by Hyun-seung Lee
Director of Policy & External Affairs, The Korea Signal
Last June, it came out that the governor of Jeju Province had sent North Korea about 160 million won — roughly $105,000 — worth of goods: a hemodialysis machine, citrus saplings, pest-control chemicals. When the story broke, Jeju’s defense was that the goods themselves were clean. Food and most medical equipment fall outside the UN Security Council’s banned categories, the province argued, and the Unification Ministry had signed off in advance. But the real exposure in this deal was never the cargo. It was who sat across the table from South Korean officials in Beijing: Ri Ho-Nam, a Reconnaissance General Bureau operative – the U.S. Treasury has designated a sanctioned individual. That alone was serious enough. What has come out since moves this into an entirely different category.
TV Chosun’s investigative team has obtained two versions of the contract behind this shipment. The substance is identical. What changes is who gets listed as a party to it. One version names all four real participants: North Korea’s disability welfare federation, a Chinese trading company based in Dandong, Jeju Province, and the South-North Korea Economic Cooperation Association. The other drops Jeju and the cooperation association entirely, leaving only the North Korean and Chinese companies as signatories. Neither document carries a date or a signature. According to the reporting, it was this laundered second version that Ri’s side handed to North Korean authorities — so that inside North Korea’s own paperwork, this would go down as Chinese aid, not South Korean aid. Seoul received both versions and approved the shipment and the contact with North Korean citizens anyway.
That’s worth sitting with. North Korea, under its “two hostile states” doctrine, has said it won’t accept assistance from the South. Jeju wanted to send the aid regardless. So this is what got built: a paper trail engineered so that Pyongyang, the very government receiving the shipment, would never see the word “Korea” on it. This isn’t a translation slip or an administrative shortcut. It’s a false record, manufactured on purpose, to misrepresent where the shipment actually came from. The Unification Ministry has described it as a “three-party agreement” arrangement with roots going back to 2019. But even a government official quoted in the same reporting admitted the explanation for why a second contract was necessary “falls somewhat short.” Something can be routine enough to be called precedent and still be something the government can’t fully account for. That’s not a procedural footnote. It’s a euphemism.
A Trick the World Already Has a Name For
International monitors and governments have spent nearly a decade documenting this exact move whenever North Korea’s other partners have pulled it. Not once has anyone called it ‘a matter of convenience’.
In 2016, the U.S. Justice Department indicted a Chinese trading company, Dandong Hongxiang Industrial Development, along with four of its executives. They had set up more than twenty shell companies from the British Virgin Islands to Hong Kong to Wales to run dollar transactions on behalf of a sanctioned North Korean bank, keeping the bank’s name off any paperwork Western financial institutions might see. Treasury froze the firm’s accounts and put the executives on the sanctions list, describing what they’d done as relying on “deceit, craft, trickery, and dishonest means” to hide who was really on the other end of the deal. Strip away the industry and the dollar figures, and the underlying mechanism is identical to what TV Chosun just found in Jeju’s contracts: build a fictional version of the deal for whoever needs deceiving, and keep the real one on file internally.
The 2019 case of the Wise Honest, a North Korean vessel the U.S. seized, lines up even more precisely, because the instrument used was exactly the same kind: a forged certificate of origin. When the coal freighter was caught off Indonesia, a local court ended up handing the cargo back to a broker after he produced a certificate claiming the coal had come from Russia. UN sanctions monitors condemned the ruling as flatly contradicting their own findings and Security Council resolutions. That document did one job: telling whoever was checking compliance that the goods hadn’t come from where they’d actually come from. Jeju’s second contract does the same job, just pointed in the opposite direction. Instead of a fake certificate telling outside monitors “this isn’t North Korean,” it’s a fake contract telling Pyongyang “this isn’t from South Korea.” The direction is reversed. The logic is identical.
Multilateral sanctions regimes exist specifically to close off the space where this kind of layered paperwork can operate. A coalition of governments and banks agreed, in effect, to watch for exactly this pattern — contracts that don’t match each other, intermediaries that vanish from one version of the record, and the party who actually needs watching quietly disappearing from whichever copy travels furthest. Secondary sanctions authority in particular exists for cases like this: the goods themselves might be perfectly legal, but the structure wrapped around them is built to hide who’s really involved. This isn’t a hypothetical. With the Unification Ministry’s own sign-off sitting in the file, a South Korean provincial governor just did it.
Two Reasons the Jeju’s Defense Doesn’t Hold
Fairness requires laying out the strongest case Jeju could make, and it isn’t nothing. A dialysis machine and citrus saplings aren’t centrifuge parts. Nothing in the reporting connects this shipment to a weapons program. Inter-Korean humanitarian exchange has a genuine legal basis under South Korean law, provincial governments have run channels like this before, and the Unification Ministry approved it going in, not after the fact. Read charitably, the double contract could be less a cover-up aimed at international monitors than a narrow accommodation to Pyongyang’s politics — not a dodge aimed at Washington, but a face-saving gesture aimed at the North, the kind inter-Korean diplomacy has leaned on before.
That reading collapses the moment you check whether the UN was actually told. Goods leaving South Korea for the North — medical equipment especially — are, in principle, supposed to go through prior review under the 1718 Committee’s humanitarian guidelines. But everything on the record so far shows only domestic approval from the Unification Ministry. There’s no evidence this shipment was separately notified to the 1718 Committee or granted an exemption. And this wouldn’t be the first time. In 2018, South Korea sent roughly 343 tons of petroleum products to the North without notifying the sanctions committee in advance, a fact that only surfaced later and triggered its own controversy. A good-faith arrangement wouldn’t need hiding. This one was built not to leave a trace — not for Pyongyang, and not for anyone watching from outside either.
There’s a second problem, and it concerns exactly how these goods made their way north. The person on the other side of the table wasn’t some anonymous welfare official. He was a Treasury-designated North Korean intelligence officer who has run back channels into the South for nearly three decades, and, according to the same reporting, personally requested the specific items in this shipment. Softening how aid is packaged for a difficult political partner is one kind of decision. Routing that aid through a sanctioned operative, then scrubbing the government’s own involvement from the paperwork at his request, is a different kind of decision entirely. Put those two facts together and this stops being awkward diplomatic practice. It becomes exactly what secondary sanctions law is written to catch: a designated person dictating the terms of a deal, and a third party structuring that deal to hide it.
At this point, what the double contract actually is becomes clear. The document does two jobs at once. One faces North Korea, erasing the South Korean origin of the aid so Pyongyang doesn’t have to reconcile it with its own policy. The other faces the outside world: if this shipment is ever investigated by the UN or Washington, the copy already sitting in North Korean hands will show “Chinese aid,” not South Korean aid. A document built to fool Pyongyang doubles as a ready-made cover story for anyone checking from the outside. That’s not a side effect. That’s the design. And it’s what turns this from an act of diplomatic tact into something with the hallmarks of sanctions evasion.
What Should Happen Now
First, the multilateral machinery built to catch exactly this kind of layered paperwork should request the full, unredacted record from Seoul. The UN Panel of Experts that used to monitor North Korea sanctions was effectively killed off in April 2024 after Russia vetoed its renewal; the Multilateral Sanctions Monitoring Team that has since picked up that watchdog role should ask for both versions of the contract, the shipping and customs documents, and confirmation the goods actually arrived. Jeju has so far refused to release this material even to its own National Assembly. A double-contract structure surfacing inside an allied government’s own aid program is exactly the kind of case that ought to be documented as a reference point for how far this technique has spread.
Second, Washington shouldn’t let this get filed away as a footnote in the bilateral relationship. When South Korea’s president attends the UN General Assembly this September, the U.S. delegation should raise this directly, not a general inquiry about inter-Korean exchange, but the double-contract mechanism specifically, and a demand for Seoul to explain, on the record, why a transaction its own ministry approved needed two different versions of the truth.
Third, The Treasury Department’s Office of Foreign Assets Control should open an immediate review of Governor Oh Young-hun’s personal exposure to sanctions. He is reported to have negotiated the aid program directly with a U.S.-designated individual, and the resulting shipment involved a contract submitted to North Korean authorities that had South Korea’s involvement stripped out. Neither fact, on its own, is enough to conclude in advance that Governor Oh personally meets the threshold for U.S. sanctions. But together they give OFAC ample reason to examine the full course of the transaction, how the double contract came to be drafted, and Ri Ho Nam’s role in it. If that review turns up something beyond an ordinary administrative judgment call, evidence of willful facilitation of sanctions evasion — then deciding what U.S. law permits in response, including possible individual designation, is a call for OFAC to make.
None of this is an argument against humanitarian engagement itself. It’s an argument that a false document is a false document no matter whose ministry stamped it. For a decade, the United States has told Beijing that shell companies and mismatched contracts are exactly how North Korea slips past international scrutiny. A treaty ally can’t run the same play and expect it to be called something else just because the goal was aid rather than weapons. Washington’s standing to hold China and Russia accountable for far larger violations has always rested on the idea that the rule applies to everyone equally. Jeju’s second contract is now a live test of whether that’s still true.
Hyunseung Lee is a North Korean escapee, human rights advocate, and lead strategist at the Global Peace Foundation, where he works on North Korea policy, human rights, and Korean unification. He is the founder of the North Korean Young Leaders Assembly and has advised the U.S. government and policy community as a consultant on North Korean affairs. Before defecting in 2014 amid a wave of severe regime purges, Lee held roles in North Korea’s shipping and mining sectors, facilitating trade between North Korea and China, and served as a sergeant in the special forces of the Korean People’s Army. He is a regular contributor to United Press International (UPI), Voice of America, and Radio Free Asia, among other global media outlets. Lee holds a bachelor’s degree in international trade and economics from Dongbei University of Finance and Economics in China and a master’s degree in public administration from Columbia University.
