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2020/04/01 - [가상화폐] - [북한 관련 UN 보고서] 북한의 가상통화를 활용한 금융제재 회피
2020/02/02 - [가상화폐/자금세탁방지법] - 북한이 가상화폐를 통해 자금을 북한으로 옮긴 것으로 추정
아래 내용은 우리나라 언론에도 소개되었던 내용인데, 북한의 소행이라고 하지만 참으로 참신한 투자형태이다. 선박투자를 블록체인 기반으로 여러사람들이 투자하여 지분을 나눠가지는 형태의 사업을 홍콩에서 진행했다는 내용이다. 실제 사업내용이 중요하다기 보다는 이러한 방식으로 법인을 세우고 바지사장인 현지인 대표를 통해 북한의 자금을 세탁하는 내용이 핵심이다. 이 홍콩법인은 오로지 이러한 목적으로 활용되었고, 홍콩법인 대표는 실제로 자신의 법인의 운영자금을 제공하는 북한사람의 정체도 정확히 모르고 그의 지시에 따라서 여러가지 업무를 수행하였는데, 결과적으로 이러한 활동이 북한의 자금의 출처를 둔갑시키는 자금세탁의 목적으로 활용되었을 가능성이 높을 것으로 보인다.
Asset-backed cryptocurrency company using blockchain technology to generate revenue
69. Registered in Hong Kong on 12 April 2018, Marine Chain Platform Limited 40 was set up as a blockchain-enabled platform for vessel transactions that offered partial ownership of maritime vessels in exchange for digital tokens. According to a Member State, Marine Chain had ties with the Democratic People’s Republic of Korea, and at least one company employee had links to Democratic People’s Republic of Korea cyber actors who have extorted Bitcoin from online companies. The Member State further indicated that Marine Chain’s start-up funds likely came from the extortion of cybercurrencies. The Panel investigated Marine Chain for evasion of financial sanctions and the prohibition of cooperative entities pursuant to paragraph 18 of resolution 2375 (2017).
70. The Panel’s investigation found that, while Captain Jonathan Foong Kah Keong was formally listed as the Chief Executive Officer of Marine Chain Platform Limited (Hong Kong Companies Registry No. 2679578), in reality, Julien Kim was the owner, sole investor and de facto Chief Executive Officer, directing all company activities through orders that he gave to Foong and other consultants. All documents and communications issued by Kim were done in the name of his alias, “Tony Walker”, with the exception of an internal company phone list describing “Julien Kim aka Tony Walker” as “Brain child and main investor” and a consultancy contract that Kim had signed with Foong on 18 January 2018 to set out his responsibilities as Kim’s external face and facilitator, with a number of tasks relating to setting up the company and bank account and signing all official paperwork (see annexes 25–28).
71. In terms of the company’s financial operations, Foong undertook multiple transfers on behalf of Kim from his company account in a Singaporean financial institution. Foong stated, “I would use my Singclass account (which is my business separate from Marine Chain) to make some of these payments upon receiving payments from Tony and upon Tony’s instructions to pay them. This was because the Singclass account was the only USD account that I had”. The payments into the account from Kim (in amounts ranging from $30,000 to $150,000) were all done through Hong Kong front companies, with a separate company used for each transaction. The payments processed by Foong through Singclass International Pte Ltd included some that appeared suspicious (see annex 29). A summary of further findings on this case is contained in annex 27.