(C) IRAN, NORTH KOREA, AND SYRIA NON PROLIFERATION

S E C R E T SEOUL 002076

SIPDIS

STATE PASS TO ISN/MTR, EAP/K

E.O. 12958: DECL: 10/22/2018
TAGS: PARM PREL MNUC ETTC
SUBJECT: (C) IRAN, NORTH KOREA, AND SYRIA NON PROLIFERATION
ACT -- NOTIFICATION OF SANCTIONS AGAINST A SOUTH KOREAN
ENTITY

REF: STATE 111822

Classified By: POLMC Joe Yun for reasons 1.4 (B, D, H).


1. (U) This is an action request. Please see para 3.


2. (SBU) On October 22, poloffs delivered reftel demarche
to Ministry of Foreign Affairs and Trade (MOFAT),Disarmament
and Nonproliferation Division's First Secretary Jae-woo Kim.
Kim was very concerned about Yolin Technology's sanction
notification in the Federal Registrar. He stressed that he
would distribute the non-paper to his supervisors for
discussion and follow-up.


3. (S) In the meantime, Kim requested a prompt USG response
to the following questions:

--Why did the USG take so long to initiate this action, since
the ROK took action against Yolin in October 2006? Was the
USG's action prompted by the ROK's actions against Yolin, a
USG investigation regarding the May 2006 event, or a separate
USG investigation of a new incident involving Yolin? If the
last case, the ROK would like all relevant information on new
violations.

--Besides its successors, subunits, and subsidiaries, will
the sanctions effect Korean entities that do business (trade
or financial) with Yolin?

--Can Yolin lodge a formal complaint, protest, or appeal
outside the legal system?

--What measures must Yolin undertake to remove itself from
the sanctions list in two years? Is it possible to be
removed earlier? Specifically, are there compliance measures
or reporting mechanisms that will facilitate Yolin's removal
from the list of sanctioned entities?

--If the ROK sanctions the company or successfully prosecutes
the individual(s) involved, is there a waiver available that
will remove Yolin from the list of sanctioned entities, or at
the very least, allow it to participate in the sanctioned
commercial activities?


4. (SBU) We would appreciate the Department's early
response to MOFAT's queries above.
STEPHENS