Case 1:20-cr-00032-RC Document 1 Filed 02/05/20 Page 1 of 50

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Holding a Criminal Term
Grand Jury Sworn in on May 3, 2018
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UNITED STATES OF AMERICA,
Plaintiff,
v.
KO CHOL MAN,
KIM SONG UI,
HAN UNG,
RI JONG NAM,
JO UN HUI,
O SONG HUI,
RI MYONG JIN,
RI JONG WON,
JONG SUK HUI,
KIM TONG CHOL,
KIM CHIN a/k/a KIM JIN,
HUANG HAILIN,
HUANG YUEQING,
JIN YONGHE,
SUN WEI,
RI CHUN HWAN,
KIM HUI SUK,
HAN YONG CHOL,

1

CRIMINAL NO. ______________
VIOLATIONS:
18 U.S.C. § 371
(Conspiracy)
50 U.S.C. § 1705
(International Emergency Economic
Powers Act Violation)
31 C.F.R. 544.201 and 544.205
(Weapons of Mass Destruction
Proliferators Sanctions Regulations)
31 C.F.R. 510.201 and 510.206
(North Korea Sanctions Regulations)
18 U.S.C. § 1344
(Bank Fraud)
18 U.S.C. § 1956(h)
(Conspiracy to Launder Monetary
Instruments)
18 U.S.C. § 1956(a)(2)(A)
(International Money Laundering)
18 U.S.C. § 1956(h)
(Continuing Financial Crimes Enterprise)
FORFEITURE:
18 U.S.C. § 982(a)(1)
18 U.S.C. § 982(a)(2)(A)
18 U.S.C. § 981(a)(1)(A)
18 U.S.C. § 981(a)(1)(C)
21 U.S.C. § 853(p)
28 U.S.C. § 2461(c)

 Case 1:20-cr-00032-RC Document 1 Filed 02/05/20 Page 2 of 50

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RI CHUN SONG,
RI JONG CHOL,
KIM KWANG CHOL,
RI YONG SU,
KU JA HYONG,
JIN YONGHUAN,
KWON SONG IL,
RYU MYONG IL,
HYON YONG IL,
HWANG WON JUN,
HAN KI SONG,
HAN JANG SU,
RI MYONG HUN,
KIM KYONG NAM,
and KIM HYOK JU,

Defendants.

INDICTMENT
The Grand Jury charges that:
At times material to this Indictment:
Introduction
1.

The charges alleged in this Indictment arise from a multi-year scheme to covertly

access the U.S. financial system in spite of sanctions which are intended to deal with unusual and
extraordinary threats to the national security, foreign policy, and economy of the United States.
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2.

The conduct alleged in this Indictment began outside of the jurisdiction of any

particular State or district, and later occurred within the District of Columbia and elsewhere, and
was therefore within the venue of the United States District Court for the District of Columbia, as
provided by Title 18, United States Code, Sections 3237(a) and 3238.
3.

FOREIGN TRADE BANK OF THE DEMOCRATIC PEOPLE’S REPUBLIC OF

KOREA (“FTB”), headquartered in Pyongyang, Democratic People’s Republic of Korea North
Korea (“North Korea”), was North Korea’s primary foreign exchange bank. FTB was a wholly
state-owned institution that represented the government of North Korea in international, inter-bank
communications. FTB maintained correspondent relationships with different financial institutions
in many countries, and has offices in several regions of the world. FTB had more than 600
employees in its head office located in Pyongyang, and approximately 300 employees worked in
its branches and subsidiaries. FTB performed functions for the North Korean government
including, but not limited to, facilitating credit loans, making investments, regulating the use of
foreign currency, setting the exchange rate for the North Korean Won, negotiating with foreign
banks, facilitating foreign banking for North Koreans, buying and selling foreign currency, and
facilitating the export and import of various commodities.
4.

On March 11, 2013, the U.S. Department of the Treasury’s Office of Foreign Assets

Control (“OFAC”) added FTB to the Specially Designated Nationals and Blocked Persons
(“SDN”) list as part of the United States’ efforts to impede North Korea’s ballistic missile and
weapons of mass destruction programs, pursuant to Presidential Executive Order 13382. OFAC
noted in its designation that North Korea used FTB to facilitate transactions on behalf of actors
linked to North Korea’s proliferation network.

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5.

KO CHOL MAN, KIM SONG UI, HAN UNG, RI JONG NAM, JO UN HUI, O

SONG HUI, RI MYONG JIN, RI JONG WON, JONG SUK HUI, KIM TONG CHOL, KIM CHIN
a/k/a KIM JIN, HUANG HAILIN, HUANG YUEQING, JIN YONGHE, SUN WEI, RI CHUN
HWAN, KIM HUI SUK, HAN YONG CHOL, RI CHUN SONG, RI JONG CHOL, KIM
KWANG CHOL, RI YONG SU, KU JA HYONG, JIN YONGHUAN, KWON SONG IL, RYU
MYONG IL, HYON YONG IL, HWANG WON JUN, HAN KI SONG, HAN JANG SU, RI
MYONG HUN, KIM KYONG NAM, and KIM HYOK JU worked in various capacities to provide
services and effect prohibited U.S. dollar transactions for FTB.
6.

KO CHOL MAN and KIM SONG UI were North Korean citizens who respectively

acted at various times as the President of FTB. HAN UNG and RI JONG NAM were North Korean
citizens and acted at various times as the co-Vice Presidents of FTB. In these roles, these
defendants oversaw the operations of FTB’s primary headquarter branch in North Korea (“FTB
Headquarters”). On September 26, 2017, OFAC designated KO CHOL MAN for being an official
of the government of North Korea.
7.

JO UN HUI, O SONG HUI, RI MYONG JIN, RI JONG WON, and JONG SUK

HUI were North Korean citizens who were agents of FTB Headquarters.
8.

KIM TONG CHOL and KIM CHIN a/k/a KIM JIN were North Korea citizens who

operated FTB’s covert branch in Shenyang, China. HUANG HAILIN, HUANG YUEQING, JIN
YONGHE, and SUN WEI were Chinese citizens who operated FTB’s covert branch in Shenyang,
China. KIM TONG CHOL, HUANG HAILIN and HUANG YUEQING managed FTB front
companies Sumer International Group Ltd (“Sumer”) and Headsoon Trading (“Headsoon”).
Defendants KIM TONG CHOL and KIM CHIN a/k/a KIM JIN managed FTB front company
Shenyang Bright Century. KIM TONG CHOL, JIN YONGHE, and SUN WEI managed FTB front
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company Mingzheng International Trading Ltd (Mingzheng). On September 26, 2017, OFAC
designated KIM TONG CHOL for being an official for the government of North Korea. OFAC
noted his role as a FTB representative in Shenyang, China. On June 29, 2017, OFAC designated
SUN WEI for acting on behalf of FTB. OFAC noted his work involved establishing and running
a front company on behalf of FTB. On August 22, 2017, OFAC designated Mingzheng for having
provided material support to, and acting on behalf of, FTB.
9.

RI CHUN HWAN and KIM HUI SUK were North Korean citizens who operated

FTB’s covert branch in Zhuhai, China. On September 26, 2017, OFAC designated RI CHUN
HWAN for being an official for the government of North Korea. OFAC noted his role as a FTB
representative in Zhuhai, China.
10.

HAN YONG CHOL and RI CHUN SONG were North Korean citizens who

operated FTB’s covert branch in Beijing, China. On September 26, 2017, OFAC designated RI
CHUN SONG for being an official for the government of North Korea. OFAC noted his role as a
FTB representative in Beijing, China.
11.

RI JONG CHOL was a North Korean citizen who operated FTB’s covert branch in

Austria. KIM KWANG CHOL and RI YONG SU, who were North Korean citizens, and RI JONG
CHOL managed the Korea Ungum Corporation. On August 3, 2018, OFAC designated the Korea
Ungum Corporation for having provided material support to, and acting on behalf of, FTB.
12.

KU JA HYONG was a North Korean citizen who operated FTB’s covert branch in

Libya. On September 26, 2017, OFAC designated KU JA HYONG for being an official for the
government of North Korea. OFAC noted his role as a FTB representative in Libya. JIN
YONGHUAN was a Chinese citizen who operated FTB’s covert branch in Libya. KU JA HYONG

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and JIN YONGHUAN managed FTB front companies Liaoning Yuzheng and Hong Kong
Yuzheng.
13.

KWON SONG IL and RYU MYONG IL were North Korean citizens who operated

FTB’s covert branch in Kuwait.
14.

HYON YONG IL, HWANG WON JUN, and HAN KI SONG were North Korean

citizens who operated FTB’s covert branch in Thailand. HAN KI SONG also served as a member
of the U.S.- and UN-designated Reconnaissance General Bureau, which is North Korea’s primary
intelligence bureau.
15.

HAN JANG SU was a North Korean citizen who operated FTB’s covert branch in

Moscow, Russia. On March 31, 2017, OFAC designated HAN JAN SU for having provided
material support to, and acting on behalf of, FTB. OFAC noted his role as a FTB representative
in Moscow, Russia.
16.

RI MYONG HUN and KIM KYONG NAM were North Korean citizens who

operated FTB’s covert branch in Khabarovsk, Russia.
17.

KIM HYOK JU was a North Korean citizen who operated FTB’s covert branch in

Vladivostok, Russia.
International Emergency Economic Powers Act
18.

The International Emergency Economic Powers Act (“IEEPA”), enacted in 1977,

authorizes the President to impose economic sanctions in response to an unusual or extraordinary
threat, which has its source in whole or substantial part outside the United States, to the national

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security, foreign policy, or economy of the United States when the President declares a national
emergency with respect to that threat.
19.

The Departments of the Treasury, Commerce, and State enforce and administer

economic sanctions under their respective authorities, to accomplish U.S. foreign policy and
national security goals. In particular, the Department of the Treasury publishes a publicly available
list of individuals and entities (“Specially Designated Nationals and Blocked Persons” or “SDNs”)
targeted by U.S. economic sanctions. SDNs’ property and interests in property, subject to U.S.
jurisdiction or in the possession and control of U.S. persons, are blocked when they are placed on
the SDN list. U.S. persons, including U.S. financial institutions, are generally prohibited from
dealing with SDNs and their property and interests in property.
20.

Using the powers conferred by IEEPA, the President and the Executive Branch

have issued orders and regulations governing and prohibiting certain transactions with countries,
individuals, and entities suspected of proliferating Weapons of Mass Destruction (“WMD”). On
November 14, 1994, the President issued Executive Order 12938, finding “that the proliferation of
nuclear, biological, and chemical weapons (‘weapons of mass destruction’) and of the means of
delivering such weapons, constitutes an unusual and extraordinary threat to the national security,
foreign policy, and economy of the United States, and [declaring] a national emergency to deal
with that threat.”
21.

On June 28, 2005, the President, to take additional steps with respect to the

national emergency described and declared in Executive Order 12938, issued Executive Order
13382 (“Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters”)
to target proliferators of WMD and their support networks and to deny designated proliferators
access to the U.S. financial and commercial systems. Executive Order 13382 authorized the
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United States Secretary of the Treasury, in consultation with the Secretary of State, “to take such
actions, including the promulgation of rules and regulations, as may be necessary to carry out the
purposes” of the Executive Order. Pursuant to that authority, on April 13, 2009, the Secretary of
the Treasury promulgated the “Weapons of Mass Destruction Proliferators Sanctions
Regulations.” See 31 C.F.R. § 544.101 et seq. Executive Order 13382 and the Weapons of Mass
Destruction Proliferators Sanctions Regulations prohibit transactions or dealings by any U.S.
person or within the United States with individuals and entities placed on the SDN list, unless
exempt or authorized by OFAC.
22.

On March 15, 2016, the President, to take additional steps with respect to the

previously described national emergency, issued Executive Order 13722 to address the
Government of North Korea’s continuing pursuit of its nuclear and missile programs. Pursuant to
that authority, on March 16, 2016, the Secretary of the Treasury promulgated the “North Korea
Sanctions Regulations.” See 31 C.F.R. § 510.101 et seq. Executive Order 13722 and the North
Korea Sanctions Regulations prohibit the export of financial services from the United States or by
any U.S. person to North Korea, unless exempt or authorized by OFAC.
23.

Executive Orders 13382 and 13722, the Weapons of Mass Destruction Proliferators

Sanctions Regulations, and North Korea Sanctions Regulations also prohibited any transaction
by any U.S. person or within the United States that evaded or avoided, or had the purpose of
evading or avoiding, any prohibition set forth in these regulations.
24.

Executive Orders 13382 and 13722, the Weapons of Mass Destruction Proliferators

Sanctions Regulations, and North Korea Sanctions Regulations also prohibit any transaction by
any U.S. person or within the United States that evades or avoids, or has the purpose of evading
or avoiding, any prohibition set forth in these regulations.
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25.

Foreign financial institutions regularly maintain accounts in the United States at

banks that process U.S. dollar transactions (“Correspondent Banks”). Correspondent Banks
accounts are broadly defined to include any account established for a foreign financial institution
to receive deposits from, or to make payments or disbursements on behalf of, the foreign financial
institution, or to handle other financial transactions related to such foreign financial institution.
See 31 C.F.R. § 1010.605. Correspondent Banks serve to support international wire transfers for
foreign customers in a currency that the foreign customer’s overseas financial institution normally
does not hold on reserve, such as U.S. dollars. It is through these accounts that the funds used in
U.S. dollar transactions clear.

SDNs are, among other things, prohibited from accessing

Correspondent Banks in the United States through foreign financial institutions, either directly or
indirectly.
26.

The Export Administration Regulations contain a list of names of certain foreign

persons – including businesses, research institutions, government and private organizations,
individuals, and other types of legal persons – that are subject to specific license requirements for
the export, reexport and/or transfer (in-country) of specified items. These persons comprise the
U.S. Department of Commerce’s Entity List, which is found at Title 15 Code of Federal
Regulations, Part 744, Supplement No. 4. The Department of Commerce first published the Entity
List in February 1997 as part of its efforts to inform the public of entities who have engaged in
activities that could result in an increased risk of the diversion of exported, reexported and
transferred (in-country) items to WMD programs. Since its initial publication, grounds for
inclusion on the Entity List have expanded to include activities sanctioned by the U.S. State
Department and activities contrary to U.S. national security and/or foreign policy interests. On an

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individual basis, the persons on the Entity List are subject to export licensing requirements and
policies supplemental to those found elsewhere in the Export Administration Regulations.
Bank Secrecy Act and the USA PATRIOT Act
27.

According to the U.S. Department of the Treasury (“Treasury”), the global financial

system, trade flows, and economic development rely on correspondent banking relationships. To
protect this system from abuse, U.S. financial institutions must comply with national anti-money
laundering requirements set forth in the Bank Secrecy Act as well as sanctions programs
administered by OFAC. The Financial Crimes Enforcement Network (“FinCEN”) was responsible
for administering the Bank Secrecy Act in furtherance of its mission to safeguard the U.S. financial
system from illicit use.
28.

The Bank Secrecy Act required U.S. financial institutions to take anti-money

laundering measures for foreign financial institutions engaged in correspondent banking of U.S.
dollar transactions.
29.

The Bank Secrecy Act broadly defined foreign financial institutions to include

dealers of foreign exchange and money transmitters in a manner not merely incidental to their
business. See 31 C.F.R. § 1010.605(f).
30.

Section 311 of the USA PATRIOT Act, codified at Title 31, United States Code,

Section 5318A as part of the Bank Secrecy Act, gave FinCEN a range of options, called “special
measures,” that could be adapted to target specific money laundering and terrorist financing
concerns. A Section 311 finding and the related special measure were implemented through
various orders and regulations incorporated into Title 31, Code of Federal Regulations, Chapter
X. In order to protect the integrity of the U.S. financial system, a special measure imposed under
Section 311 prevented financial institutions from causing U.S. financial institutions from engaging
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in any type of financial transaction with an entity within the jurisdiction deemed an area of money
laundering concern.
31.

In May 2016, FinCEN made a Section 311 finding against North Korea.

Specifically, FinCEN’s finding deemed the entire North Korean financial sector as a jurisdiction
of primary money laundering concern. See Federal Register, Vol. 81, No. 107 (June 3, 2016).
32.

In November 2016, FinCEN implemented the most severe special measure against

the entire North Korean financial sector. See Federal Register, Vol. 81, No. 217 (November 9,
2016); 31 CFR § 1010.659. The “special measure” barred U.S. financial institutions from
maintaining a correspondent account for any North Korean financial institution or any party acting
on its behalf. The “special measure” also required covered financial institutions to take reasonable
steps to not process a transaction for the correspondent account of a foreign bank in the United
States if such a transaction involved a North Korean financial institution. Because of the finding
that the entire North Korea financial sector was a primary money laundering concern, FinCEN cut
all North Korean financial institutions—and entities acting on their behalf—off from any trade in
U.S. dollar transactions via correspondent banking.
33.

FinCEN noted that North Korea makes “extensive use of deceptive financial

practices, including the use of shell and front companies to obfuscate the true originator,
beneficiary, and purpose behind its transactions,” in part “to evade international sanctions.” See
Federal Register, Vol. 81, No. 217 at 78716, 78718. North Korean entities have attempted to
circumvent the Section 311(a) ban by using foreign front companies to engage in financial
transactions on their behalf.
34.

Correspondent banks in the United States that fail to comply with the Section 311

finding, are subject to criminal liability pursuant to Title 31, United States Code, Section 5322.
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COUNT ONE
THE CONSPIRACY
35.

From on or about March 11, 2013, through the Present, within the District of

Columbia and elsewhere, defendants KO CHOL MAN, KIM SONG UI, HAN UNG, RI JONG
NAM, JO UN HUI, O SONG HUI, RI MYONG JIN, RI JONG WON, JONG SUK HUI, KIM
TONG CHOL, KIM CHIN a/k/a KIM JIN, HUANG HAILIN, HUANG YUEQING, JIN
YONGHE, SUN WEI, RI CHUN HWAN, KIM HUI SUK, HAN YONG CHOL, RI CHUN
SONG, RI JONG CHOL, KIM KWANG CHOL, RI YONG SU, KU JA HYONG, JIN
YONGHUAN, KWON SONG IL, RYU MYONG IL, HYON YONG IL, HWANG WON JUN,
HAN KI SONG, HAN JANG SU, RI MYONG HUN, KIM KYONG NAM, and KIM HYOK JU
did knowingly combine, conspire, confederate and agree with others known and unknown to the
Grand Jury, to:
a.

commit offenses against the United States, that is, the export of financial

services from the United States to a SDN in North Korea without having first obtained the
required license from OFAC, located in the District of Columbia, in violation of Title 50,
United States Code, Sections 1702 and 1705, the Weapons of Mass Destruction
Proliferators Sanctions Regulations, pursuant to Title 31, Code of Federal Regulations,
Section 544.201, et seq., and North Korea Sanctions Regulations, pursuant to Title 31,
Code of Federal Regulations, Section 510.201, et seq.;
b.

defraud the U.S. Government by interfering with and obstructing a lawful

government function, that is, the enforcement of: the Weapons of Mass Destruction
Proliferators Sanctions Regulations; the North Korea Sanctions Regulations; and the of
laws and regulations prohibiting the supply of financial services from the United States to
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a SDN in North Korea without authorization or a license, by deceit, craft, trickery, and
dishonest means;
c.

defraud the United States government by interfering with and obstructing a

lawful government function, that is, supervision by the Federal Reserve Board and the
Office of Comptroller of Currency, which are located in the District of Columbia, of banks
implementation of required anti-money laundering and sanctions programs;
d.

commit offenses against the United States, that is, by knowingly executing

a scheme: to defraud a financial institution; and to obtain moneys and funds owned and
under the custody and control of, a financial institution, by means of false and fraudulent
pretenses, representations, and promises, that is by concealing from U.S. financial
institutions that they were engaged in financial transactions with a North Korean financial
institution, which was in a jurisdiction deemed an area of money laundering concern, in
violation of Title 18, United States Code, Section 1344(1) and (2).
Objects of the Conspiracy
36.

The objects of the conspiracy were:
a. to enrich the defendants and other co-conspirators;
b. to transact in U.S. dollars by North Korean entities otherwise barred from
accessing the U.S. financial system;
c. to facilitate the purchase of products and services for North Korean end users;
and
d. to evade relevant regulations, prohibitions on export of financial service, and
licensing requirements.

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Manner and Means of the Conspiracy
37.

The manner and means by which defendants and their co-conspirators sought to

accomplish the objects of the conspiracy, included, among others, the following:
a.

the defendants and other co-conspirators communicated with co-

conspirators inside and outside of North Korea;
b.

FTB policy dictated sending the defendants and other co-conspirators

abroad “in close cooperation with different financial institutions of other countries to study fast
developing financial technologies and experiences of other countries.”
c.

the defendants and other co-conspirators opened and operated covert

branches of FTB outside of North Korea, including in Thailand, Libya, Austria, Russia, Kuwait,
and China, which the defendants used to engage in otherwise prohibited U.S. dollar transactions.
d.

the defendants and other co-conspirators took up residence in foreign

countries to operate these covert branches, from which they opened and operated front companies
and worked with established third-party financial facilitators to procure commodities and facilitate
payments in U.S. dollars on behalf of parties in North Korea;
e.

the defendants and other co-conspirators concealed FTB’s involvement in

U.S. dollar payments from Correspondent Banks in order to trick the banks into processing
payments that the banks otherwise would not have done;
f.

the defendants and other co-conspirators concealment tactics included:
i. establishing and using over 250 front companies to process U.S. dollar
payments;
ii. repeatedly creating new front companies after the government or banks
detected prior front companies’ association with North Korea;
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iii. listing false end destinations and customers on documents such as contracts
and invoices; and
iv. engaging in coded conversations.
g.

the defendants and other co-conspirators caused Correspondent Banks to

process at least $2.5 billion in illegal payments via over 250 front companies, which payments
transited through the United States during the period of the conspiracy.
Overt Acts
38.

In furtherance of this conspiracy, and to accomplish its purposes and objects, at

least one of the co-conspirators committed or caused to be committed, in the District of Columbia
and elsewhere, at least one of the following overt acts, among others:
a.

FTB Headquarters
i. On or about March 13, 2013, JO UN HUI corresponded with agents of
several FTB foreign covert branches, including KIM TONG CHOL of FTB
Shenyang, KU JA HYONG of FTB Libya, HYON YONG IL of FTB
Thailand, KIM KYONG NAM and RI MYONG HUN of FTB Khabarovsk,
and RI JONG CHOL of FTB Austria.
ii. On or about July 19, 2013, a co-conspirator at FTB Headquarters made a
coded request for 2nd and 4th quarter balance information from HYON
YONG IL of FTB Thailand, RI JONG CHOL of FTB Austria, KU JA
HYONG of Libya, RYU MYONG IL of FTB Kuwait, and KIM KYONG
NAM and RI MYONG HUN of FTB Khabarovsk.
iii. On or about February 28, 2014, JO UN HUI made a coded request to HYON
YONG IL of FTB Thailand, KU JA HYONG of FTB Libya, HAN JANG
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SU of FTB Moscow, KIM KYONG NAM and RI MYONG HUN of FTB
Khabarovsk, and RYU MYONG IL of FTB Kuwait, to send currency
balance information for 2014 to FTB Headquarters.
iv. On or about June 10, 2015, a co-conspirator at FTB Headquarters
corresponded with agents of several FTB foreign covert branches, including
KIM TONG CHOL of FTB Shenyang, RI CHUN SONG of FTB Beijing,
KU JA HYONG of FTB Libya, RYU MYONG IL of FTB Kuwait, HYON
YONG IL of FTB Thailand, KIM KYONG NAM and RI MYONG HUN
of FTB Khabarovsk, RI JONG CHOL of FTB Austria, RI CHUN HWAN
and KIM HUI SUK of FTB Zhuhai, HAN JANG SU of FTB Moscow, and
a Dandong representative of Korea Kwangson Bank, a sanctioned North
Korean bank subordinate to FTB.
v. On or about April 25, 2017, a co-conspirator at FTB headquarters
corresponded with agents of several FTB foreign covert branches, including
KIM TONG CHOL of FTB Shenyang, RI JONG CHOL of FTB Austria,
RI CHUN SONG of FTB Beijing, KU JA HYONG of FTB Libya, HWANG
WON JUN of FTB Thailand, RI CHUN HWAN of FTB Zhuhai, and HAN
JANG SU of FTB Moscow.
vi. On or about May 29, 2017, RI MYONG JIN corresponded with agents of
several FTB foreign covert branches, including KIM TONG CHOL of FTB
Shenyang, RI CHUN SONG of FTB Beijing, KU JA HYONG of FTB
Libya, HWANG WON JUN of FTB Thailand, RI CHUN HWAN of FTB
Zhuhai, RI MYONG HUN of FTB Khabarovsk, and HAN JANG SU of
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FTB Moscow.
vii. On or about June 12, 2018, KO CHOL MAN, HAN UNG, and RI JONG
NAM caused a FTB front company to pay a U.S. Company approximately
$90,000.00 on behalf of the North Korean government.
viii. On or about March 20, 2019, KO CHOL MAN, HAN UNG, and RI JONG
NAM caused a FTB front company to pay a U.S. Company approximately
$195,000.00 on behalf of the North Korean government.
ix. On or about December 24, 2019, KO CHOL MAN, HAN UNG, and RI
JONG NAM caused a foreign company to pay a U.S. Company
approximately $10,000.00.
x. On or about January 3, 2020, KO CHOL MAN, HAN UNG, and RI JONG
NAM caused a foreign company to pay a U.S. Company approximately
$20,000.00.
xi. On or about January 10, 2020, KO CHOL MAN, HAN UNG, and RI JONG
NAM caused a foreign company to pay a U.S. Company approximately
$20,000.00.
b.

FTB Shenyang
i. On or about June 19, 2013, SUN WEI opened a bank account at Chinese
Bank 1.
ii. On or about August 6, 2013, FTB Headquarters sent KIM TONG CHOL
coded instructions to pay a Shenyang foreign trade company (“Shenyang
Company”) $46,000.00 at its Chinese bank and included a coded reference
number.
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iii. On or about August 7, 2013, KIM TONG CHOL caused Sumer, a FTB
Shenyang front company established by HUANG HAILIN, to wire a
payment of $45,930.00 to Shenyang Company’s Chinese bank account,
which payment cleared through a U.S. correspondent bank.
iv. On or about August 21, 2013, KIM TONG CHOL directed HUANG
YUEQING to amend a U.S. dollar payment instruction which contained a
coded payment reference.
v. On or about October 7, 2013, HAN JANG SU of FTB Moscow provided
KIM TONG CHOL with passport information for KIM SONG UI and
JONG SUK HUI of FTB HQ.
vi. On or about November 11, 2013, KO CHOL MAN of FTB HQ sent a copy
of his passport to KIM CHIN.
vii. On or about December 3, 2013, KIM TONG CHOL directed JONG SUK
HUI of FTB HQ to make a $30,000.00 payment using Shenyang Bright
Century, a FTB Shenyang front company.
viii. On or about December 17, 2013, KIM TONG CHOL corresponded with
HUANG HAILIN about a transaction fee related to Sumer, a FTB Shenyang
front company.
ix. On or about February 20, 2014, KIM TONG CHOL provided FTB
Headquarters the name of a FTB front company based out of the Marshall
Islands, International Silver-Bridge Commercial Group, and its Chinese
bank account.
x. On or about April 2, 2014, FTB Headquarters sent KIM TONG CHOL
18

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coded instruction to pay $25,000.00 to a Chinese electronics company at its
Chinese bank account, and a related coded payment reference.
xi. On or about April 3, 2014, KIM TONG CHOL caused International SilverBridge Commercial Group to wire payment of $24,910.00 to a Chinese
electronics company’s Chinese bank account, which payment cleared
through a U.S. correspondent bank.
xii. On or about June 3, 2014, HUANG HAILIN discussed with KIM TONG
CHOL a due diligence inquiry from Chinese Bank 1 about Sumer, a FTB
Shenyang front company, and its wire payments to Panda International
Information—a Chinese company that the U.S. Commerce Department
added to the Entity List in June 2014 for activities contrary to the national
security of the United States—and Dandong Kehua Economic and Trade
Co—a Chinese company which OFAC later sanctioned.
xiii. On or about June 3, 2014, KIM TONG CHOL directed HUANG HAILIN
to falsely state to the Chinese Bank 1 that Sumer, a FTB Shenyang front
company, wired payments to Panda International Information and Dandong
Kehua Economic and Trade Co. for legitimate telecommunication
equipment purchases.
xiv. On or about July 8, 2014, HUANG YUEQING provided KIM TONG
CHOL with a due diligence inquiry that a U.S. correspondent bank provided
to Chinese Bank 1 in which HUANG YUEQING falsely told Chinese Bank
1 that Sumer, a FTB Shenyang front company, did not have any relationship
with North Korea.
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xv. On or about July 8, 2014, KIM TONG CHOL provided HUANG
YUEQING with additional false statements for HUANG YUEQING to
provide in regards to remaining questions on the due diligence inquiry from
the U.S. correspondent bank.
xvi. On or about July 11, 2014, KIM TONG CHOL directed HUANG
YUEQING to contact Chinese Bank 2 to ask why a payment of $19,950
from Sumer’s account at Chinese Bank 2 to a Chinese electronics
company’s account at Chinese Bank 3 had not yet been processed.
xvii. On or about July 18, 2104, SUN WEI made a recorded phone call to Chinese
Bank 4 to inquire about opening an account and what the fees would be for
international wire payments.
xviii. On or about August 1, 2014, SUN WEI opened a bank account at Chinese
Bank 4.
xix. On or about August 15, 2014, KIM TONG CHOL and HUANG YUEQING
caused Sumer’s account at Chinese Bank 2 to wire $19,930.00 to a Chinese
electronics company’s account at Chinese Bank 3, which payment the U.S.
correspondent bank blocked, and which wire included a coded FTB
payment reference.
xx. On or about September 29, 2014, KIM TONG CHOL provided JIN
YONGHE FTB’s official stamp.
xxi. On or about November 18, 2014, HUANG HAILIN sent KIM TONG
CHOL payment confirmation of $400,000.00 from Headsoon, a FTB
Zhuhai front company established by HUANG HAILIN, to Sumer.
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xxii. On or about February 25, 2015, SUN WEI received a Mingzheng contract
with a Chinese company, which listed SUN WEI as the CEO of Mingzheng
on the signature page.
xxiii. On or about March 11, 2015, KIM CHIN sent KIM TONG CHOL U.S.
dollar payment instructions to a Chinese electronics company.
xxiv. On or about March 20, 2015, KIM CHIN sent Mingzheng’s U.S. dollar bank
account information at Chinese Bank 4 to RI CHUN HWAN and KIM HUI
SUK of FTB Zhuhai.
xxv. On or about March 20, 2015, RI CHUN HWAN and KIM HUI SUK of FTB
Zhuhai caused China Unitech, a FTB Zhuhai front company, to wire
$100,000.00 to Mingzheng’s bank account at Chinese Bank 4, which
payment cleared through a U.S. correspondent bank.
xxvi. On or about March 24, 2015, KIM CHIN confirmed to RI CHUN HWAN
and KIM HUI SUK of FTB Zhuhai that FTB Shenyang had taken a loan of
$100,000.00 from FTB Zhuhai.
xxvii. On or about June 12, 2015, JIN YONGHE directed KIM TONG CHOL to
pay $23,470.00 to a co-conspirator company.
xxviii. On or about June 12, 2015, KIM TONG CHOL and JIN YONGHE caused
Mingzheng to wire $23,470.00 to a co-conspirator company, which
payment cleared through a U.S. correspondent bank.
xxix. On or about November 2, 2015, KIM TONG CHOL caused Mingzheng to
wire $174,982.00 to a Chinese company’s Chinese bank account, which
payment the U.S. correspondent bank blocked.
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xxx. On or about November 5, 2015, KIM TONG CHOL caused Mingzheng to
wire $295,769.21 to Chinese company 2’s Chinese bank account, which
payment the U.S. correspondent bank blocked.
xxxi. On or about November 11, 2015, KIM TONG CHOL and Chinese
Telecommunications Company 1 employee received a contract receipt from
Chinese Company 2 about the November 5, 2015 blocked payment, which
contract reflected the shipment of electronic goods to North Korea.
xxxii. On or about November 12, 2015, KIM TONG CHOL and a Chinese
Telecommunications Company 1 employee received a contract receipt from
Chinese Company 2 about the November 5, 2015 blocked payment, which
contract falsely changed the destination of the shipment of electronic goods
from North Korea to Hong Kong.
xxxiii. On or about November 18, 2015, JIN YONGHE sent KIM TONG CHOL a
notice from Chinese Bank 4 notifying Mingzheng that a U.S. correspondent
bank blocked a payment of $24,932.00 as part of OFAC sanction
compliance.
xxxiv. On or about November 18, 2015, JIN YONGHE sent KIM TONG CHOL a
notice from Chinese Bank 4 notifying Mingzheng that a U.S. correspondent
bank blocked a payment of $174,982.00, which noted that the transaction
could not be processed due to the Weapons of Mass Destruction
Proliferators Sanctions Regulations issued by OFAC.
xxxv. On or about November 19, 2015, KIM TONG CHOL sent JIN YONGHE
several documents including a copy of SUN WEI’s Chinese national
22

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identification card, an English translation of the identification card, invoices
documenting payments from Mingzheng, the business registration
certificate for Mingzheng , and Certificate of Incorporation for Mingzheng.
xxxvi. On or about November 19, 2015, KIM TONG CHOL sent JIN YONGHE a
copy of the wire transfer receipt for the $174,982.00, which had hand
written notes underlining the North Korean weapons of mass destruction
reference and the information about filing a license application with OFAC.
xxxvii. On or about November 20, 2015, JIN YONGHE sent KIM TONG CHOL a
copy of a notice from Chinese Bank 1 that a U.S. correspondent bank
blocked a payment of $9,945.0 payment from a Chinese electronics
company to Mingzheng because of OFAC’s weapons of mass destruction
proliferation sanctions program.
xxxviii. On or about November 20, 2015, SUN WEI submitted a letter to OFAC in
which he falsely stated that Mingzheng had not violated the North Korean
weapons of mass destruction proliferators sanctions regulations issued by
OFAC.
xxxix. On or about November 20, 2015, SUN WEI submitted a license application
to OFAC, which contained Mingzheng incorporation records and fabricated
contracts and invoices signed by SUN WEI.
xl. On or about December 7, 2015, JIN YONGHE sent KIM TONG CHOL
information about OFAC blocking Mingzheng payments via a U.S.
correspondent bank.
xli. On or about January 12, 2016, a Swiss businessman told KIM TONG
23

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CHOL to create falsified documents, including a signed agreement between
Mingzheng and the Swiss company, to replace the original contract with a
North Korean entity, in an attempt to have OFAC release $41,822.04 in
blocked funds Mingzheng had attempted to send the Swiss businessman on
or about November 15, 2015.
xlii. On or about January 15, 2016, KIM TONG CHOL informed JO UN HUI
of FTB Headquarters about three sets of U.S. dollar payments to front
companies, each with a coded FTB payment reference.
xliii. On or about January 15, 2016, KIM TONG CHOL further informed JO UN
of FTB Headquarters HUI about the blocking of Mingzheng payments by
OFAC.
xliv. On or about January 15, 2016, KIM TONG CHOL also informed JO UN
HUI of FTB Headquarters that KIM TONG CHOL was attempting to get
fabricated documents relating to the Mingzheng blocked funds, which
would be submitted to OFAC.
xlv. On or about March 1, 2016, KIM TONG CHOL sent the documents to the
Swiss businessman, including a fabricated Mingzheng contract backdated
June 5, 2015, with the Swiss businessman’s company, which falsely stated
that the goods originated shipped from Hong Kong, when in fact they were
coming from North Korea.
DANDONG KEHUA
xlvi. On or about March 29, 2013, FTB Headquarters sent KIM TONG CHOL
coded payment instructions to pay co-conspirator Dandong Kehua—a
24

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Chinese company which OFAC later sanctioned—$8,670.00, which
instructions reflected that such payment was for a 20% payment for a prior
contract.
xlvii. On or about April 1, 2013, KIM TONG CHOL at FTB Shenyang caused
Mingzheng to wire a payment of $8,670.00 to Dandong Kehua’s Chinese
bank account, which payment cleared through a U.S. correspondent bank,
and which payment included the same notation of a 20% payment for a prior
contract and a coded FTB reference number.
xlviii. On or about August 8, 2014, FTB Headquarters sent KIM TONG CHOL
coded payment instructions to pay co-conspirator Dandong Kehua
$59,319.00, which instructions included a coded FTB reference number.
xlix. On or about April 20, 2013, co-conspirator Dandong Kehua renewed an
annual contract with Chinese Telecommunications Company 2 for the sale
of Chinese Telecommunications Company 2 handsets, and which contract
contained a provision requiring compliance with U.S. export control laws
and forbade shipment to embargoed countries.
l. On or about August 13, 2014, KIM TONG CHOL at FTB Shenyang caused
Mingzheng to wire a payment of $613,483.80 to Dandong Kehua’s Chinese
bank account, which payment cleared through a U.S. correspondent bank,
and which payment included the same coded FTB reference number.
li. On or about September 5, 2014, FTB Headquarters sent KIM TONG CHOL
coded payment instructions to pay co-conspirator Dandong Kehua
$250,871.60, which instructions included a coded FTB reference number.
25

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lii. On or about September 8, 2014, KIM TONG CHOL at FTB Shenyang
caused International Silver-Bridge Commercial Group to wire a payment of
$250,380.03 to Dandong Kehua’s Chinese bank account, which payment
cleared through a U.S. correspondent bank.
liii. On or about February 17, 2015, co-conspirator Dandong Kehua renewed an
annual contract with Chinese Telecommunications Company 2 for the sale
of Chinese Telecommunications Company 2 handsets, and which contract
contained a provision requiring compliance with U.S. export control laws
and forbade shipment to embargoed countries.
liv. On or about August 26, 2015, FTB Headquarters sent KIM TONG CHOL
coded payment instructions to pay co-conspirator Dandong Kehua
$454,900.00, which payment instructions encoded Dandong Kehua’s phone
number and bank account, and the SWIFT code for the Bank of Dandong—
a bank which the United States subsequently banned from U.S. dollar
transactions based on North Korean money laundering.
PANDA INTERNATIONAL INFORMATION TECHNOLOGY
lv. On or about August 21, 2014, FTB Headquarters sent KIM TONG CHOL
coded instructions to pay Panda International Information Technology—a
Chinese company that the Commerce Department added to the Entity List
in June 2014 for activities contrary to the national security of the United
States—$120,000.00 at Panda International Information Technology’s

26

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Chinese bank account, noted that the customer was the Korean Ministry of
Post and Telecommunication, and a related coded payment reference.
lvi. On or about August 22, 2014, KIM TONG CHOL caused Mingzheng to
wire payment for $119,782.00 to Panda International Information
Technology’s Chinese bank account, which payment cleared through a U.S.
correspondent bank, with a notation referencing the coded payment.
lvii. On or about March 23, 2015, RI CHUN HWAN and KIM HUI SUK of FTB
Zhuhai caused China Unitech, a FTB Zhuhai front company, to wire
$200,000.00 to Panda International Information Technology’s Chinese
bank account, which payment cleared through a U.S. correspondent bank.
lviii. On or about October 29, 2015, KIM TONG CHOL caused Mingzheng to
wire $174,982.00 to Panda International Information Technology’s Chinese
bank account on behalf of Cheo Technology joint venture, which payment
the U.S. correspondent bank blocked, and which wire included a coded FTB
payment reference.
c.

FTB Zhuhai
i. On or about September 5, 2013, KIM HUI SUK informed HUANG
YUEQING of FTB Shenyang that KIM HUI SUK caused Headsoon, a FTB
Zhuhai front company, to wire $498,000.00 to a Chinese company’s bank
account at Chinese Bank 1, which payment cleared through a U.S.
correspondent bank.
ii. On or about October 3, 2013, RI CHUN HWAN shared his new FTB Zhuhai
contact information with KIM TONG CHOL, who forwarded that
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information to FTB Headquarters.
iii. On or about October 14, 2013, FTB Headquarters sent RI CHUN HWAN
coded instructions to pay a Malaysian company $50,220.88 at its Malaysian
bank account with a coded reference number and a contract number.
iv. On or about October 15, 2013, RI CHUN HWAN caused Headsoon, a FTB
Zhuhai front company, to wire $50,100.00 to the Malaysian company’s
bank account, which payment cleared through a U.S. correspondent bank.
v. On or about January 6, 2014, FTB Headquarters sent FTB Zhuhai coded
instructions to wire a Malaysian company $20,937.00 at its Malaysian bank
account for a contract with a North Korean trading company with a coded
reference number.
vi. On or about January 7, 2014, KIM HUI SUK caused China Unitech, a FTB
Zhuhai front company, to wire $20,875.00 to the Malaysian company’s
Malaysian bank account, which payment cleared through a U.S.
correspondent bank.
vii. On or about January 7, 2014, KIM HUI SUK caused FTB Zhuhai to send
coded confirmation to FTB Headquarters that FTB Zhuhai paid $20,937.00,
with the same coded FTB reference number.
viii. On or about January 20, 2015, KIM HUI SUK caused China Unitech, a FTB
Zhuhai front company, to wire $6,325.36 to Headsoon, a FTB Zhuhai front
company, which payment cleared through a U.S. correspondent bank.
ix. On or about March 20, 2015, RI CHUN HWAN caused FTB Zhuhai to
arrange a $200,000.00 loan with a North Korean trade company.
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x. On or about March 31, 2015, KIM HUI SUK provided the name and
Chinese bank account number of China Unitech, a FTB Zhuhai Front
Company, to an agent of Korea Kwangson Bank, a sanctioned North Korean
bank subordinate to FTB.
xi. On or about December 23, 2018, RI MYONG JIN of FTB Headquarters
communicated with RI CHUN HWAN.
xii. On or about April 19, 2019, RI CHUN HWAN confirmed to RI MYONG
JIN of FTB Headquarters in a coded communication that RI CHUN HWAN
caused FTB Zhuhai to make a $1,060,000.00 payment.
d.

FTB Beijing
i. On or about November 3, 2014, HAN YONG CHOL sent Korea Kwangson
Bank, a sanctioned North Korean bank subordinate to FTB, coded
instructions to make two payments totaling $500,000.00 to Dandong Kehua
Economic and Trade Co—a Chinese company which OFAC later
sanctioned.
ii. On or about November 19, 2014, HAN YONG CHOL received the name
and bank account of a front company associated with Korea Kwangson
Bank, a sanctioned North Korean bank subordinate to FTB.
iii. On or about June 23, 2015, RI CHUN SONG received coded instructions
from Korea Kwangson Bank, a sanctioned North Korean bank subordinate
to FTB, to make a $56,941.00 payment.
iv. On or about June 23, 2015, RI CHUN SONG sent the coded $56,941.00
payment instructions from Korea Kwangson Bank, a sanctioned North
29

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Korean bank subordinate to FTB, to HAN YONG CHOL.
v. On or about August 27, 2015, HAN YONG CHOL caused Hong Kong Vast
International Trade Co., a FTB Beijing front company, to wire $248,085.00
to a Korea Kwangson Bank front company’s Chinese bank account, which
payment cleared through a U.S. correspondent bank.
vi. On or about December 9, 2015, HAN YONG CHOL received due diligence
documents from a Chinese Bank 1, which documents referenced OFAC
compliance.
vii. On or about December 15, 2015, HAN YONG CHOL received a ledger that
a Chinese bank compiled of wire payments transacted in 2015 by Hong
Kong Vast International Trade Co., a FTB Beijing front company, totaling
approximately $13,988,940.27.
viii. On or about March 18, 2016, RI CHUN SONG contacted FTB
Headquarters to share his new contact information.
ix. On or about March 23, 2016, FTB Headquarters sent RI CHUN SONG
coded instructions to pay a Chinese company $768,974.70, with a coded
FTB reference number.
x. On May 3, 2016, HAN YONG CHOL sent KIM KYONG NAM and RI
MYONG HUN of FTB Khabarovsk a copy of HAN YONG CHOL’S
passport.
xi. On or about May 24, 2016, RI CHUN SONG informed HAN YONG CHOL
that a Chinese bank wanted FTB to send payment instructions in a letter on
FTB letterhead, signed by KIM SONG UI, and be addressed to the Chinese
30

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bank’s financial institution department.
xii. On or about November 22, 2016, RI CHUN SONG received coded
instructions from FTB Headquarters to pay a U.S. Company $77,400.00 on
behalf of the North Korean government with a coded reference number.
xiii. On or about November 23, 2016, RI CHUN SONG caused Dalian Ouya, a
FTB Beijing front company, to wire $77,400.00 to a U.S. Company, which
payment cleared through a U.S. correspondent bank.
xiv. On or about November 23, 2016, RI CHUN SONG sent FTB Headquarters
a coded receipt for payment of $77,400.00 by Dalian Ouya, a FTB Beijing
front company, to a U.S. Company.
xv. On or about May 8, 2017, RI CHUN SONG sent HAN YONG CHOL
payment confirmation that a FTB Beijing front company sent $385,000.00
to Velmur—a FTB Vladivostok front company, which OFAC later
sanctioned—which payment cleared through a U.S. correspondent bank.
xvi. On or about May 8, 2017, RI CHUN SONG sent HAN YONG CHOL
payment confirmation that a FTB Beijing front company sent $407,000.00
to Velmur, which payment cleared through a U.S. correspondent bank.
xvii. On or about June 27, 2017, RI CHUN SONG sent FTB Headquarters a
coded receipt for payment of $150,000.00.
xviii. On or about September 26, 2018, HAN YONG CHOL sent KU JA HYONG
of FTB Libya identity documents for co-conspirators in Libya.
xix. On or about February 17, 2019, HAN YONG CHOL warned RI CHUN
SONG of FTB Beijing about anti-money laundering regulations being
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implemented by banks.
xx. On or about May 28, 2019, HAN YONG CHOL described hardware failures
in a component that can be used in ship, aviation, and rocket machinery.
e.

FTB Austria
i. On or about May 9, 2013, FTB Headquarters sent RI JONG CHOL coded
payment instructions for payment of $44,455.08 on behalf of a North
Korean entity.
ii. On or about March 14, 2014, RI JONG CHOL provided documentation to
an Austrian bank, which stated that the Ungum Corporation was wholly
owned by the North Korean government.
iii. On or about May 5, 2014, RI JONG CHOL informed HYON YONG IL that
RI YONG SU was the Section Chief of the Ungum Corporation—an entity
OFAC sanctioned in August 2018 as a FTB front company—who was
responsible for Ungum’s Austrian bank account.
iv. On or about October 23, 2014, RI JONG CHOL signed a power of attorney
form in Austria on behalf of Ungum Corporation.
v. On or about February 28, 2018, RI JONG CHOL received coded payment
instructions from KIM KWANG CHOL.
vi. On or about November 11, 2018, RI JONG CHOL informed KIM KWANG
CHOL, the chairman of Ungum, about the shipment of coal and a related
coded FTB U.S. dollar payment reference.
vii. On or about February 18, 2019, RI JONG CHOL informed KIM KWANG
CHOL, the chairman of Ungum, about a coded FTB U.S. dollar payment
32

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reference.
viii. On or about March 17, 2019, RI JONG CHOL informed KIM KWANG
CHOL, the chairman of Ungum, about a coded FTB U.S. dollar payment
reference.
f.

FTB Libya
i. On or about April 26, 2013, JIN YONGHUAN caused Hong Kong Yuzheng
Industry Co., Limited to be incorporated in Hong Kong.
ii. On or about July 10, 2013, KIM TONG CHOL informed FTB Headquarters
that he had signed a contract with Liaoning Yuzheng International Trading
Co., Ltd. (“Liaoning Yuzheng”) and that they would use an offshore
company to move funds.
iii. On or about November 9, 2016, KU JA HYONG and JIN YONGHUAN
caused Hong Kong Yuzheng, the offshore branch of Liaoning Yuzheng, to
receive a payment of approximately $994,980.00 from Dandong Zhicheng
Metallic Materials—a company which OFAC later sanctioned—which
payment cleared through a U.S. correspondent bank.
iv. On or about October 18, 2016, KU JA HYONG caused JIN YONGHUAN
to use Hong Kong Yuzheng, the offshore branch of Liaoning Yuzheng, to
make a payment of approximately $101,206.00 to a U.S. Company, which
payment cleared through a U.S. correspondent bank.
v. On or about November 9, 2016, KU JA HYONG and JIN YONGHUAN
caused Hong Kong Yuzheng, the offshore branch of Liaoning Yuzheng, to
receive a payment of approximately $100,000.00 from Ruizhi Resources—
33

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a front company for Dandong Zhicheng Metallic Materials—which
payment cleared through a U.S. correspondent bank.
vi. On or about January 4, 2017, KU JA HYONG and JIN YONGHUAN
caused Hong Kong Yuzheng, the offshore branch of Liaoning Yuzheng, to
make a payment of approximately $499,436.00 to a Chinese oil company,
which payment cleared through a U.S. correspondent bank.
vii. On or about June 8, 2017, KU JA HYONG sent JIN YONGHUAN coded
instructions to pay $77,400.00 to the U.S. Company, with a coded FTB
reference number.
viii. On or about June 8, 2017, KU JA HYONG sent JIN YONGHUAN coded
instructions to pay $21,000.00 to a Chinese communication company, with
a coded FTB reference number.
g.

FTB Kuwait
i. On or about February 8, 2017, RYU MYONG IL provided KWON SONG
IL a copy of RYU MYONG IL’s Kuwaiti identity card.
ii. On or about April 26, 2017, RYU MYONG IL corresponded with FTB
Headquarters.
iii. On or about May 15, 2017, RYU MYONG IL informed a co-conspirator
about coded payment transactions.
iv. On or about May 21, 2017, RYU MYONG IL informed FTB Headquarters
about crediting U.S. dollar payments he received from North Koreans in
Kuwait.
v. On or about June 26, 2017, KWON SONG IL received coded instructions
34

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from FTB Headquarters to pay $63,000.00 to a state fund for economic
development.
vi. On or about August 29, 2017, RI MYONG JIN of FTB Headquarters sent
RYU MYONG IL and KWON SONG IL coded instructions to pay
$705,000.00 to a foreign telecommunications company, with a coded FTB
reference number, on behalf of Cheo Technology joint venture.
vii. On or about September 11, 2017, RYU MYONG IL informed FTB
Headquarters about crediting payments he received from North Koreans in
Kuwait.
viii. On or about September 25, 2017, RYU MYONG IL confirmed in a coded
message to RI MYONG JIN of FTB Headquarters that RYU MYONG IL
paid $705,000.00 related to the foreign telecommunications company’s
invoice to Cheo Technology joint venture.
ix. On or about September 30, 2017, KWON SONG IL received an account
statement from a Kuwaiti financial institution.
x. On or about October 27, 2017, KWON SONG IL received a request from a
Kuwaiti financial institution to update his account information.
h.

FTB Thailand
i. On or about August 26, 2013, HYON YONG IL arranged for HAN UNG
of FTB Headquarters and RYU MYONG IL of FTB Kuwait to travel via
Air Koryo— an airline which OFAC later sanctioned—to Thailand.
ii. On or about July 11, 2014, HYON YONG IL received coded payment
instructions from FTB Headquarters to pay $50,340.00 to a Thai electronics
35

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company’s Singaporean bank account for a contract with the North Korean
government with a coded FTB reference number.
iii. On or about July 15, 2014, HYON YONG IL caused the wiring of
$30,340.00 to the Thai electronics company’s Singapore bank account,
which payment cleared through a U.S. correspondent bank.
iv. On September 17, 2015, HYON YONG IL emailed FTB Headquarters a
letter issued by FTB Headquarters that guaranteed payment to a Thai front
company for a shipment of aluminum to a North Korean purchaser with a
purchase price of $325,080.00, which if not paid to the Thailand front
company within six months, FTB Headquarters would debit the North
Korean buyer’s account and repay the full purchase price directly to the
Thailand front company.
v. On or about December 28, 2015, HYON YONG IL communicated with
FTB Beijing’s HAN YONG CHOL about obtaining Thai residency for an
incoming FTB Thailand agent, HWANG WON JUN, and provided a copy
of HWANG WON JUN’s North Korean passport, as well as his application
for residency in Thailand.
vi. On or about January 25, 2016, HYON YONG IL requested a Chinese
company to issue an invoice in the name of Kisgum Co., LTD, a FTB
Thailand front company.
vii. On or about January 28, 2016, HYON YONG IL received a message about
a banking problem due to OFAC and how they were working to solve this
problem.
36

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viii. On or about May 2, 2016, HYON YONG IL received a spreadsheet
detailing a profit–sharing plan between a business in Thailand and FTB,
which included expenses related to travel to/from North Korea.
ix. On or about April 21, 2017, JO UN HUI of FTB Headquarters sent
HWANG WON JUN coded instructions to pay Thailand Front Company 1
$49,785.00 at its Thailand bank account, with a coded FTB reference
number.
x. On or about July 19, 2017, HWANG WON JUN caused Kisgum Co, LTD,
a FTB Thailand front company, to pay approximately $45,839.12 to a
company which Australia subsequently designated, which payment cleared
through a U.S. correspondent bank.
xi. On or about October 9, 2017, HWANG WON JUN received coded
instructions to pay a communications company $50,250.00 at its Thai bank
account with a coded FTB reference number.
xii. On or about December 28, 2017, FTB Headquarters sent HWANG WON
JUN coded instructions to pay a technology company $600,000.00 on
behalf of a North Korean based electronics and communications company,
with a coded FTB reference number.
xiii. On or about December 29, 2017, HWANG WON JUN sent FTB
Headquarters a coded confirmation of the $600,000.00 payment, with a
coded FTB reference number.
xiv. On or about September 3, 2018, HAN KI SONG sent an order to First Credit
Bank, another sanctioned North Korean bank, to make a $25,000.00
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payment.
xv. On or about October 16, 2018, HAN KI SONG sent an order to First Credit
Bank, another sanctioned North Korean bank, to make a $50,000.00
payment.
xvi. On or about December 26, 2018, HAN KI SONG sent a copy of his North
Korean passport to a Thai company.
xvii. On or about March 13, 2019, HAN KI SONG sent an order to First Credit
Bank, another sanctioned North Korean bank, to make a $40,000.00
payment.
xviii. On or about May 23, 2019, RI MYONG JIN of FTB Headquarters sent
HWANG WON JUN coded instructions to pay two Chinese companies,
$303,329.83 and $1,000,000.00 respectively, both of which payments
included a coded FTB reference number.
xix. On or about June 12, 2019, RI MYONG JIN of FTB Headquarters sent
HWANG WON JUN coded instructions to pay $49,850.00 to a Thai
company and included a coded FTB reference number.
xx. On or about June 13, 2019, RI MYONG JIN of FTB Headquarters sent
HWANG WON JUN coded instructions to pay $50,250.00 to a Thai
telecommunication company and included a coded FTB reference number.
xxi. On or about June 14, 2019, RI MYONG JIN of FTB Headquarters sent
HWANG WON JUN coded instructions to pay $100,000.00 to a Chinese
technology company and included a coded FTB reference number.
xxii. On or about June 14, 2019, HWANG WON JUN informed RI MYONG JIN
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of FTB Headquarters that HWANG WON JUN had caused a payment of
$49,850.00 and included a coded FTB reference number.
i.

FTB Moscow
i. On or about December 30, 2015, HAN JANG SU informed KO CHOL
MAN and KIM TONG CHOL of FTB Headquarters that the FTB office in
Moscow was operational.
ii. On or about July 30, 2016, HAN JANG SU sent HAN YONG CHOL of
FTB Beijing a “Certificate of Appointment” document that identified HAN
JANG SU as the Deputy General Manager of a Dandong-based Chinese
trading company.
iii. On or about June 28, 2017, HAN JANG SU received a request from a
Russian bank for a letter from the North Korean government confirming RI
JONG WON’s status at FTB.
iv. On or about October 4, 2017, HAN JANG SU received a contract and
related documents, which detailed the sale of goods for $67,840.00 to be
paid via a U.S. correspondent bank, and that shipments would transit
through Dalian, China with an ultimate destination of North Korea.
v. On or about October 5, 2017, HAN JANG SU received a contract for the
purchase of goods in U.S. dollars for the Korea Gyonghung General Trading
Corporation in North Korea.
vi. On or about October 18, 2017, HAN JANG SU sent a Russian bank a letter
from FTB headquarters addressing problems with correspondent banking.
vii. On or about January 10, 2018, KO CHOL MAN, HAN UNG, RI JONG
39

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NAM, and O SONG HUI of FTB Headquarters caused HAN JANG SU to
send a letter to a Russian bank confirming their status as members of the
Board of Directors at FTB.
viii. On or about January 29, 2018, HAN JANG SU provided a Russian bank
with a signature card for FTB’s account signed by:
1. KO CHOL MAN, listed as Chairman and President;
2. HAN UNG, listed as Vice President;
3. RI JONG NAM, listed as Vice President;
4. RI YONG SU;
5. JO UN HUI;
6. O SONG HUI, and
7. RI JONG WON.
ix. On or about August 13, 2018, HAN JANG SU informed RI CHUN SONG
that banks required corporate registration documents notarized by the North
Korean embassy or Army commander in order to open a bank account for a
foreign company.
x. On or about January 10, 2019, HAN JANG SU received a due diligence
document for a Russian bank, which reflected that KO CHOL MAN was
the beneficial owner of FTB’s bank account and the chairman of FTB, and
that FTB was 100% owned by the government of North Korea.
xi. On or about January 10, 2019, HAN JANG SU received an inquiry from a
Russian bank about Ungum.
xii. On or about January 10, 2019, HAN JANG SU received a due diligence
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document for a Russian bank, which reflected that KIM KWANG CHOL
was the beneficial owner of Ungum’s bank account and the chairman of
Ungum, and that Ungum was 100% owned by the government of North
Korea.
xiii. On or about January 29, 2019, KO CHOL MAN, HAN UNG, RI JONG
NAM, and O SONG HUI of FTB Headquarters caused HAN JANG SU to
send a letter to a Russian bank confirming their status as members of the
Board of Directors at FTB.
j.

FTB Khabarovsk
i. On or about May 21, 2013, RI MYONG HUN obtained accreditation
documents from the Central Bank of Russia, which identified RI MYONG
HUN as the head of the Representative Office of FTB in Khabarovsk.
ii. On or about March 10, 2015, KIM TONG CHOL sent RI MYONG HUN
information about Shenyang Bright Century Trade Limited Co., a FTB
Shenyang front company.
iii. On or about August 27, 2015, RI MYONG HUN completed a signature card
of FTB Khabarovsk’s bank account at a Russian bank.
iv. On or about September 22, 2015, KIM SONG UI, identified as president of
FTB, signed a power of attorney authorizing KIM KYONG NAM,
identified as deputy head of FTB’s representative office in Khabarovsk, to
act on behalf of FTB with Russian banks and government entities, establish
correspondent banking relationships, provide assistance to FTB clients,
make deposits of FTB funds.
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v. On or about October 4, 2015, KIM SONG UI, identified as president of
FTB, certified that FTB Headquarters previously appointed KIM KYONG
NAM as the deputy head of FTB’s representative office in Khabarovsk.
vi. On or about October 4, 2015, KIM SONG UI, identified as president of
FTB, certified that FTB Headquarters previously appointed RI MYONG
HUN as the head of FTB’s representative office in Khabarovsk.
vii. On or about November 1, 2015, KIM KYONG NAM submitted due
diligence records to a Russian bank which identified KIM KYONG NAM
as an employee of the official representative office of FTB in Khabarovsk.
viii. On or about November 1, 2015, RI MYONG HUN submitted due diligence
records to a Russian bank which identified RI MYONG HUN as an
employee of the official representative office of FTB in Khabarovsk.
ix. On or about December 27, 2015, KIM KYONG NAM corresponded with
HYON YONG IL of FTB Thailand.
x. On or about January 27, 2019, RI MYONG JIN and JO UN HUI of FTB
Headquarters received a message from HAN JANG SU of FTB Moscow.
k.

FTB Vladivostok
xi. On or about April 17, 2017, HAN YONG CHOL of FTB Beijing sent a coconspirator bank account information for Velmur—a FTB Vladivostok
front company, which OFAC later sanctioned.
xii. On or about June 12, 2017, KIM HYOK JU caused a co-conspirator in
Russia to receive bank account information for Velmur, a FTB Vladivostok
front company.
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xiii. On or about the following dates, KIM HYOK JU caused the following wires
to Velmur, which payments cleared through a U.S. correspondent bank:
Date
May 5, 2017
May 9, 2017
May 10, 2017
May 12, 2017
May 12, 2017
May 24, 2017
June 1, 2017

Wire Amount
$1,199,975.00
$1,099,975.00
$999,975.00
$1,200,000.00
$1,510,000.00
$500,000.00
$490,000.00

Wire To
Velmur
Velmur
Velmur
Velmur
Velmur
Velmur
Velmur

xiv. On or about November 7, 2017, KIM HYOK JU provided a co-conspirator
in Russia with a copy of the U.S. Department of Justice’s forfeiture
complaint against FTB-front company Velmur.
(Conspiracy to Commit Offenses and Defraud the United States, in violation of Title
18, United States Code, Section 371)
COUNT TWO
(Violation of the International Emergency Economic Powers Act)
39.

The allegations set forth in Paragraphs 1 through 34 and 37 through 38 are

incorporated and re-alleged by reference in this Count.
40.

On or about March 20, 2015, KO CHOL MAN, RI CHUN HWAN, KIM HUI SUK,

KIM TONG CHOL, HUANG HAILIN, HUANG YUEQING, KIM CHIN a/k/a KIM JIN, JIN
YONGHE, and SUN WEI did willfully violate and attempt to violate the International Emergency
Economic Powers Act, by effecting payment of $100,000.00 from China Unitech, a FTB Zhuhai
front company, to Mingzheng, a FTB Shenyang front company, which transited through the United
States financial system, on behalf of the Democratic People’s Republic of Korea, without a license
or authorization obtained from the U.S. Department of the Treasury’s Office of Foreign Assets
Control located in the District of Columbia.
43

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(Unlawful Provision of Financial Services to a SDN in North Korea, in violation of
Title 50, United States Code, Section 1705; Title 31, Code of Federal Regulations, Part
544)
COUNT THREE
(Violation of the International Emergency Economic Powers Act)
41.

The allegations set forth in Paragraphs 1 through 34 and 37 through 38 are

incorporated and re-alleged by reference in this Count.
42.

On or about May 8, 2017, KIM SONG UI, HAN UNG, RI CHUN SONG, HAN

YONG CHOL, HAN JANG SU, RI MYONG HUN, KIM KYONG NAM. and KIM HYOK JU
did willfully violate and attempt to violate the International Emergency Economic Powers Act, by
effecting payment of $407,000.00 from a FTB Beijing front company to Velmur, a FTB
Vladivostok front company, which transited through the United States financial system, on behalf
of the Democratic People’s Republic of Korea, without a license or authorization obtained from
the U.S. Department of the Treasury’s Office of Foreign Assets Control located in the District of
Columbia.
(Unlawful Provision of Financial Services to a SDN in North Korea, in violation of
Title 50, United States Code, Section 1705; Title 31, Code of Federal Regulations, Parts
544 and 510)

44

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COUNTS FOUR – SEVEN
(Bank Fraud)
43.

The allegations set forth in Paragraphs 1 through 34 and 37 through 38 are

incorporated and re-alleged by reference in this Count.
44.

On or about the dates in the below chart by, within the District of Columbia and

elsewhere, the respective defendants attempted to execute a scheme and artifice to defraud, and to
obtain monies, funds, credits, assets, securities, and other property owned by, and under the
custody and control of a U.S. correspondent bank, which was a financial institution with deposits
insured by the Federal Deposit Insurance Corporation, by means of materially false and fraudulent
pretenses, representations, and promises:
COUNT DATE
DEFENDANTS
4
March 20,
KO CHOL MAN, RI
2015
CHUN HWAN, KIM HUI
SUK, KIM TONG CHOL,
HUANG HAILIN,
HUANG YUEQING, KIM
CHIN a/k/a KIM JIN, JIN
YONGHE, and SUN WEI
5
Nov. 9, KU JA HYONG and JIN
2016
YONGHUAN
6

7

May 8,
2017

KIM SONG UI, HAN
UNG, RI CHUN SONG,
HAN YONG CHOL, HAN
JANG SU, RI MYONG
HUN, KIM KYONG
NAM. and KIM HYOK JU
July 19, JO UN HUI and HWANG
2017
WONG JUN

TRANSACTION
China Unitech, a FTB
Zhuhai front company, to
Mingzheng

AMOUNT
$100,000.00

Ruizhi Resources to
$100,000.00
Liaoning Yuzheng, a FTB
Libya front company
FTB Beijing front company $407,000.00
to Velmur, a FTB
Vladivostok front company

Kisgum Co, LTD, a FTB
Thailand front company, to
a company which Australia
subsequently designated

$45,839.12

(Bank Fraud, in violation of Title 18, United States Code, Sections 1344(1) and 1344(2)).

45

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COUNT EIGHT
(Conspiracy to Launder Money)
45.

The allegations set forth in Paragraphs 1 through 34 and 37 through 38 are

incorporated and re-alleged by reference in this Count.
46.

Beginning in or around March 2013, and continuing up to and including in or about

June 2017, within the District of Columbia and elsewhere, the defendants, KO CHOL MAN, KIM
SONG UI, HAN UNG, RI JONG NAM, JO UN HUI, O SONG HUI, RI MYONG JIN, RI JONG
WON, JONG SUK HUI, KIM TONG CHOL, KIM CHIN a/k/a KIM JIN, HUANG HAILIN,
HUANG YUEQING, JIN YONGHE, SUN WEI, RI CHUN HWAN, KIM HUI SUK, HAN
YONG CHOL, RI CHUN SONG, RI JONG CHOL, KIM KWANG CHOL, RI YONG SU, KU
JA HYONG, JIN YONGHUAN, KWON SONG IL, RYU MYONG IL, HYON YONG IL,
HWANG WON JUN, HAN KI SONG, HAN JANG SU, RI MYONG HUN, KIM KYONG NAM,
KIM HYOK JU, and co-conspirators known and unknown to the Grand Jury, conspired with each
other and with others known and unknown to the Grand Jury to knowingly violate Title 18, United
States Code, Section 1956(a)(2)(A), that is, by transporting, transmitting, and transferring, or
attempting to transport, transmit, and transfer monetary instruments and funds from places outside
of the United States to and through a place inside the United States, and from a place in the United
States to or through a place outside the United States, with the intent to promote the carrying on
of specified unlawful activity, to wit, violations of: section 1344 (relating to financial institution
fraud); and the penalty provision of IEEPA.
The Object of the Conspiracy

47.

The objects of the conspiracy were:
a.

to illegally enrich the coconspirators;

b.

to illegally access the U.S. financial system; and
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c.

to promote the provision of financial services for a Specially Designated

National without the necessary OFAC licenses.
(Conspiracy to Launder Money in Violation of Title 18, United States Code,
Section 1956(h))
COUNTS NINE – TWELVE
(International Money Laundering)
48.

The allegations set forth in Paragraphs 1 through 34 and 37 through 38 are

incorporated and re-alleged by reference in this Count.
49.

On or about the dates in the below chart by, within the District of Columbia and

elsewhere, the respective defendants transported, transmitted, and transferred, and attempted to
transport, transmit, and monetary instruments and funds from places outside of the United States
to and through a place inside the United States, and from a place in the United States to or through
a place outside the United States, with the intent to promote the carrying on of specified unlawful
activity, to wit, violations of: section 1344 (relating to financial institution fraud); and the penalty
provision of IEEPA.
COUNT DATE
DEFENDANTS
9
March 20,
KO CHOL MAN, RI
2015
CHUN HWAN, KIM HUI
SUK, KIM TONG CHOL,
HUANG HAILIN, HUANG
YUEQING, KIM CHIN
a/k/a KIM JIN, JIN
YONGHE, and SUN WEI
10
Nov. 9,
KU JA HYONG and JIN
2016
YONGHUAN
11

May 8,
2017

KIM SONG UI, HAN
UNG, RI CHUN SONG,
HAN YONG CHOL, HAN
JANG SU, RI MYONG
HUN, KIM KYONG NAM.
and KIM HYOK JU
47

TRANSACTION
China Unitech, a FTB
Zhuhai front company, to
Mingzheng

AMOUNT
$100,000.00

Ruizhi Resources to
Liaoning Yuzheng, a FTB
Libya front company
FTB Beijing front
company to Velmur, a
FTB Vladivostok front
company

$100,000.00

$407,000.00

 Case 1:20-cr-00032-RC Document 1 Filed 02/05/20 Page 48 of 50

12

July 19,
2017

JO UN HUI and HWANG
WONG JUN

Kisgum Co, LTD, a FTB
Thailand front company,
to a company which
Australia subsequently
designated

$45,839.12

(International Money Laundering, in violation of Title 18, United States Code, Sections
1956(a)(2)(A), and 1956(h)).
COUNT THIRTEEN
(Continuing Financial Crimes Enterprise)
50.

The allegations set forth in Paragraphs 1 through 34 and 37 through 38 are

incorporated and re-alleged by reference in this Count.
51.

From in or about or about March 2013 to in or about December 2015 and on or

about January 2018 to the Present, within the District of Columbia and elsewhere, KO CHOL
MAN organized, managed, and supervised a continuing financial crimes enterprise, and received
$5,000,000 or more in gross receipts from such enterprise during any 24-month period.
(Continuing Financial Crimes Enterprise, in violation of Title 18, United States Code,
Sections 225).
COUNT FOURTEEN
(Continuing Financial Crimes Enterprise)
52.

The allegations set forth in Paragraphs 1 through 34 and 37 through 38 are

incorporated and re-alleged by reference in this Count.
53.

From in or about or about January 2016 to in or about December 2017, within the

District of Columbia and elsewhere, KIM SONG UI organized, managed, and supervised a
continuing financial crimes enterprise, and received $5,000,000 or more in gross receipts from
such enterprise during any 24-month period.
(Continuing Financial Crimes Enterprise, in violation of Title 18, United States Code,
Sections 225).
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FORFEITURE ALLEGATION
1.

Upon conviction of any of the offenses alleged in Counts One through Three of this

Indictment, defendants shall forfeit to the United States: (a) any property, real or personal, which
constitutes or is derived from proceeds traceable to the offenses, pursuant to Title 18, United States
Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any property, real
or personal, which constitutes, or is derived from, proceeds traceable to these offenses. The United
States will also seek a forfeiture money judgment against the defendants for a sum of money equal
to the value of any property, real or personal, which constitutes, or is derived from, proceeds
traceable to a violation of these offenses. The United States will also seek a forfeiture money
judgment for a sum of money equal to the value of any property, real or personal, which constitutes,
or is derived from proceeds traceable to these offenses.
2.

Upon conviction of the offense alleged in County Four through Seven of this

Indictment, defendants shall forfeit to the United States any property constituting, or derived from,
proceeds the defendant obtained, directly or indirectly, as the result of this violation, pursuant to
Title 18, United States Code, Section 982(a)(2)(A). The United States will also seek a forfeiture
money judgment against this defendant equal to the value of any property constituting, or derived
from, any proceeds obtained, directly or indirectly, as a result of this violation.
3.

Upon conviction of the offense alleged in Counts Eight through Twelve of this

Indictment, defendants shall forfeit to the United States any property, real or personal, involved in
the offense, or any property traceable to such property, pursuant to Title 18, United States Code,
Section 982(a)(1). The United States will also seek a forfeiture money judgment for a sum of
money equal to the value of any property, real or personal, involved in this offense, and any
property traceable to such property.
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4.

The specific property subject to forfeiture includes $63,511,387.85 frozen and

seized by the U.S. government between October 19, 2015 and January 9, 2020.
5.

If any of the property described above as being subject to forfeiture, as a result of

any act or omission of the defendants:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a third party;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property that cannot be subdivided without
difficulty;
the defendants shall forfeit to the United States any other property of the defendants, up to the
value of the property described above, pursuant to Title 21, United States Code, Section 853(p).
(Criminal Forfeiture, in violation of Title 18, United States Code, Sections 981(a)(1)(C),
982(a)(1), and 982(a)(2)(A); Title 28, United States Code, Section 2461(c); and Title 21,
United States Code, Section 853(p)).

A TRUE BILL

FOREPERSON

Attorney of the United States in
and for the District of Columbia

50