U.S. Department of the Treasury's OFAC Removes Two Chinese Companies and One Chinese National Linked to North Korea's SEK Studio from Sanctions List; Newly Designates 18 Iran-Related Targets
United States
On October 21, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) removed two Chinese companies and one Chinese national linked to North Korea's SEK Studio, as well as one Belarusian national, from the Specially Designated Nationals (SDN) List. On the same day, it newly designated five Iran-related individuals, four entities, and nine vessels.
Targets Removed from the List
Three North Korea-related targets were delisted: Shanghai Moxing Cultural Media (Moxing Cartoon), Shanghai Hongman Animation Design Studio, and Lu Hezheng. On the OFAC list, Moxing and Lu Hezheng were linked to SEK Studio, and Hongman was linked to Lu Hezheng. All are targets with addresses in the Xuhui District of Shanghai.
The Belarusian target is one individual, Andrei Rybakov, with an address in Minsk. He was listed under three different name spellings. This individual was a target of Belarus-related sanctions.
2021 Designations
The U.S. Department of the Treasury sanctioned them on December 10, 2021, on International Human Rights Day. At the time, a press release described SEK Studio as a "Government of North Korea-operated animation studio." It stated that animation workers located in North Korea and China perform work for foreign clients, and that foreign media companies continue to subcontract work in search of cheap labor.
According to the press release, SEK Studio utilized multiple front companies to evade sanctions targeting the North Korean government. Lu Hezheng was a high-level employee and former shareholder of Nings Cartoon Studio. Lu coordinated with SEK Studio representatives to facilitate financial transfers through Nings and other Chinese front companies. Lu is also the sole shareholder of Hongman Studio. These front companies have received millions of dollars from foreign clients in recent years.
The grounds for designation varied for each target: Lu Hezheng for having provided financial and material support to SEK Studio; Hongman for being owned or controlled by Lu Hezheng; and Moxing for having attempted to act for or on behalf of SEK Studio.
New Iran-Related Designations
The five newly designated individuals are all Panamanian nationals, two of whom also hold Greek nationality. All five are connected to Karnakis and Karnakis, a legal services firm based in Panama City.
The four entities are Karnakis and Karnakis, Singapore-based Amigoz Singapore, Panama-based Roxette Maritime Shipping and Trading, and Dubai-based Whales Shipping Line. Whales Shipping Line is linked to Amigoz Singapore.
There are nine vessels. The seven Panama-flagged vessels linked to Roxette Maritime are ANEMOS, DESTINY, FLAMINGO 1, GLORIS, HARMONY, PRIDE, and PRINCE. The two United Arab Emirates-flagged vessels linked to Whales Shipping are WHALES DIAMOND and WHALES PEARL.
General Licenses
On the same day, OFAC issued three general licenses. Iran General License GG authorizes the wind-down of transactions involving Karnakis and Karnakis. General License HH authorizes wind-down activities, limited safety and environmental transactions, and the discharge of cargo involving targets and vessels sanctioned on October 21. Russia General License 131K authorizes the negotiation and entry into contingent contracts and related maintenance activities for the sale of Lukoil International GmbH.
OFAC also amended Frequently Asked Questions (FAQs) 1224 and 1225.
Sources (KST)
- U.S. Department of the Treasury OFAC · Actions for 2026-10-21 · https://ofac.treasury.gov/recent-actions/20261021
- U.S. Department of the Treasury OFAC · 2021-12-10 Press Release · https://home.treasury.gov/news/press-releases/jy0526