Satellite imagery of Nampo port shows North Korean waters busier than at any point on record. A year-long investigation by the Citizens' Alliance for North Korean Human Rights (NKHR), supported by expert maritime analysis from Data Desk (UK) and combining vessel-tracking analysis of 47 ships, has found that sanctioned North Korean vessels are now making more foreign port calls than at any point since before the pandemic. Based on testimony from 22 witnesses, the report reveals that the Ministry of National Defense has consolidated an almost total monopoly over North Korea's coal and mineral exports and is managing its profits through a financial architecture built entirely inside China that international sanctions have failed to reach.
The breakdown of international sanctions monitoring has coincided with a steep increase in vessel detections at North Korea's five major ports, rising from 783 in 2019 to 3,756 in 2025. More than 3,000 of those detections were recorded at Nampo alone - North Korea's largest oil and coal cargo terminal and its primary maritime gateway - where foreign flags of convenience have been largely replaced by Chinese-flagged vessels, signaling a deepening normalization of direct Chinese commercial involvement in sanctioned North Korean trade.
Coal exports from North Korea are often produced by slave labor enforced by the Ministry of State Security and Ministry of Public Security - the institutions responsible for the gravest human rights violations inside the country - but their export is controlled almost exclusively by enterprises affiliated with the Ministry of National Defense, which owns the transport infrastructure and commands the border and coastal zones through which smuggling occurs. The revenue does not pass through the international banking system. Instead, it is managed through secret accounts in Chinese banks, rendering the 2017 SWIFT exclusion of North Korea largely ineffective. Funds never need to enter North Korea: export proceeds and stolen wages earned by overseas forced laborers are all settled within China by representatives of each North Korean organ and spent on military imports and goods there.
The same sanctioned vessels supposed to have been grounded by international sanctions framework are now making more foreign port calls. The steepest increase is observed after Russia's 2024 veto of the UN Panel of Experts of 1718 Sanctions Committee, the body that was mandated to monitor North Korean sanctions violations. A Russian-operated pier at Rajin port in the DPRK's Special Economic Zone, operating supposedly under a sanctions exemption, appears in vessel-tracking records as a loading and offloading point for coal. Given that the Republic of Korea has not imposed a full ban on Russian coal imports since Russia's invasion of Ukraine, the route raises serious concerns about North Korean minerals entering South Korean supply chains disguised as Russian in origin.
For the United Nations and multilateral bodies
1.1. The UN High Commissioner for Human Rights should recognize the overlapping role between human rights violations entrenched in North Korea’s political economy and the profits from those violations directed toward North Korea’s weapons program, which threatens peace and security on the Korean Peninsula and beyond through growing weapons revenue and should recommend an independent body to investigate these links.
1.2. The UN Security Council member states should convene a special briefing dedicated to the situation in the DPRK to urgently discuss the critical links between human rights and security, with primary focus on the connection between the DPRK’s military and security forces, their international supply chains tied to mining and light industry, and the associated crimes against humanity.
1.3. Support the Multilateral Sanctions Monitoring Team with a mandate that includes formal consultation with civil society organizations that produce these kinds of investigations.
For national governments
2.1. Governments and bodies with targeted human-rights sanctions authority should pursue sanctions against the individuals and entities identified in this and other reports by the Citizens’ Alliance for North Korean Human Rights.
2.2. Add the 20 unsanctioned high-risk vessels identified in the companion database (Section V) to relevant sanctions lists, prioritizing those with the clearest route overlap with already sanctioned vessels.
2.3. Pursue secondary sanctions and enhanced due-diligence requirements targeting the Chinese ports, flag-of-convenience shipping registries, and companies operating the vessels flagged in this report and database.
2.4. Expand joint maritime surveillance and intelligence-sharing among allied navies and coast
guards operating in the Yellow Sea and East China Sea. Port authorities should separately increase surveillance of mineral shipments arriving from China.
2.5. South Korea and Japan should enact and enforce import-ban legislation that includes a rebuttable presumption of forced labor for products, including minerals and light-industry goods, from countries or regions at high risk of state-imposed forced labor, including North Korea, and should adopt human-rights-targeted sanctions legislation.
2.6. The European Commission should classify North Korea as a high-risk country given its use of state-imposed forced labor in prison camps, recognizing that resulting goods and minerals may stem from gender-based, political, or religious persecution and from forced labor exploited for profit, moving through transnational supply chains into China, Russia, and global markets.
For financial regulators and institutions
3.1. Treat correspondent banking relationships and customer accounts linked to Dandong, Shenyang, and Beijing-based trading entities and banks as elevated money-laundering and sanctions-evasion risk requiring enhanced due diligence.
3.2. Strengthen monitoring of China-based banks, given their documented role in converting sanctions-linked funds into usable currency for North Korean front companies.
For supply chain actors, importers, and corporate entities
4.1. Conduct sanctions and forced-labor due diligence on coal and mineral sourcing anywhere the supply chain touches Chinese ports, Russian ports, the Rajin-Sonbong area, or trading companies near the North Korea border.
4.2. Screen vessel charters and bills of lading against the companion high-risk vessel database (Section V) before contracting for bulk coal or mineral shipments originating from or transiting Northeast Asian ports.
4.3. Recognize that officials may face criminal liability for aiding, abetting, or otherwise contributing to crimes against humanity or forced labor through financial aid or the provision of goods, information, or services, and put in place a mechanism to identify and report instances of forced labor in the supply chain to relevant authorities.
4.4. Where due diligence reveals that an enterprise has caused or contributed to forced labor, cooperate with relevant authorities to help provide appropriate forms of remedy to those affected.
Victim redress and accountability
5.1. Recognize that North Korean victims residing in South Korea who provided evidence for this report, having suffered crimes against humanity and forced labor linked to businesses within the North Korean supply chain, are entitled to reparations.
5.2. South Korea, as a global leader on this issue, should spearhead international support for an International Anti-Corruption Court to prosecute and punish kleptocrats and their collaborators, and to recover, repatriate, and repurpose ill-gotten gains for the victims of grand corruption.
NKHR's Recommendations:
