Crisis Management for a Conflict with North Korea

Steptoe & Johnson LLP | English | AcademicThink | Nov. 19, 2025 | Geopolitical Conflict and Disputes

The US Attorney for the District of Columbia, DOJ, FBI, and US Secret Service have launched a new interagency Scam Center Strike Force to combat scams targeting Americans from Southeast Asian scam compounds linked to Chinese transnational crime organizations (TCOs). These agencies, in coordination with the State Department, OFAC, and Commerce, will use sanctions, seizures, and prosecutions to disrupt scam operations and provide victim education and restitution. This initiative coincides with fresh sanctions on Chinese TCO-linked armed groups and companies operating scam centers in Myanmar and Thailand. Southeast Asian scam centers employ trafficked labor and exploit weak governance and special economic zones to host large-scale investment and romance scams, causing American losses estimated at over $16.6 billion, with blockchain analytics tracking global scam losses exceeding $53 billion since 2023.

International efforts to counter Southeast Asian scam centers have intensified, with coordinated actions including the largest US-UK sanctions targeting the Cambodia-based Prince Group network and Myanmar’s military shutdown of the KK Park scam center. China has increased pressure on Myanmar to target these centers, arresting 57,000 Chinese nationals suspected of involvement. However, dismantling centers remains challenging due to rapid relocation and money laundering through luxury assets and cryptocurrencies in regions with weak governance. The US Strike Force represents a move toward more integrated enforcement tactics, potentially supported by international cooperation initiatives such as a proposed China-Thailand joint venture.

OFAC designated 32 individuals and entities across multiple countries on November 12 for involvement in procuring materials supporting Iran’s ballistic missile and UAV programs linked to the IRGC-QF, marking the second round of nonproliferation sanctions following the reinstatement of UN sanctions after the JCPOA suspension. Additionally, OFAC and FinCEN partnered with Mexico to sanction 27 individuals and entities supporting the Hysa Organized Crime Group, implicated in cartel-run money laundering through gambling establishments. The US aims to completely eliminate cartel influence within its borders, consistent with President Trump’s executive orders.

Following a November 10 meeting between President Trump and Syrian President Ahmed al-Sharaa, the US suspended mandatory sanctions under the Caesar Syria Civilian Protection Act. This decision follows removal of SDGT designations on al-Sharaa and the Syrian Interior Minister by OFAC and the UNSC. The US may pursue a full repeal of the Caesar Act, as indicated in Senate legislation. Concurrently, a Tri-Seal Advisory was issued clarifying permissible activities under the relaxed sanctions regime.

OFAC issued or amended four Russia-related general licenses in mid-November to authorize certain transactions involving Rosneft and Lukoil subsidiaries, following designations of these companies in October. The UK updated its Iran Nuclear Sanctions guidance in response to reintroduced UN sanctions, increasing compliance requirements for sectors like energy and finance. The UK Export Control Joint Unit reported a decline in export licenses issued in Q2 2025 and longer processing times, with total license value dropping to £2.7 billion.

UK authorities charged the Hauser & Wirth gallery and art shipper Artay Rauchwerger Solomons with violating Russia luxury goods export sanctions related to a 2022 sale. This marks the first criminal enforcement under the UK’s Russia luxury goods restrictions, signaling higher scrutiny of high-value art transactions. OFSI issued a new general license allowing continuation of business with certain Lukoil Bulgaria entities under UK sanctions.

The UK announced plans to ban maritime services related to Russian liquefied natural gas (LNG) exports, including shipping and insurance, as part of a phased 2026 implementation alongside the EU, extending its 2023 import ban on Russian LNG. The EU updated its dual-use export control list to incorporate emerging technologies such as AI processors and quantum-safe cryptography, reflecting 2024 international non-proliferation revisions.

China suspended counter-sanctions on South Korea’s Hanwha Ocean subsidiaries for one year, following the US’s suspension of investigation measures targeting China’s maritime and shipbuilding sectors, signaling efforts to ease trade tensions. In retaliation to Japan’s sanctions over Ukraine, Russia imposed indefinite entry bans on 30 Japanese nationals, including government officials.

Australia eased sanctions on Syria’s energy and banking sectors on November 14, removing certain export controls on petrochemical goods and delisting two Syrian banks from financial sanctions. This marks a significant relaxation of restrictions on Syrian industries.