On January 6, 2016, North Korea announced that it had successfully detonated a “miniaturized hydrogen bomb,” its fourth nuclear test in 10 years.
Thousands of North Koreans gathered in Pyongyang two days later to celebrate with a mass rally and dance in Kim Il Sung Square. That it was also Supreme Leader Kim Jong Un’s 32nd birthday may or may not have been a coincidence; a giant fireworks display exploded overhead.
The rest of the world was less jubilant. The United Nations (UN) Security Council “strongly condemned” the test and promised to impose tough new sanctions on the rogue state. The U.S. said it would “not accept” North Korea as a nuclear state. Then in March, the UN imposed new sanctions on North Korea in an attempt to help stop the regime’s pursuit of weapons of mass destruction. On top of that, the U.S. and Europe levied their own bilateral sanctions, adding up to the harshest penalties yet.
Among those navigating around the tightened sanctions are the assorted humanitarian organizations that operate inside the DPRK. Over the past several months, news reports have painted a dire picture of a humanitarian community bereft of funds with which to help feed the hungry and care for the sick as an unintended consequence of overly broad sanctions. According to the UN’s latest country report, roughly 70 percent of North Korea’s population of 24.9 million are food insecure, with 10.5 million people classified as “undernourished.” But while the sanctions certainly don’t make things any easier, those on the ground in North Korea say they’re not necessarily the primary cause of their difficulties.
CASH IS KING
Interviews with foreign aid workers posted in Pyongyang and U.S. government officials close to the issue reveal a situation on the ground that is highly nuanced and decidedly non-binary.
One American NGO worker, who spends weeks at a time on aid missions inside North Korea, said the UN agencies with offices there “appear to really be taking a bite.” A TB prevalence survey being carried out by the World Health Organization is at least two years behind schedule, claimed the aid worker, and is currently stalled because the agency doesn’t have “the money to buy the gas and pay the guides and pay the health staff to go out and do it.
“Meanwhile, we know that TB is exploding in North Korea, we have to find hotspots but there is no way to do that without money on the ground.” (The UN declined to comment for this article; a spokesperson would say only that they are “working on a solution.”)
The aid worker isn’t particularly comfortable carrying large amounts of cash into the country; theft in transit, accidental loss, or trouble at customs are a constant concern. But, “there is no other way to cover in-country expenses,” the aid worker said. “I also ask each team member to bring some cash, just so I’m not carrying this great big wad. It’s safer to split it up.”
Others, however, don’t necessarily find it a struggle to abide by the sanctions and carry out their work. A staffer with a European NGO resident in Pyongyang confirmed that while procurement by UN agencies has been delayed at times due to the new round of restrictions, “Sanctions so far have had no untoward effect on our operations. Our procurement is so far on time, with no delays from our suppliers.”
“We continue to carry cash from headquarters whenever our expatriates visit [our main] office,” continued the aid worker, who asked for anonymity due to the sensitivity of the situation. “[The main office] also has a practice to pay our suppliers directly [from the agency’s home city in Europe], which is helping us in lessening our burden to carry more cash into the country. But there has been always scarcity of funds, even before the current sanctions, as we have to wait until someone is bringing cash from HQ.”
The North Korean government requires foreign aid agencies to utilize the regime’s Foreign Trade Bank, which was designated as a sanctioned entity by the U.S. Treasury since 2013
Dealing in cash is a technique generally off-limits to UN agencies, which are for the most part bound by much stricter guidelines. The North Korean government requires foreign aid agencies to utilize the regime’s Foreign Trade Bank, which was designated as a sanctioned entity by the U.S. Treasury since 2013 for serving to “facilitate transactions on behalf of actors linked to its proliferation network.” The Industrial and Commercial Bank of China reportedly began freezing North Korean accounts last December, and in May, the Russian central bank is said to have told all Russian financial institutions to cease their dealings with North Korean agencies, organizations, and individuals on the UN Security Council sanctions list. A Russian presidential decree will also take effect soon to close North Korean bank branches and joint venture firms.
Nevertheless, the European aid worker said, “One Russian bank accepted to work with the Foreign Trade Bank of DPRK through which the funds seemingly get transferred to UN agencies here, although this takes some time.”
This was corroborated by others in the field, identifying the institution in question as a small bank in the Vladivostok area. The fees are higher than usual, given the circumstances. But the arrangement doesn’t violate U.S. sanctions, which do not prohibit foreign financial institutions from establishing and maintaining correspondent accounts used specifically for conducting humanitarian transactions in North Korea.
In fact, American sanctions include a specific exception that allows banks to facilitate legitimate humanitarian transfers to North Korea, points out Ambassador Robert King, the U.S. State Department’s Special Envoy for North Korean Human Rights Issues.
While drafting the latest round of sanctions, King said he and his colleagues consulted with various American NGOs, along with representatives from the Treasury, Commerce, and State Departments, to listen to their concerns and make sure their programs wouldn’t be interrupted. From this emerged General License No. 5, which is attached to President Obama’s March 2016 Executive Order, which explicitly allows for humanitarian activities in North Korea.
American sanctions include a specific exception that allows banks to facilitate legitimate humanitarian transfers to North Korea…but most banks avoid engaging in transactions with even the slightest whiff of North Korea
Still, King admits that most banks avoid engaging in transactions with even the slightest whiff of North Korea. The scrutiny from regulators is intense, and the cost of a violation – which can include not only massive fines but being cut off from the wider global banking network – far outweigh the small revenues attached.
“Banks don’t want to risk their reputation or getting into trouble with our banking regulators,” King said. “There’s more caution than there might be with other countries; a lot of banks have dealings with American banks, and we have very tight rules in terms of applying sanctions.”
Of course, there are workarounds. International staff salaries can be deposited in employees’ accounts abroad, and food, medicine, and equipment to be brought into North Korea is paid for before it ships, thus, “That money is never going to actually enter North Korea,” explained Jerome Sauvage, who was the United Nations Development Program’s (UNDP) resident coordinator in Pyongyang from 2009 to 2013. The money that does enter North Korea goes mainly toward in-country expenses, including local staff salaries, which is where things get a bit dicey.
After a scandal in 2007, which found the UNDP’s cash controls in North Korea severely lacking, the agency was temporarily shut down by UN administrators. At one time, workers’ salaries were paid to the North Korean government, in euros, by check or wire transfer, after which employees would be given a small portion of the total. When the UNDP office in Pyongyang reopened two years later under Sauvage’s supervision, it was ordered to pay local staff in North Korean Won so as to avoid giving the regime any additional access to hard currency. Sauvage said they followed the rules to the letter, transferring salaries into specially-designated accounts at the Foreign Trade Bank (FTB) through the Bank of China, which cut ties with the FTB in 2013.
A REGULATORY MINEFIELD
Keeping one’s operations above board in North Korea means navigating rules that extend far beyond the already-byzantine financial guidelines. For instance, if an item being brought into North Korea contains more than 10 percent American-made content, it requires an export license from U.S. authorities.
“We presented every computer, even Chinese computers, to OFAC, because of ‘Intel inside,’” said Sauvage. “It delayed things for months. And you’d end up in the craziest situations. We bought a Ford made in China, and we had a letter from the Ford company that said, ‘Nothing in this car is made in the United States.’ Imagine that.”
Disposing of that same equipment is also highly regulated, so the North Korean regime can’t take possession of any technology that could be used for military purposes. Sauvage said he and his team brought all the computers they took into the country back out again when they left, getting rid of them in a third country.
If an item being brought into North Korea contains more than 10 percent American-made content, it requires an export license from U.S. authorities
The dos-and-don’ts are extraordinarily complex. And for all the detail, there remains a lack of clarity in certain areas that can be frustrating, said Bernt Berger, director of the Engagement Policy Center in Berlin.
“If you want to support positive trends, economic buildup and decentralization, you need people who have skills,” explained Berger, who has worked on a number of capacity-building projects in North Korea over the years. “But you never know exactly what’s forbidden training under the sanctions, and that’s quite tricky.”
Few individuals do have a full handle on the finer points of the sanctions, and that includes lawmakers. A U.S. aid worker who runs extensive programs in North Korea recounted spending many hours “educating” elected officials on what their decisions on sanctions implementation could mean for the NGO community working there. During the most recent ratcheting-up of sanctions, there were “two or three provisions being considered to the draft versions, that if passed as-is, would have stopped our work,” said the aid worker, who asked to remain anonymous.
“Even though they had humanitarian exemptions written in, they had provisions like, no U.S. NGO could have a relationship of any kind with the North Korean government,” the aid worker continued. “Well, we work with the Ministry of Public Health, we work with KCCA (Korean Canadian Cooperation Agency), and a whole bunch of others. Those are all North Korean government entities, so that right there would have stopped everything, even though it was unintended. We were able to get the word out to our Congressmen and Senators, and thankfully, the final version of the House bill stripped out those really sensitive provisions.”
Shipping anything other than food or medicine from the U.S. to North Korea requires a license from the Treasury and Commerce Departments. Certain items can be purchased in China, which go to North Korea by train or truck, and don’t require extra disclosures. It’s all perfectly legal, although the aid worker said, “We make sure not to put ‘DPRK’ or ‘North Korea’ on the memo line. You call it your ‘hepatitis program,’ or your ‘agriculture project,’ or something else, but you certainly do not use the words ‘DPRK’ or ‘North Korea,’ unless you want the wire to be stopped and you get asked a thousand questions and fill out a ream of paperwork.”
International monitors have tried, with varying degrees of success, to keep pace with the North Korean government’s financial bobbing and weaving, says George Lopez, the Hesburgh Professor of Peace Studies Emeritus at the University of Notre Dame, and a former member of the UN Panel of Experts on North Korea.
Some of the regime’s financial schemes are detailed in the most recent Panel of Experts report, released in February 2016. It cites a combination of “aliases, agents, foreign individuals in multiple jurisdictions, and a long-standing network of front companies and embassy personnel” as what allows North Korea continued access to the global banking system, sanctions notwithstanding. Money is often laundered by cooperative non-North Koreans, who use “indirect payment methods and circuitous transactions dissociated from the movement of goods or services to conceal their activity.”
The Panel’s previous investigation identified the Director of the International Relations Department for the Korean United Development Bank in Pyongyang, Kim Su Gyong, as having been “engaged in financial activities under false pretenses in order to conceal the involvement of her country.” According to the Panel, Kim was colluding with undercover agents from North Korea’s Reconnaissance General Bureau, the country’s clandestine intelligence service, operating abroad. Two undercover operatives — Kim’s father, Kim Yong Nam, and her brother, Kim Su Gwang — were found embedded as ordinary civil servants at, respectively, UNESCO headquarters in Paris and the World Food Programme in Rome.
North Korean diplomats and trade representatives also play “key roles in facilitating the trade of prohibited items, including arms and related materiel and ballistic missile-related items,” according to Panel investigations.
In one case, three North Koreans traveling on DPRK service passports — travel documents issued to officials other than diplomats — were detained at an unnamed Southeast Asian airport in 2014 for failing to declare $450,000 in cash. The Panel said the money was “suspected to be proceeds from an arms transaction,” though the group “could not be charged under any domestic laws of the Member State A,” and the trio was released.
“From my experience on the Panel of Experts, it was foreign embassies who really got pissed off about the sanctions…Once luxury goods were banned, they couldn’t bring in scotch, or caviar, and so forth”
At the same time, UN agencies, NGOs, and any private companies doing business with them must abide strictly by the rules. And although shipments have been delayed or prevented due to individual country laws, or skittish private companies unwilling to take the legal risk of dealing with North Korea, the Panel “has been unable to find incidents in which bans imposed under the [UN] resolutions directly resulted in shortages of foodstuffs or other humanitarian aid.”
“From my experience on the Panel of Experts, it was foreign embassies who really got pissed off about the sanctions,” said Lopez. “Once luxury goods were banned, they couldn’t bring in scotch, or caviar, and so forth. At my first meeting, I asked, ‘Why are the Russians so upset about humanitarian impact?’ And my colleague leaned over and said, ‘Because we restricted the amount of vodka that could go to their Pyongyang embassy.’”
There are people who believe there wouldn’t be a food problem in North Korea if it weren’t for sanctions, though Lopez said he sees this as a specious argument.
“You do hear a lot of bombast from the aid agencies, which I think is a way for them to make sure they get into North Korea the next time,” he said.
In reality, it’s important for aid workers to be there, maintains Jerome Sauvage. The relatively small amounts of money being spent on humanitarian projects can’t be held responsible for propping up the regime, and no matter what the ever-tightening sanctions might lead some to believe, Sauvage thinks that the U.S. and European powers-that-be truly want foreign aid workers to remain in North Korea.
“They have eyes on the ground, local knowledge of what’s going on, and they keep open a sort of ‘third-track’ discussion,” said Sauvage. “Plus, the proposition that North Koreans should just starve is not realistic, because the day Korea is unified, you’ll have a severely under-capacitated population. You’ve got to keep North Korea’s population somewhat afloat, otherwise it will be a disaster with a lot of implications for the region.”
“The relatively small amounts of money being spent on humanitarian projects can’t be held responsible for propping up the regime”
DONOR FATIGUE AND INEFFICIENCIES
According to Sauvage, getting money into North Korea is less of a problem than getting enough money in the first place.
“The context we are working in is, ‘Are we going to stay in North Korea, yes or no?’ Monitoring and evaluation is a constant battle, the human rights situation is a major issue from the perspective of the UN, there are people in the international community who think we should just end the presence of the UN in North Korea,” said Sauvage. “So, rather than fighting to improve the situation, we’re barely hanging on, explaining why it’s worth it.”
Indeed, “There are other very sympathetic causes to contribute to: Syria, Sudan, and so forth,” said Ambassador King. “With North Korea’s activities and the way it has appeared internationally — the missile testing, the kinds of attitudes that have been expressed [when responding to] human rights criticism — it becomes the kind of place that makes people say, ‘I don’t want to give money to them.’”
“With North Korea’s activities and the way it has appeared internationally…it becomes the kind of place that makes people say, ‘I don’t want to give money to them’”
The numbers do reveal a yawning gap between how much the UN aid agencies say they need and how much they actually have to work with.
In 2013, per UN data, the five agencies resident in North Korea — the World Food Program, UNICEF, the World Health Organization, the United Nations Population Fund (UNFPA), and the Food and Agriculture Organization (FAO) — asked for a combined total of $150,090,000. They received $72,349,425, or, less than half of what they requested.
In 2014, the five UN agencies asked for $115.3 million, of which they got $48.2 million, or, about 42 percent.
In 2015, the UN agencies operating in North Korea got $18.8 million of $110.8 million requested, or, 17 percent.
This year, those same five UN agencies requested $116.7 million of which they received $28.3 million, or, 24 percent of their total ask — a slight improvement over 2015, but still a severe shortfall.
There have been signs of improving harvests and glimmers of a market economy beginning to emerge in North Korea, and the elites of Pyongyang are largely unaffected by shortages of any kind. Thus, according to the Congressional Research Service, any malnutrition problem that exists “is likely due less to food shortages and more to inequities in the distribution system and governmental priorities.”
The price of rice in North Korea soared in 2010, when mass hunger reappeared in the country. Today, rice prices in Pyongyang are stable, suggesting that food insecurity may not be as bad as it once was. In other words, “We are feeding people that the regime won’t feed; we are helping people who wouldn’t be helped otherwise,” says Andrew Natsios, former USAID administrator and author of The Great North Korean Famine (United States Institute of Peace, 2001).
Natsios, who is now the director of the Scowcroft Institute of International Affairs at Texas A&M University, says he pressed for aid to continue during the famine of the mid-1990s that killed hundreds of thousands of North Koreans, “But the regime has been so unwilling to help or facilitate aid work, lots of people are questioning whether or not we should do this, despite that fact that we are.”
“The regime has been so unwilling to help or facilitate aid work, lots of people are questioning whether or not we should do this, despite that fact that we are”
“We do see real change on the ground, and that’s what it’s about,” one foreign aid worker said. “But there is tremendous deception on the North Korean side. The whole place is a lie, it permeates everything. You’re constantly fighting that element of being taken, and that is incredibly wearing.”
Aid work, especially in North Korea, is also extremely expensive. A 2008 investigation by the U.S. Senate Committee on Homeland Security and Governmental Affairs provided a peek at the UN’s financial affairs inside the country. Between 1995 and 2005, the UNDP spent $33.5 million in North Korea. However, that figure is distorted by the fact that the North Korean government requires aid agencies to exchange their currency at the official rate of 99 Korean People’s Won to 1 U.S. Dollar, which Natsios calls “a form of theft.” For context, the black market — and more accurate — rate currently hovers around 8,000 to 1.
Of that $33.5 million, roughly $6 million went toward staff and operating costs: $500,000 per year for rent, office supplies, per diems, and “other expenses,” as well as about $100,000 per year for payments to local staff and contractors.
“The whole place is a lie, it permeates everything. You’re constantly fighting that element of being taken, and that is incredibly wearing”
The UN offices in North Korea are run by permanent UN employees from outside the country. Administrative, operations and clerical positions are filled by local North Koreans, who are said to be attached to the DPRK Ministry of Foreign Affairs, installed on a take-it-or-leave-it basis by the North Korean government.
Per the UN salary scale, “Level 1 General Service Staff” in North Korea — a locally-hired messenger would fall into this category — starts at 54,317 Korean People’s Won (KPW) per year, or about $838 annually at the official exchange rate. The local drivers on which every aid agency in North Korea relies are categorized as Level 2 General Service Staff, and paid starting salaries of KPW 852,399 per year, or about $947 annually. Level 3 General Service Staff, a category which includes senior drivers and clerk-typists, begin at KPW 895,019, or roughly $994 per annum. At Level 4, locally-hired secretaries, administrative clerks, and finance clerks start at KPW 939,744, or approximately $1,044 a year. Level 5 are senior secretaries, senior administrative clerks, and senior finance clerks (KPW 1,000,862; $1,112); Level 6 titles include administrative assistants, finance assistants, and “Secretary to Head of Office” (KPW 1065917; $1,184); and at the top end, Level 7 employees — senior administrative assistants, senior finance assistants — earn starting annual salaries of KPW 1,135,216, or, $1,261.
Each UN aid mission in North Korea is also staffed by a contingent of locally recruited “National Professional Officers.” NPOs, according to a UN employee handbook, “perform professional duties that require knowledge and experience at the national level and so cannot be carried out as effectively by internationally recruited staff. The functions involved are normally in the areas of development assistance and public information.”
The category begins at the NO-A level, which includes the job titles of Assistant Administrative Officer and Assistant Programme Officer, and starts at KPW 1,184,465 per year, or roughly $1,316 at the official exchange rate. NO-B includes Associate Administrative Officers and Associate Programme Officers, who start at KPW 1,231,885 — about $1,368. Administrative Officers and Programme Officers are classified at the NO-C level, and start at KPW 1,281,135, or about $1,423 per annum. (Salaries were once handed over to the North Korean government, after which a small portion of each employee’s wages would be doled out to them. According to a source, UN agencies now deposit local salaries directly into workers’ accounts, a claim which could not be independently verified by NK News.
Aid workers say the relationship between UN and private NGO staff is a good one, though at least one private NGO employee lashed out at what she described as, “so much waste, to the tune of millions of dollars.”
“It’s not deliberate, but it’s a matter of not learning from past mistakes,” said the NGOer. “The cycle of turnover in these positions in North Korea is tremendous, because nobody wants to go there. So, North Korea ends up being a stop on somebody’s career ladder rather than them being there for the right reasons, to do the right thing for the people.”
A RECALCITRANT REGIME
Beyond any obvious sanctions-related inconveniences, aid work in North Korea is made many orders of magnitude more difficult than it would be otherwise, thanks in no small part to the Kim Jong Un regime.
Natsios, for one, calls the in-country data collected by the UN and private NGOs “a guess, it’s what the North Koreans want them to think.”
When Doctors Without Borders left North Korea almost 20 years ago, they complained it had been impossible to create “the minimum conditions necessary to work decently.”
“The teams realised that the government fabricated whatever they wanted aid workers to see: malnourished children in nurseries when more food aid was desired, and well-fed children when donors needed reassurance that food aid was doing good,” the organization said at the time in a sharply-worded statement. (At the end of 2014, Doctors Without Borders once again had three staffers in North Korea, and the group is apparently in negotiations to once again run projects in North Korea.)
Aid workers from French humanitarian agency Action Contre la Faim (ACF) interviewed last year by Emma Campbell, a visiting fellow at the Strategic and Defence Studies Centre at Australian National University, described a 1998 meeting with diplomats at the Russian consulate in Chongjin, North Korea’s third-largest city. The Russians showed the ACF group baby soap and shampoo that ACF had brought into the country to distribute to orphans and kindergarteners, and which the Russians had purchased in the Rajin-Sonbong Free Trade Zone, near the Chinese border. After this episode, North Korean officials prevented the ACF team from having any further contact with the Russian consulate.
North Korea’s treatment of foreign aid agencies might also be described as schizophrenic, at best
“Given the political and security environment and the cultural context, intransigence on the part of the authorities was perhaps inevitable,” wrote Campbell. However, “The surprise displayed by humanitarian actors in the face of these challenges…suggested a profound naivety amongst many organisations operating in the country.” (Others maintain that most large-scale aid diversion took place in the late 1990s, and that present-day “intentional and systematic diversion of aid by the government is highly unlikely.”)
North Korea’s treatment of foreign aid agencies might also be described as schizophrenic, at best. German NGO Welthungerhilfe has spent more than 60 million euros on food, sanitation and clean water programs in North Korea since establishing a presence in the country in 1997. In February 2015, without warning or explanation, Welthungerhilfe’s country director, Regina Feindt, was suddenly deported by the regime.
“Welthungerhilfe does not see anything in Mrs. Feindt’s behavior that would have justified an expulsion,” the organization said in a press release. (A Welthungerhilfe spokesperson declined to comment further on the situation, but confirmed that the agency is still active in North Korea.)
Less than two months later, North Korea ordered the deportation of Sandra Suh, the Korean-American founder of the Los Angeles-based humanitarian organization Wheat Mission Ministries.
“A relevant institution of the DPRK investigated American Suh Sandra who had been engaged in plot-breeding and propaganda against the DPRK for nearly 20 years when she made frequent visits to it under the pretext of ‘grant-in-aid,’” claimed KCNA, North Korea’s state-run news agency.
“According to the investigation, she frequented the DPRK from 1998 under the pretence of ‘humanitarianism’ but she has been engaged in anti-DPRK propaganda abroad with photos and videos about the DPRK she secretly produced and directed, out of inveterate repugnancy toward the DPRK,” the article continued. “She admitted that her acts are ones that seriously insulted the absolute trust of the people of the DPRK in their leader and indelible crimes that infringed on its sovereignty in violation of its law. She apologized for her crimes and earnestly begged for pardon.”
Suh was ejected from North Korea rather than imprisoned, KCNA said, “taking into full consideration her old age and by displaying the generosity of the DPRK law.” (Suh has since died, said an attorney for Wheat Mission Ministries.)
The month after Suh’s deportation, North Korea test-fired a submarine-launched ballistic missile, which the United States called a “clear violation” of UN sanctions. The regime’s fourth nuclear test was conducted nine months later.
None of this comes cheap, and the money spent by Pyongyang on war preparations and material would be better used for food, argues Joshua Stanton, a Washington, D.C. attorney and ex-Army JAG who helped draft H.R. 757, the North Korea Sanctions and Policy Enhancement Act.
The money spent by Pyongyang on war preparations and material would be better used for food
“The North Korean government spends somewhere in the range of $600 to $700 million a year on luxury goods. That doesn’t include the billion-plus they spend on missiles, and I don’t know of any estimates of what they spend on their nuclear program,” said Stanton, who blogs about the DPRK at One Free Korea. “They built a ski resort, they’re building luxury apartments all over Pyongyang. Compare that to the World Food Program’s annual budget for North Korea. Kim Jong Un could take the money out of his pocket and feed everyone in the country.
“Certain issues the North Koreans will talk about. How they spend their money is not something they are willing to discuss with us, or anyone else, for that matter,” said Robert King. “The North Koreans appear to believe that this is a problem someone else has made, and if someone else wants to give them assistance, then they can figure out how to do it. It reflects, unfortunately, the government’s attitude toward its population.”
Stanton sees different parts of the UN “clearly working at cross purposes — the Security Council and the 1718 Committee are trying to defang a country that is nuking up, and the aid agencies are worried about feeding about a million-and-a-half people out of about 24 million total who are the ‘permitted recipients’ of that aid. I’m sure there are some inconveniences; I’ve heard that banks are afraid of touching the money, but maybe that’s what we need to disarm North Korea.”
Or, maybe not, according to Bernt Berger.
There are banks, suppliers, and shippers who “don’t care about” abiding by UN and U.S. regulations, in countries that don’t put forth much effort enforcing compliance, anyway. After all, North Korea sanctions have been in place for a full decade now, and Pyongyang’s nuclear ambitions only appear to be escalating.
“The controls are only as good as the people working on them,” said Berger. “There have been big networks built up where money is transferred across many stations before it finally reaches North Korea. It’s more costly for the North Koreans, but it’s still there. Just more underground.”
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