specifically, 'equests that OF AC issue a specific license that authorizes the transactions 

that are authorized with respect to other countries subject to OFAC sanctions, as follows: 

and are authorized to engage in 

the following transactions in connection with patent, trademark, copyright or 

other intellectual property protection in the United States or North Korea: 

(1) the :filing and prosecution of any application to obtain a patent, trademark, or 

copyright or other forl11 of intellectual property protection, including importation 

of or dealing in North Korean-origin services, and payment to persons in NOith 

Korea directly connected to such intellectual property protection; 

(2) the receipt of a patent, trademark, and copyright or other form of intellectual 

property protection; 

(3) the renewal or maintenance of a patent, trademark, copyright, or other form of 

intellectual property protection; 

(4) the filing and prosecution of opposition, cancellation or infringement 

proceedings with respect to a patent, trademark, copyright or other form of 

intellectual property protection, or the entrance of a defense to any such 

proceedings. 

4. 	 II) PnOTEcT10N AUTHORIZATlON DOES NOT JEOPARDIZE U.S. SANCTIONS POLICY 


OBJECTIVES 


SpecifIc authorization of the proposed transactions would not undermine the policy objectives 

1,ll1derJying the North Korean sanctions, which in general target the illicit activities of the North 

Korean government and particular parties identified on OFAC's SON List. None of the 

governmental entities or private parties involved in activities to protect 

2012-08-244:North Korea:JW:000042

(b)(4) 

(b)(4) 

(b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) 
(KIRKLAND &. ELLis LLP) 


Director Szubin 

8/3/2012 

Page 7 

intellectual property rights is an SDN. The only governmental agency believed to be involved in 

these transactions is the North Korean Trademark Office. 

U.S. policy objectives are served by permitting U.S. companies, such as Jo protect their 

rights from counterfeiting and piracy in North Korea. Consistent with this rationale, we note that 

OFAC authorizes these intellectual property protection activities in other countries subject to 

U,S. economic sanctions. ll 

5. 	 No ENFORCEMENT ACTION IS WARRANTED WITH REGARD TO ANY ApPARENT 

VIOLATIONS OF OFAC's NORTH KORI~AN SANCTIONS REGULATIONS 

II 	 See e.g., 3 I C.F.R. §560.509 ([ran Transactions regulations; 31 C.F.R. 538.514 (Sudan Sanctions Regulations); 

31 C.F.R. §S5 15.527 & 515.528 (Cuban Asset Control Regulations); Syria General License No, 15. 

2012-08-244:North Korea:JW:000043

(b)(4) 

(b)(4) 

(b)(4) 

(b)(4) 

(b)(4) 

(b)(4) (b)(4) (b)(4) (b)(4) 
(KIRKLAND-&' ELLIS LLP) 


Director Szubin 

8/312012 

Page 8 

6. REQUEST FOR CONFIDENTIAL AND EXPEDITED TREATMENT OF THIS REQUEST 

This submission contains confidential and proprietary commercial and financial information of 

kd jhe public release of which would cause harm to all pmties, including those 

identified in Exhibit A. Pursuant to 31 C.F.R. § 501.805 and 5 U.S.C. § 552 (Freedom of 

Information Act), we request that the information submitted herein be treated as confidential 

business information and understand that, on behalf of :ve will be timely notified and 

afforded an opportunity to object if any request for this information is received by OFAC. 

2012-08-244:North Korea:JW:000044

(b)(4) (b)(4) 

(b)(4) 

(b)(4) 

(b)(4) 

(b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) 
, . 


QqBKLAND& ELLIS LLP) 

Director SZllbfi1 

,813/20.12 

Bage·9 

Theabillt-y ;ol\KFSho :'protcct hu.pprtant hitelledilatphYpertydghts·rnay DcTilJPa:.ired:l!yd'elay i)) 

;(hj~ a~Lthori~ati!()lYt0;c.~lrduct.]P 'm::tlv1i;~s fcilatct(tQ Nm1h KQre~, weTequestfhdtoj~Ajtconsi'd~'i' 

this req:uesf iniril expedHed 'i1ranne,r,.. Weare .~vajla;ple to m:eet; willi OF:~C;pets,ql1t:1e1, ~f SUe!l 

me.ding; wouId.cxpedit.e'this nufttet. 

Thpnk Y9uinadvanc~ t'(n: y~u.r'icol1s1~leraJion.Qf t~ls l:equcst.Shou]0)'0U hav.~4n~,questi0nSQr 

-r~tlhe"any .additi.o~~~[()t~:~a~tt~~, ipf~~e :cO:lllact at 'qF 

at (

2012-08-244:North Korea:JW:000045

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(6) (b)(6) 
21771 Stevens Creek Blvd, SUite 100 

Cupertmo, CA 95014 

www novakdruee com 

Phone 408 414 7330 

Fax 408996 1145 

NOVAK. DRUCE + QUIGG llP 

ATTORNEYS AT LAW 

Email EXPEDITED PROCESSING REQUESTED 

August 15,2012 

Office ofForeign Assets Control 

U.S. Department ofthe Treasury 

Treasury Annex 

1500 Pennsylvarua Avenue, NW 

Waslungton, DC 20220 

Attention' Llcensmg Division 

RE. 	 Intel Corporation's Request for Expedited Processing of an Application for a 

Specific License to Engage in Certain Transactions Related to Intellectual 

Property Rights in North Korea 

Dear SrrlMadam' 

Our law finn, Novak Druce + Qwgg LLP ("NDQ"), represents Apphcant Intel Corporation 

("Intel") Wlth regard to the management of Intel's worldwide trademark portfolio On behalf 

of Intel, and in our capacity as outside counsel, we are sublllittmg this ApplIcatlOn for a 

Specific License for Intel, pursuant to 31 CFR §50 1 80 1 (b), in order to engage m transactIons 

related to mtellectual property nghts m North Korea whIch otherwise may be prohibited Uflder 

Ex~utive Order 13570. We also request expedited review of this applIcation m light of 

upcoming deadlmes for trademark applicatiOns and registrations already existing in North 

Korea. 

Background 

Intel is a well-known, global manufacturer and suppher of mtegrated circwts and other 

electromcs products. Intel has Implemented an extensive worldwide program of 

registermg and protectIng Its trademarks from Infnngement and other Ufllawful uses 

aroUfld the world. As part of Inte}'s trademark filIng and protectIOn strategy, Intel 

regularly seeks protectIOn for its trademarks worldWlde 

President Obama Signed Executive Order 13570 (EO 13570) on Apnl 18,2011 EO 

13570 has an effective date of Apn119, 2011. EO 13570 states In Section 1 

Except to the extent provided In statutes or In licenses, regulatIons, orders, or 

dIrectives that may be Issued pursuant to this order, and notwithstanding any 

contract entered Into or any lIcense or penmt granted to the date ofthIs order, the 

importation into the United States, directly or indirectly, or any goods, 

services or technology from North Korea is prohibited. 

2012-08-244:North Korea:JW:000046

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) 
August 1S, 2012 

Page 2 

NOVAK CRUCE. QUIGG UP 

·It IS our understanding that the bolded wording above may be Interpreted by the Office of 

Foreign Assets Control. ("OFAC") to prohibit actIOns associated with the engagement of a 

trademark agent or counsel In North Korea with regard to the ownership of Intellectual 

property In North Korea, including the ability to file, prosecute, renew, assign, maintain, 

and enforce trademark fIghts and other Intellectual property nghts Given tills 

understanding, we request below, on behalf of and for Intel, a SpeCific LIcense that wIll 

allow Intel to pursue, mamtaln and enforce trademark nghts In North Korea, EO 13570 

notwIthstanding. 

Required Applicant Information 

Applicant. 

Intel CorporatIon, a Delaware corporation 


2200 Mission College Boulevard 


Santa Clara, CA 95052 


AdditIonal Anticipated Parties Involved 

Intel's US. Trademark Counsel 

Novak Druce + Qwgg LLP, headquartered at 1000 Lowslana Street, Fifty-Third 

Floor, Houston, Texas 77002, With addItiOnal offices ill Washrngton DC, San 

FranCISCO, Cupertino.(Silicon Valley) and West Palm Beach 

North Korean Agents 

1 	 and other agents of Moranbong Patent & Trademark Agency, 

located at POBox 43, Ryugyong-dong No 2, Pothonggang DIStrict, Pyongyang, 

DPR Korea, or other appropnately designated agents In North Korea as future 

needs anse. 

2 	 The North Korea Trademark, Industnal DeSign and GeographIcal IndIcatIOn 

Office, a government entIty, located at lnhung 1 Dong, Moranbong DIStnct, 

Pyongyang, DPR Korea, and other such government agencies ofNorth Korea 

responsible for and admirustering the filing, prosecutIOn, maintenance, ownership, 

and enforcement of trademark matters In North Korea ' 

Intel and NDQ will provide such addItional mformatIOn as OF AC deems necessary to afford a 

proper determinatIOn by OF AC. 

\ 

2012-08-244:North Korea:JW:000047

(b)(6) & (b)(7)(C) (b)(4) 
August 15, 2012 

Page 3 

NOVA~ DRUCE + QUIGG llP 

Please kindly address all written correspondence to 

Intel CorporatIOn 

c/o Novak Druce + Quigg LLP 

21771 Stevens Creek Boulevard, Swte 100 

Cupertmo, CA 95014 

AttentIOn: 

Request for Specific License and Authorization 

ProtectIOn ofmtellectual property nghts IS somethmg regularly excluded from U.S. 

sanctions programs, or for which a General or Specific license IS often granted. EVidence 

ofthIs pohcy is reflected. in the eXisting general licenses estabhshed by OFAC for the 

protectIon oftrademarks and other intellectual property nghts In sanctioned countnes 

such as Cuba, Iran, Sudan and Syna, among others 

Intel respectfully requests that pursuant to 31 CFR Parts 501 and 510, OFAC provide a 

Specific License to Executive Order 13570' Authorlzmg Intel CorporatIOn and its 

appointed agents mcludmg Novak Druce + Quigg LLP, to engage in all transactIOns to 

pursue, obtain, and maintam protectIOn for Intel's trademarks and trademark rights in 

North Korea, and to remit funds to the Government ofNorth Korea and other persons In 

North Korea m connection therewith, so long as such persons are not on the Specially 

DeSignated NatIOnals List (SON) 

Such transactions could also be covered by granting authonzation, Similar to that granted 

in the 'existing general hcenses established by OFAC, to Intel CorporatIOn and Its 

appomted outside counsel Novak Druce + QUigg LLP to carry out the followmg 

transactions and actIvIties that might be otherwise prorublted by EO 13570, Includmg 

engagmg services ofNorth Korean counsel, agents or other representatives, so long as 

such persons are not on the Special DeSignated Persons List (SON), for and related to 

a) 	 The filing and prosecutIOn ofapphcatlOns for trademarks In North Korea or 

deSIgnating North Korea m an applicatIOn for InternatIOnal Registration; 

b) 	 The processmg, receipt, acqUisItIon and assignment oftrademarks through 

North Korean agents; 

c) 	 The renewal and mamtenance oftrademarks In North Korea, 

\ 

2012-08-244:North Korea:JW:000048

(b)(6) & (b)(7)(C)
August 15, 2012 

Page 4 

NOVAk D~uce • QUIGG llP 

d) 	 The enforcement, defense or establIshment of trademark nghts m North 

Korea, mcluding filmg and prosecutIOn of opposItion, cancellatIOn and 

mfringement proceedings in North Korea; and 

. e) 	 The ImportatIOn of servIces from North Korea m connectIon WIth any of the 

foregomg, and payment of all officIal application filIng and registratton fees, 

renewal and maintenance fees, as well as ordmary and customary servIce fees 

to legal counsel and/or agents m connectIon with any of the foregomg m 

North Korea 

Request for Expedited Consideration 

Intel respectfully requests that thIs ApplIcation for a SpecIfic LIcense be considered on 

an expedited basis because Intel has at least three non-extendible deadhnes approachmg 

in September, November, and December 2012 WIth regard to trademark matters m North 

Korea The three matters WIth deadlInes coming up m 2012 are 

1 A pendmg applIcatIOn for International RegistratIOn filed via the Uruted States 

Patent & Trademark Office (with a North Korea deSIgnation) usmg the 

Madrid Protocol system WIth a final September 30,2012 deadlIne to respond 

to an office actIOn Issued by the North Korean trademark office, and 

2 Two final renewal deadlInes for eXIstmg trademark regIstratIons m North 

Korea due on November 25, 2012 and December 25,2012 respectively 

Please note that the deadlines listed above are the final deadlines, and addItional tIme wIll 

be needed to provide mstructions to coUnsel m North Korea and to send any written 

materials Should Intel fall to respond timely to the above deadlines, It will lose the 

pendmg trademark apphcatlon and eXlstmg registrations Because trademark nghts m 

North Korea arIse from trademark regIstratIOns, the loss ofthe pending applicatlon and 

registratIOns will be irreparable as Intel WIll lose the early filmg dates along WIth the 

nghts and protection afforded through these trademark fihngs Such a permanent loss 

would result m undue and unfair harm to Intel Thus, Intel respectfully requests that 

OF AC consIder thIs ApplIcatIon for a Specific LIcense on an expedIted baSIS 

\ 

2012-08-244:North Korea:JW:000049
NOVAK DIU, E + QUIGG UP 

August lS, 2012 

PageS 

ArTQRH'fY$ Ar LAW 

If OFAC has any questIons or reqwres additional mfonnation, please contact

by phone at by fax at (408) 996.. 1145; or by email at 

All written correspondence should be directed to at 

the address shown above 

Thank you very much for your attention to thIS matter. 

Sincerely yours, 

cc 	 Mr Adam J Szubin, DIreCtor, OFAC 

This letter contams Intel proprietary and confidential mformatlOn which IS exemptfrom publzc 

disclosure under the Freedom ofInformatlOnAct (FOIA) 5 USC sec 552(b)(4), and 31 C F R. 

sec 501 805 Any disclosure ofIntel's proprietary and confidentzal mformatlOn could adversely 

affect Intel's financial or competlllve pOSitIOn and the normal course ofInters busmess 

Accordingly, we respectfully request that thiS letter, and all mformatlOn contamed herem, be 

mazntamed m confidence, and wzthheld In the event ofa demand or request for release or 

disclosure hereof We further request that, In the event ofany such demand or requestfor release 

or disclosure, the Office ofForeign Assets Control prOVide Intel With prompt nollce ofthat 

demand or request, and an opportumty to be heard prIOr to any such release or disclosure 

\ 

2012-08-244:North Korea:JW:000050

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) 
1776 K STREET NW 

WASHINGTON, DC 20006 

PHONE 202,719,7000 

FAX 202,719,7049 

7925 JONES BRANCH DRIVE 

McLEAN, VA 22102 

PHONE 703,905,2800 

FAX 703,905,2820 

www,wUeyrein,com 

June 30,2009 

VIA FAX AND MAIL 

Adam Szubin, Director 

Office of Foreign Assets Control 

North Korea Unit 

1500 Pennsylvania Avenue, NW 

Washington, D.C. 20220 

ATTN: Licensing 

Re: License Request to Import Printer Cartridges from South Korea that 

are Produced using Labor in North Korea 

Dear Mr. Szubin: 

On behalf of Printer Essentials.com, Inc. ("Printer Essentials"),' and out of an 

abundance of caution, we respectfully request that the Office of Foreign Assets 

Control ("OFAC") grant a specific license pursuant to 31 C.F.R. § 500.586(b) 

allowing Printer Essentials to import printer cartridges from Ltd. 

a South Korean company that manufactures its cartridges, in part, 

by using labor fi-om a North Korean company. 

Irriporter: Printer Essentials.com, Inc. 

Address: 5190 Neil Road, Suite 205 

Reno, NV 89502 

Telephone: 1-800-965-1180 ext. 1041 

Fax: 775-850-2630 

E-mail Address:

Contact: (CEO/President) 

" Exporter:

Business Registration #:

Address:

South Ko

Telephone:

Fax:

2012-08-244:North Korea:JW:000051

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(6) 
Adam Szubin 

June 30,2009 

Page 2 

Background 

Printer Essentials is a U.S. importer and wholesaler of compatible imaging supplies 

and power products that seeks to import printer cartridges from a 

registered business in South Korea that operates a manufacturing facility in

South Korea. 

provides with the necessary materials for to 

manufacture the cartridges. Specifically, it provides

plays no other role 

in exportation of cartridges other than The processes 

that

 pays . approximately

per fmished cartridge and wire-transfers these fiands to through the 

Industrial Bank of Korea, a South Korean bank. 

After

Before exporting the 

cartridges, performs final tasks such as:

Provided that OFAC grants Printer Essentials the required authorization, Printer 

Essentials would import printer cartridges from It would import 

approximately printer cartridges per month at an average cost of

Consistent with the licensing provisions of 31 C.F.R. § 500.586(b), the following 

information is hereby provided: 

Producer's Name in North Korea:

2012-08-244:North Korea:JW:000052

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) , (b)(6) & (b)(7)(C) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(6) & (b)(7)(C) 

(b)(6) & (b)(7)(C) 

(b)(4) 

(b)(4) 

(b)(4) (b)(4) (b)(4) (b)(4) 
Adam Szubin 

June 30,2009 

Page 3 

Producer's Address in North Korea:

North Korea 

Location Where Product Produced: South Korea

Request for a Specific License 

To the extent that one is required, and out of an abundance of caution, Printer 

Essentials seeks a specific license that would authorize it to import toner cartridges 

fi'om a South Korean company that manufactures its cartridges, in part, 

by a North Korean company. 

This letter contains business sensitive information, which, if disclosed, could 

damage Printer Essentials competitively. We request that it not be disclosed under 

the Freedom of Information Act, and further, that Printer Essentials be informed of 

and given an opportunity to object to any decision to release this letter or the 

information it contains. 

Sincerely, 

Counsel to Printer Essentials.com, Inc. 

2012-08-244:North Korea:JW:000053

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(4) (b)(4) (b)(4) 

(b)(4) 

(b)(4) 
1.: 

.~. . J' 

r~ 

l 

; 

KOREA PYONGYANG TltADDNG USA, Unc.. 
 98 THAYER STREET, #1B, NEW YORK, NY 1'0040 

Tel: Fax: 

September 21,2011 

North Korea Unit 

Licensing Division 

. Office of Foreign Assets Control 

U.S. Department of.the Treasury 

1500 Pennsylvania Avenue N.W. Annex 

Washington, D.C. '10220 

Re: 	 Request for Review and Approval of Import 

Daedonggang Beer, Product of North Korea (D. P. R. of Korea) 

Dear Sir or Madam: 

My name is of Korea Pyongyang Trading USA Inc., doing business as Korea 

, Pyongyang Trading USA (hereinafter referred as "KPTU"). KPTU is an importer and exporter like any 

other but we do business with North Korea. 

Pursuant to the compliance with provisions of the Arms Export Control Act, 22 U.s.C. 2751, et seq. 

(the"AECA"),and under the authority of E.O. 13570, we are seeking for an authorization to import 

Daedonggang Beer (hereinafter, the Beer), produced in North Korea (D. P. R. of Korea), to U.S. 

We respectfully request for an approval to import the Beer from North Korea. Following are the 

information about proposed import: . 

• Importer: 

Narne: 

Company Name: Korea Pyongyang Trading U.S.A. Inc 

Company Address: 98 Thayer Street, Suite I B 

Ne~ York. NY. 10040 

e-mail: 

Tel: 

Fax: 

• Description of the product to be imported (initial): 

o Chemical Composition of Ingredients: 

2012-08-244:North Korea:JW:000054

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C) (b)(6) (b)(6) (b)(6) (b)(4) (b)(4) 
... 


Korea Pyongyang Trading USA, Inc. 

98 Thayer Street, Suite I B 

:~', 

). 

r 

" 

o List of Material(s) .Product: 

i

, 

~. 

o Means Transportation: 

Transportation: by Sea (40 ft. or 20 ft. Container) 

Quantity: 

o 	 Packing Style: 

1 Carton Boxl24 Bottles 

o 	 Import Unit Value: 

o 	 Import of Total Amount: 

• 	 Name and Address of the producer ofthe product: 

Company name: Korea Daedonggang Brewery 

Person in charge: 

Company Address: Songsin I-dong, Sadong District ,.

, Pyongyang. D.P.R. of Korea 

Tel: 

Fax.: 

E-mail addresses: none 

• 	 Name of the location where the product was produced. 

Company name: Korea Daedonggang Brewery 

Person in charge: 

Company Address: Songsin l-dong, Sadong District 

I 

2012-08-244:North Korea:JW:000055

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) (b)(6) 

(b)(4) (b)(4) (b)(4) (b)(4) 

(b)(4) (b)(4) (b)(4) (b)(4) (b)(4) 
'. 

Korea Pyongyang Trading USA, Inc. 

98 Thayer Street, Suite I B 

Pyongyang. D.P.R. of Korea 

Tel: 

Fax: .

E-mail addresses: none 

• 	 Exporter: 

Nan1e: 

Address: 

Pyongyang. D.P.R. of Korea 

Tel: 

Fax: 

+850~2-381 ~4427 

E-mail addresses: none 

Products to be imported were not produced by 

(a) a foreign person designated by the Secretary of State as having engaged in missile 

technology proliferation activities; 

(b) an activity of the North Korean Government relating to the development or production of 'j, any missile equipment or technology; or 

(c) an activity of the North Korean Government affecting the development or production of 

electronics, space systems or equipment, and military aircraft_ 

. We much appreciate your attention to this matter and look forward to your. expedited processing of our 

request. ,,-, 

President 

KPTU 

! ' 

2012-08-244:North Korea:JW:000056

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C) (b)(6) (b)(6) (b)(4) 
KORIEAPYONGYANIG TRADING USA, .One. 


98 THAYIER STR!CIET, #1B, Nli:WYQRK, NY 10040 

Tel: Fax:

June 18,2010 

Via Facsimile 

202-622-1657 

Total: 3 Pages 

. Ms. Clara Y. David 

Chief, TWEA Licensing Section 

Office of Foreign Ass~ts Coutrol 

U.S. Department of the Treasury 

1500 Pennsylvania Avenue N.W. Annex 

Washington, D.C, 20220 .' 

Re: Request for Amendment on an Approved Authorization (Case # NK-93089) 

Daedonggang Beer, Product ofNorth Korea (D. P. R. of Korea) 

Dear Ms. David: 

First of all, ·on behalf of importer, Korea Pyongyang Trading USA Inc., and exporter, I tJmnk 

you for your speedy approval of our request to import 1,250 cases (25,000 bottles) of 

Daedonggang Beer,a product ofD. P. R. of Korea (D.P.RX.). 

Because of prOper fitting ofbottles per transportingcontalner, cost effectiveness of 

transportation, and distribution strategies towards market, we would like to request for an 

instant amendment and approval for the approved authorization # NK-93089, as follow: . 

Quantity 

Period 

Bottles Boxes 

(24 bttls /box) 

Total liquid 

(Unit: ml.) 

Unit cost 

(U$D) 

Total 

(U$D) 

Initial Shipment 

First Quarter 

Second Quarter I 

Third Quarter I 

2012-08-244:North Korea:JW:000057

(b)(6) & (b)(7)(C)

(b)(6) (b)(6) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4) (b)(4)
Korc~ Pyongyang Trading USA, Inc. 

9lJ Thayer Street, Suit-t I B 

o Description ofthe product'to be imported: 

o . Chemical Composition ofIngrediems: 

. 

o 	 List ofMaterial(s) Product: 


o Packing Style: 

o 1 Carton Box/20 Bottles 

o Import Unit Value: . 

o 

o Means Transportation: 

o T.t:anspOliatiOI1 by Sea (40 ft. or 20 ft. Container) 

o 	 Name and Address of the Importer: 

Name: 

Company Name: Korea Pyongyang Trading U.S.A. Inc 

Company Address: 98 Thayer Street, Suite 1 B 

New York. NY. 10040 

e-mail: 

Tel: 

fax: 	

o 	 Name and Address of the Exporter: 

"" Name: 

Address: 	

Pyongyang, D.P.R. of Korea 

2012-08-244:North Korea:JW:000058 (b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) (b)(6) 

(b)(4) (b)(4) 

(b)(4) 

(b)(4) 

(b)(4) 
Korea Pyongyang Tradins USA, Inc, 

98 Thayer Si'tet, Suit.. I B 

Tel: 

Fax: 

E-mail addresses: none 

o 	 'Kame and Address Qfthe producer oftlle product: 

Company name: Korea Daedonggang Brewel'Y , 

Person in charge: 

Company Address: SOllg~in i-dong, Sadong District 

Pyongyang, D:P.R. of Korea 


Tel: 

Fax: 

E-mail addresses: ' , none 


0, Name ofthe IpcatiQn where the product was produced. 

Company name: Korea Daedonggang Brewery 

Person in charge: 

Company Address: Songsin 1-dong, Sadong District 

Pyongyang. D.P.R. of Korea 


Tel: 


Fax: 


E-mail addresses: none 


Products to be imported were not produced by 

(a) a foreign 'person designated by the Secretary of State as having engaged in missile 

technology prolifel;a.tion activities; 

(b) an activity of the North Korean Government relating to the development or production of 

any missile equipment or technology; or , ' 

(0) an activity of the North Korean Government affecting the development or production of 

electronics, space systerns or equipI1'l:ent, and mj\itary aircraft. 

We much appreciate your attention to this matter and look forward to your expedited , 

processing of our request. 

Very truly yours, 

2012-08-244:North Korea:JW:000059

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(6) (b)(6) (b)(6) (b)(6) 
KOREA PYONGYANG TRADING USA, Inc. 

98 TH~YER STREET! #1Bt NEW YORK, NY ~OO40 

Tel: Fax:

January 29,2010 

Via Facsimile 


. 202-622-1657 


Total: 3 Pages 


North Korea Unit 


Licensing Division 


OffIce of Foreign Assets Controi 


U.S. Department oftlle Treasury 


1500 Pennsylvania Avenue N.W. Annex 


Washington, He: 20220 


Re: 	 Request for Review and Approval ofImport. 

Daedonggang Beer, Product ofNorth Korea CD. P. R. ofKorea) 

Dear Sir or Madam: 

My name is ofKorea Pyongyang Trading USA Tnc., doing business as 

Korea Pyongyang Trading USA (hereinafter referred as "KPTU'). KPTU 1S an importer 

and exporterHke any other but we do business with North Korea. 

Pursuant to the compliance with provisions ofthe Arms Export Control Act, 22 U.S.c. 


2751" et seq. (the "AECA"), we are seeking for an authorization to import Da~donggang 

Beer (hereinafter, the Beer), produced in North Korea (D. P. R. of Korea), to U.S. 


We respectfully request for an approval to import the Beer from North Korea. Following 


are the information about proposed impOlt: 


• Importer:. 

Name: 

Company Name: Korea Pyongyang Trading US.A. Inc 

Company Address: 98 Thayer Street, Suite lB 

New York NY. 10040 

e-mail: 

Tel: 

Fax: 

2012-08-244:North Korea:JW:000060

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C) (b)(6) (b)(6) (b)(6) 

(b)(6) & (b)(7)(C)
Kor~a Pyongyang Trading USA, Inc. 

98 Th~),¢f Street, Stlito 18 

• Description of the product to be impo11ed (initial): 

o Chemical Composition of Ingredients: 

Q List of Material(s) Product: 

o 	 Means Transportation: 

Transportation: 'by Sea (40 ft. or 20 ft. Container) 

Quantity: 

o 	 Packing Style: 


1 Carton Boxi20 Bottles 


o 	 Import Unit Value: 

o 	 Import of Tota! Amount: 

• 	 Name and Address ofthe producer of the product 

Company nam.e: Korea Daedonggang Brewery 

Person in charge: 

Company Address: Songsjn I-dong, Sadong District 

Pyon.gyang. D.P.R. ofKore.a 

2012-08-244:North Korea:JW:000061

(b)(6) & (b)(7)(C) (b)(6) 

(b)(4) (b)(4) 

(b)(4) (b)(4) 

(b)(4) (b)(4) (b)(4) (b)(4) 
Korea"Pycmg)'<lIIg Trading USA, IlIc" 

9S Thayer St{cct, Suitt; lB 

Tel: 

Fax: 

E~mail addresses: none 

• 	 Name of the location where the product was produced. 


Company name: Korea Daedonggang Brewery 


Person in charge: 

Compauy Address: Songsin I-dong, Sadong District 


Pyongyang. D.P.R. of Korea 

Tel: 

Fax: 

E-mail addresses: none 


• 	 Exporter: 


Name: 

Address: 

Pyongyang. D.P.R. of Korea 

Tel: 

Fax: 

E-mail addres~es: none 


Products to be-impolted were not produced by 

(a) a foreign person designated by the Secretary of State as having engaged in 

missile technology proliferation activities; 

(b) an activity of the North Korean Govenunent relating to the development or 

production of any missile equiptn.ent or technology; or 

(c) an activity of the North Korean Govemment affecting the development or 

production of electronics, spape systems or equipment and. military aircraft 

'Ve much appreciate your attention to this matter and look forward to your expedited 

processing of our request. 

Very tiuly yours, 

­

President 

KPTU 

2012-08-244:North Korea:JW:000062

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(6) 

(b)(6) (b)(6) (b)(6) 
DEPARTMENT OF THE TREASURY 
 il~~: WASHINGTON., Q,C, 20220 
 \~'G'~' '" ..Q~~.. ~'" 

Case No, NK·93078 

Akennan Senterfitt 


One Southeast Third Aveune 


25th Floor . 

Miami, FL 33131-1714 

Dear

This is in response to your letter dated December· 8, 2008 (the"Application"), to the 

Office of Foreign Assets Control ("OFAC") requesting pennission of behal f of

to purchase not more than 100 grams ofColumbite ore from Korea Undok 

Trading Company, Ltd., a North Korean entity. While the Application states that the 

purchase'would be made by a third-party analytical laboratory not located in the United 

Slates, the Application does not state whether the intention is to import the ore into the' 

United States. 

The Application references Executive Order 13466 and 31 C.F.R. 500,586(b)(2) and 

(e)(3) as support for the request. Subsequent to the issuance of the Executive Order, on 

July 21, 2008, OFAC continues to conduct case-by-case authorization ofNorth Korean 

imports in order to ensure compliance with provisions of the AnTIS Export Control Act, 

22 U.S.c. § 2751 et seq. (the "AECA"). Persons wishing to import goods from North 

Korea must submit infonnation and receive prior authorization to import North Koreanorigin goods, 

Pursuant to your Application, OFAC denies authorization to import the quantity 

of CQlumbite ore referenced in the application due to proliferation concems with 

regard to the identified exporter. Should your client identify a new exporter, you 

may submita revised request to OFAC for review, 

If you ha've ::my addit,ional questions '?bout the U.S. economic sanctions programs 

administered by OFAC, you may refer to our website at ~~w.treas,gov!ofat; or 

call our office at (202) 622-2480. 

Sincerely", 

~~~ 1/;~//!L Clara Y. David 

Chiet~ TWEA Licensing Section· 

Office of Foreign Assets Control 

2012-08-244:North Korea:JW:000063

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)
( I 3053745095 T-SS4 P,04/0S Job-SSS '&IMR-tlS-09 ,'4:17 FrD/II:AKERM.4.N SENTERFITT 

ron Lauderdale A"" SQ~' Third ","vIm•• 

luclt$onvilll: 25th floor' 

L&Ansclcs Miami. Florida 331.31-1714 

M~d~ , www.lIkcrman.cllm Mi.tmi 

N~w Yor1c lOS 374 5600 ,.[ lOS ]14 SO!>Sjia 

Orlando 

To.llllhllS," 

'tAmpa 

TysonsComu 

WllilhinlllOl'l. DC 

Won Palm Buell 

December 8,2008 

North Korea Unit, Office ofForeign Assets Control, 

U.S. Department ofthe Treasury 


1500 Pennsylvania Avenue, N.W. AIUlex 


Washington, DC 20220 


Re: ,Proposed Purcbase from North Korea 

Dear Sirs: 

Pursuant to' the prodamation of June 26, 2008, Executive Order 13466. and 31 C. F. R. SOO. 586 

(b) (2) and (e) (3). following is a request for authorization to purchase certain goods from North 

Korea. 

The underslgned represents a U.S. citizen. who is regularly engaged in 

the business of trading in niobium (Nb) and tantalum (Ta) and their aUoys. 

hereby :requests authorization to purchase from a North Korean entity a small quantity (not more 

than 100 grams) of Columbite ore, for purposes of testing and determining whether commercial 

quantities of the product may be purchased at affordable prices. The proposed initial purchase 

would be made through a third party analytical laboratory not located in the U.S. 

Columbine.ore is a Ta and Nb bearing ore, with the major sources being Brazil and Nigeria. 

Typically, in the West. such ore runs 5 - 6%. Ta205 and 50 - 60% Nb20S (c.g., 10:1 ratio after 

proper mineral dressing). In comparison, the ore from Pyongyang was said to run 5 - 6% TalOS 

and 40 - 45% Nb205. although the Koreans admitted they needed better technology for 

upgrudingand wanted approximately $3 million in investments to do so. To put North Korean____ 

production into JlersRective,.Jhe_North-Koreans-elaim-·a-current-m·ontilly proauciion of 20,000 

--------metnc .tons of Columbite ore, which might yield approximately 25,000 pounds Ta205/per year 

and approximately 100 metric tons Nb205/per year. It is estimated that the total world supply of 

these metals this year will be in the vicinity of 6,000.000 pounds for Ta20S and approximately 

100,000 metric tOns for Nb20S. 

Ta has a variety of uses, primarily in electronics, such as for capacitors and sputtering targetS. 

with well under 5% being for military applications. Nb also has a wide range of applications 

[Ml'l56502: II 

2012-08-244:North Korea:JW:000064

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)
• IMR-OS-09 l.h\ T Ftom;AKERIMN SENTERFtTT 3053T4S09S T-SS4 P.OS/05 Job-SSa 

North Korea Unit, Authors of Foreign Assets Control 


December 8,2008' 


Page 2 


primarily as a microalloying elements in stee], with probably less than 1% in military 

applications. Please note that a substantial amount of processing. is required to convert the ore to 

a final military product. which', obviously. this purchaser would not intend til undertake. Prices 

for Columbite ore are currently approximately the US$16 - $18llb. In comparison. prlces for Ta 

and Nb metalcaneasily be well above, S100 per lb. 

The North Korean entity from which the product would purchased is: 

Korea Undok trading Co, Ltd. 


Uiamdong, Taedonggang Dist. 


Pyongyang DPRK. 


The Individual from North Korea, who made the contact with my client was: 

who is based in Shenyang People's Republic ofChina. 


mobile telephone number: 

e-mail: 

Please call the undersigned ifyou have any further questions. 

Very truly yours, 

, AKERMAN SENTERFITT 

2012-08-244:North Korea:JW:000065

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(6) 
Mystic Stamp Company, Inc. 

9700 MiII Street, Camden, New York 13316 

America's Leading Stamp Dealer June 25; 2012 

North Korea Unit 

. Office of Foreign Assets Control 

US Department of the Treasury 

1500 Pennsylvania Avenue 

NW Annex 

Washington, DC 20220 

To Whom It May Concern; 

Weare currently on file with you for case #NK93107. We were previously granted a 


license to import postage stamps from the Korea Stamp Corporation in North Korea. Our last 


license expired as of June 4, 2011. 


InJuly 2011 we attempted to acquire another license to import postage stamps from the 

Korea Stamp Corporation. On June 6th, 2012 our request for license was denied. 

"Can y(Hl'~lease provide information on the following: 


':.' . What process needs to take place in order to appeal this recent decision? 


- . 'Ate there any restrictions to reapplying for a license? 


" 1...' ~~: w~;:Zmport North Korean stamps from a country other than North Korea? 
 r~ • . .; , 

.'!" As 'Ameridi,,* 'ieaa~n:g :stamplProvider,rproviding these stamps ate an integral part of 

our promise to customers. Our customer base is primarily postage stamp colleCtors. The purchase 

could benefit hundreds of stamp collectors across the United States. Stamps are a great source of , ~ '\ . . inforriuitional material that we are looking forward to supplying to our valued customers. 

We respectfully request permission for import . 

• J • I , :,"." ',",' .. : " ! i ~ . 

: :. • .:. r : " 

"1,. ' l •• :r I" -t· ':. ,: ::::; 

,J', r ". '. '. tj • !:~"" 

. Mystic Stamp ComiJl:inY~BUyi'ng:and;Irl.ventory Control' .', "'r.~.r . ".;. : . ~ .. ';:.';. f,' :. 

9700 M1HStreet' '!.':~ : > ,'(;'! . ./.1':' :"'!:..j ·r·.: I;J:: ':. .•.. ·,.:r:, 

Camden/:NY 13'316'· j~'.~':",; >.... ~j::"~" , :~..-." , I~r~:; (II "f( -. >\.r.~ ..·~ j'! ;". ,.·i!. J .. 'd< ",' ,!::: :. ...t. ':J !'~:1 

!: ..'l· "J !i..:'·' ;' L' 


. . 
 '!'j:!, ;' )~j '; ';~;.: "i:" :,£11:5 f. E 

:;, I.;J!n:-,i:( :.UL P!:;,!!·';G ;/:1.-: (I~!l!(l" 

. , : :' . 

0· FAX 315-245-0036 


2012-08-244:North Korea:JW:000066

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C) (b)(6) (b)(6) 
" 

Inter-Governmental Philatelic Corp. 

460 WEST 34 STREET • NEW YORK, N,Y. 10001 

TEL: {2121 629·7979 • FAX: (212) 629·3350 

WWW.IGPC.NET • EMAIL: INFO@IGPC.NET 

. August 9, 2010 

.	Ms. Clara Y. David 


Cillef, T\XlEA Licensing Section 


Office of Foreign Assets Control 


Department of the Treasury 


Treasury Annex 


1500 Pennsylvania Avenue 


Washington, DC 21220 


Dear Ms. David: 

We have been contacted by Mystic Stamp Company with regard to purchasing stamps from North 

Korea, 

We understand that they received a letter from you giving them permission. As we are regular 

supplier!l to Mystic Stamp Company of foreign stamps from many countries, we would like to ask 

you to give us permission to purchase from the North Korean Post OfflCe stamps from them for us 

to supply to Mystic Stamp Company. To date we have never imported anything from North Korea. 

Looking forward to receiving your positive response. 

Inter-Governmental Philatelic 


Corporation, New Yonk 


Enclosure - Copy of letter to Mystic Stamp Company 


cc: 

2012-08-244:North Korea:JW:000067

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)
DEPARTMEIIJ) OF THE,.1RE,ASURY 

WASHINGTON, D.C. 20220 

Case No. NK-93087 

Mystic Stamp Company 


9700 MiU Street 


Camden, NY 13316 


. Dear

This is in response .to yow.: letter dated June 2009 (the "Application"), to the Office of Foreign Assets 

Control ("OF AC") requesting pennission to import unused postage stamps from the Korea Stamp 

Corporation iIi North Korea. 

OF AC is required to conduct cnse-by-case authorization ofNorth Korean imports in order to ensure 

compliance with provisions ofthe Anns Export Control Act, 22 U.S.C. § 2751 et seq. (the "AECA"). 

Persons wishing to import good~ from North Korea must submit infonnation and receive prior 

authoriwtion to import North.Korean-origin goods. ' 

Pursuant to your AppliGation, OFAC hereby authorizes Mystic Stamp Company to import 

unused postage Stamps from the Korea Stamp c:orporation in North Korea. This authoriwtion to 

. import North Korean-origin postage stamps is valid for a period ofone year from the date ofthis 

letter:.'and may be revoked o~'modified at any time at the discretion of the Secretary of the' 

'. Treasury or his duly'appointed. agent.' .: . . 

Ifyou have any additiona!'questions about the economic.sanctions programs administered by 

OFAC, you may refer to ourwehsite at ~.treas.gov/ofac or call our office at (202) 622-2480. 

Sincerely, 

·ClaraY. David: 

. Chief, TWEA Licensing Section 

Office.ofForeign Assets Control 

2012-08-244:North Korea:JW:000068

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)
N0rth Korea Unit June 2009. 


Office of foreign Assets Control 


US Department of'the Treasury . 


1500 Pennsylvania Ave. 


NWAnnex 


Washington, DC 20220 


Dear Sirs; 


We have noted on the United States Department of Treasury website that 

permission ml:lst be granted to have goods of North Kmean Origin shipped to the United 

States. 

We would like to request permission to import approximately 1000 sets of unused 

postage stamps issued from 2007-08 from the North Korean Post, which we will sell to 

stamp collectors. I estimate the cost of these stamps to be under $75,000. 

The stamps originate from the Korea Stamp Corporation. The Korea Stamp 

Corp0ration accepts and delivers mail within North Korea, in the same fashion as the 

United States Postal Service does here in the U.S. 

To the best of our knowledge, the Korea Stamp Corporation is n0t engaged in 

missile technology proliferation activities, or any activity relating to developing or 

production- of any missile equipment or technology. The Korea Stamp Corporation is not 

engaged in any North Korean Government activity affecting the development ·or 

production of electronics, space systems, or equipment of military aircraft. 

This purchase CQuid benefit hundreds of stamp collectors across the United 

States. We respectfully request permission for import. Piease send the· permission 

documentation to my attention. . 

Thank "you, 

Mystic Stamp Co. 

2012-08-244:North Korea:JW:000069

(b)(6) & (b)(7)(C)
12/2312009 

POBox 572 

Harrogate, TN 37752 

Phone: 

Fax.:

Email: 

Office ofForeign Assets Control 


l!.S. Department ofthe Treasury 
 TREASURY DEPARTMENT Treasury Annex RECf:~\!En 1500 Pennsylvania Avenue 


Washington, DC 20220 JAN 06 2a~a 

Attention: Licensing Division 
 FOREIGN ASSETS CONTROL 

Re: Proposed Transaction 

Dear Sir or Madam, 

. I am writing to request a license for a single transaction to purchase an item which is 

produced in North Korea. The item in question is a pair ofjeans manufactured by Noko 

Jeans in conjunction with a Pyongyang manufacturing facility. Noko Jeans ina Swedish 

company and I believe the product ships from Sweden. The cost is approximatc;:]y U.S. 

$220.00. I hope to purchase this pair ofjeans for my wife whose father is originally from 

North Korea and escaped tQ the South just before the Korean War. 

More information is available at www.nokojeans.com 

Thank you in advance for your he1p in this matter. 

Sincerely, 

2012-08-244:North Korea:JW:000070

(b)(6) & (b)(7)(C) (b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)

(b)(6) (b)(6)
H. D. HUDSON MANUFACTURING COMPANY 

500 North Michigan Avenue· Chicago, IL 60611·3769- USA 

Phone: (312) 644·2830 • Fax: (312) 644·7989 - www.hdhudson.com 

j J : I 	 ., - March 30,2010 

Jodi Kouts 


Office of Foreign Assets Control 


Department of the Treasury 


1500 Pennsylvania Avenue N.W. 


Washington, D.C. 20220 


Attn: 	 licensing Division 


Jodi L. Kouts. Assistant 


Director for Licensing 


Please letme know if we are permitted to sell Hudson® X-Pert® Sprayers into 

North Korea for humanitarian purposes. 

Sincerely, 

, . .', .

Senior Vice President and 
 ','2~~~,j Corporate Secretary 


-.­

2012-08-244:North Korea:JW:000071

(b)(6) & (b)(7)(C)
./

./ 

.' 

304 E University Ave 

Georgetown, TX 78626 

19 June 2008 

Office ofForeign Assets Control 

US Department of the Treasury 

Treasury Annex 

1500 Pennsylvama Avenue" NW 

Washmgton, DC 20220 

Sirs. 

Per your Instructions on your website, I am wnttng to obtam penmssion from OF AC to Import 

Items for resale from North Korea (DPRK) , 

I wish. to Import purely consume'r Items such as pamtIngs, ceramIcs and beer for resale to people 

around the world, in~ludtng US cItIzens, VIa a website. ' 

Could you please advise me on the necessary steps to seek OF AC approval for this 

2012-08-244:North Korea:JW:000072

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C)
To Whom it may Concern, 

I was tord I needed to apply for a general license in order to purchase a pair of jeans produced 

in North Korea. These are the details of the transaction that I would like to complete. 

I would like to purchase one pair of sized 32/32 jeans from http://nokojeans.com for 1500 SEK. 

The Company is NOKO Jeans. The contact information listed is: info@nokoieans.com, and 

press@nokojeans.com. The company shipping the jeans would be based out of Sweden, 

with contact information provided as: 

Varroftagatan 47 J 1827 Stockholm. Sverige 

Thank you for your time, 

2012-08-244:North Korea:JW:000073

(b)(6) & (b)(7)(C)
----------------,~,-

To Whom It May Concern, 

".q, i~', ,:,' '~I" , . ,J. "'I will be traveling to the Democratic People's RepUblic of Korea at the end 

of September 2008 on a tourist Visa. I was put in contact with one of the OFAC 

~. " ... ,...••, " .' .", ~'. ',"','.' ... :;'f!'.~.f:~;} • ;' ,. ", ..:: ~. 

'representatives who instructed me to submit a. reque'st for cI'n import review, 

. • ." , '. . ". ",:: !~.: .. ~, ,. 

have read the North Korea summary of sanctions from the OFAC website. 

However, since ~y 'visit will'bonsist s~lely o'f tc;urism, 'I do not at this prese'nt time 

,', '" :" 

know what items I will be bringing into the United States. 'am planning on 

bringing back small-scale tourist items such as t-shirts, postcards, books, and 

other stationery articles.' However, I do not expect my trip will incur more than 

'" 10~15 ot'these small items, not totaling more than'$40-$50 USD. I want to ", 

'f "'\ • • , •• 

formally submit this request for an import 'review from North Korea, and thank 

l' "~~" .. ,~ •••.:.... :., •.(,j' ... ~.' -.' :'" . . i' . " • :.' ",: :":>:,:'" . ': 

youihadvance for considering my request. I patiently await your response .. 

, . , .'. 

_ y, "Baptist University 

, 713 

3000 Mt. Creek Parkway 

Dallas TX, 75211 

Fax: (918) 341-2769 

Daytime Phone: 

2012-08-244:North Korea:JW:000074

(b)(6) & (b)(7)(C)

(b)(6) & (b)(7)(C) (b)(6)