FinCEN published its final North Korea special measure on November 9, 2016, with an effective date of December 9. The earlier proposal appeared June 3. That chronology matters: the final action completes an identifiable regulatory process, and its publication date should not be treated as evidence of an election-related motive or immediate implementation. [2016-27049][2016-13037]

The operative text separates two account restrictions. Covered financial institutions may not maintain or open a U.S. correspondent account for or on behalf of a North Korean banking institution. They must also take reasonable steps not to process a transaction involving a North Korean financial institution through a foreign bank's correspondent account in the United States. [2016-27049]

The June proposal explained the anticipated implementation burden in terms of notices to certain account holders and screening that institutions already performed. The final text specifies minimum diligence and further risk-based measures. Notifications concern foreign correspondents the covered institution knows or has reason to believe serve a North Korean financial institution. This is a defined duty, not an instruction to notify every customer about their nationality. [2016-27049][2016-13037]

The rule also requires documentation of notice compliance without adding reports beyond those otherwise required by law or regulation. It is not a stand-alone description of all sanctions or a universal trade prohibition. These two primary documents are stages of the same FinCEN proceeding, not independent evidence of enforcement outcomes. At the coverage date, they establish scope and timing, not how many transactions would ultimately be prevented. [2016-27049][2016-13037]

Source documents

  1. Imposition of Special Measure Against North Korea as a Jurisdiction of Primary Money Laundering Concernhttps://www.govinfo.gov/content/pkg/FR-2016-11-09/html/2016-27049.htm
  2. Imposition of Special Measure Against North Korea as a Jurisdiction of Primary Money Laundering Concernhttps://www.govinfo.gov/content/pkg/FR-2016-06-03/html/2016-13037.htm