Key highlights include findings on the forced deployment of North Korean military personnel to Russia under the guise of educational visas, sanctions evasion through masked “scholarships” payments, and the identification of over 100 DPRK-linked entities in Russia, most linked to North Korean nuclear and ballistic weapons program and export of weapons.
Drawing on financial records, registry data, and information from North Korean and Russian sources, with support from Transparency International-Russia investigative teams, the evidence reveals that individuals connected to the top Russian officials have played significant roles as enablers. These include the involvement of Russian financial institutions and companies, some of which maintain networks within the EU market.
NKHR's Recommendations:
1. To effectively update the milestone UN Commission of Inquiry’s 2014 report on the DPRK, an intersectional approach is essential. Such an approach should connect the state’s mass atrocities to its illicit economic activities and the military and security organs that both operate the abusive system and sustain profits. The same organs pose threats to international security through their involvement in the expansion of weapons program by the DPRK. We call on the international community to urgently adopt and discuss this comprehensive framework.
2. The Citizens’ Alliance for North Korean Human Rights calls on all concerned states to recommend that the President of the UN Human Rights Council appoint a panel of experts. This panel, in collaboration with the UN Special Rapporteur on the Situation of Human Rights in DPRK, should examine the institutional framework, individuals involved, and chain of command of the military and security forces in the DPRK, including Ministry of State Security, Ministry of Public Security, Ministry of Defence, Second Economic Committee with its Department 93, the Munitions Industry Department with its 131 Nuclear Guidance Bureau as well as Bureau 39 that are responsible for and are profiting from commission of mass atrocities, including imprisonment, enslavement, rape and sexual violence, torture, extermination, and persecution based on gender, religious and/or socio-political (songbun) grounds, as well as trafficking for exploitation through labor. It is important to analyze how these forces are able to sustain themselves through their involvement in these abuses and the international supply chain, business and military networks that support them. Mirroring Myanmar’s Fact-Finding Mission, the report should analyze the state’s structures, expose the criminal enterprise rooted in a slavery system, and detail all companies profiting from a business model that involves committing crimes against humanity and is linked to weapons program, as these weapons are used to commit war crimes in other countries.
3. The European Commission should designate North Korea as a high-risk country for its use of state-imposed forced labor. This practice is prevalent in its domestic prison camps for consumer goods production and extends to trafficking citizens for forced labor abroad, notably in Russia. In line with the EU regulation that prohibits products made with forced labor, an investigation is warranted. This inquiry should focus on banning goods from Russian agricultural and textile companies identified as using North Korean labor, especially those with investors or retailers in the EU market. Furthermore, all companies must be mandated to implement robust due diligence processes, ensuring their supply chains are free from any involvement with North Korean forced labor.
4. All United Nations member states must implement a warning system for companies, alerting them to the heightened risk of complicity in severe human rights abuses when conducting business with North Korean authorities, their representatives, or affiliated entities, whether directly or indirectly. Under the UN Guiding Principles on Business and Human Rights and the UN Global Compact, states are obligated to ensure that companies carry out thorough human rights due diligence.
5. The government of the Republic of Korea should strengthen monitoring and enforcement measures targeting financial flows linked to North Korean military, security, and state trading entities operating abroad. When companies operating in the Republic of Korea or engaged in transactions with Korean financial institutions are found to be interlocked with Russian entities implicated in the use of North Korean forced labor or in financing the DPRK’s military and security organs, authorities should freeze and seize associated assets and suspend financial transactions. Financial regulators and investigative bodies should also enhance cooperation with international partners to identify shell companies, intermediaries, and joint ventures connected to the DPRK’s military-industrial and security apparatus and their breaches of international sanctions.
6. The Republic of Korea should also adopt Magnitsky-style targeted sanctions legislation, enabling the government to impose asset freezes and travel bans on foreign individuals and entities responsible for serious human rights abuses and corruption. Such legislation would allow South Korean authorities to sanction North Korean and Russian officials involved in forced labor trafficking, crimes against humanity, and illicit financial networks that fund the DPRK’s weapons program and security apparatus.
7. In addition, the Republic of Korea should introduce mandatory human rights due diligence requirements for Korean companies operating internationally. These measures should require companies to ensure that their supply chains and business partners are not linked to North Korean forced labor, prison camp production, or enterprises controlled by
DPRK military and security organs operating abroad, including in the Russian Federation.
8. The Multilateral Sanctions Monitoring Team (MSMT) should regularly consult with civil society and investigative journalists. These consultations should focus on examining evidence of slavery, crimes against humanity, and forced labor trafficking within DPRK supply chains, particularly where profits are funneled into its weapons program and linked to its military and security forces, in violation of international sanctions.
9. For effective sanctions against DPRK entities, bilateral and multilateral coordination is crucial and should involve closing loopholes in information sharing and enforcement. Currently, numerous Russian financial, business, and academic institutions that facilitate forced labor trafficking from North Korea have not been officially sanctioned for this role. Many of these entities have ties to the highest structures and officials of the Russian government. While some have faced selective sanctions for their involvement in the aggression against Ukraine, their part in enabling forced labor linked to the DPRK’s military, security forces, and weapons program has been largely ignored. This oversight is particularly evident with two key DPRK entities: the 131 Nuclear Guidance Bureau (under the Munitions Industry Department) and Department 93 (under the Second Economic Committee). These groups are responsible for uranium mining, operating the Punggye-ri nuclear test site, and developing nuclear and ballistic missiles. For the past decade, they have funded these activities by trafficking military contingents to Russia for exploitation through labor and operating military-linked companies there. Despite their direct involvement in both global security threats and severe human rights abuses, neither entity has been sanctioned. These are long-term ongoing violations of UN Security Council’s Resolution 2375 (2017) which prohibits joint ventures with North Korean entities, and exploit loopholes in the UN Security Council’s Resolution 2397 which required all UN member states to repatriate North Korean nationals earning income abroad by 22 December 2019 and prohibited states from issuing new work authorizations to citizens of the DPRK to cut financial flows that contribute to funding the DPRK’s nuclear and ballistic missile programs.
10. Countries with Magnitsky-style sanctions should target North Korean and Russian officials, individuals, and entities responsible for human rights abuses and corruption. Specifically, those listed in the accompanying database should be sanctioned for their involvement in trafficking North Koreans for forced labor in Russia. This scheme enriches North Korean elites through Bureau 39 companies and military and security forces through their companies, thereby funding the same security apparatus responsible for the persecution and crimes against humanity documented by the 2014 UN Commission of Inquiry.
11. As a member of the International Coalition for an International Anti-Corruption Court, we urge governments worldwide to support this crucial initiative. The Court would have the power to prosecute and penalize kleptocrats and their collaborators, as well as recover and repatriate illicitly gained assets to aid the victims of grand corruption. This includes the victims of North Korea, whose access to justice is severely restricted. The UN Commission of Inquiry’s recommendation to refer DPRK officials to the International Criminal Court remains unenforced, highlighting the urgent need for a dedicated body to hold corrupt leaders accountable.
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