ICAS Spring Symposium
The Korean Peninsula Issues
May 22, 2006 9:00 AM -- 7:30 PM
United States Senate Russell Office Building Caucus Room SR 325
Capitol Hill, Washington D.C. 20510
Institute for Corean-American Studies, Inc.
965 Clover Court, Blue Bell, PA 19422
Biographic Sketch & Links: Donald L. Glaser
The Case of North Korea
Donald L. Glaser
Deputy Assistant Secretary for Terrorist Financing and Financial Crimes
United States Department of Treasury
Thank you. Thanks for the introduction and thanks for having me here today. I always welcome the opportunity to speak publicly about what we're doing at the Treasury Department both with respect to North Korea, and really with respect to all of the exciting things that are going on recently at the Treasury Department.
I think what would be helpful for me to do would be to give you a little of the background on my office at Treasury, what we do, what authorities we have, how we approach both law enforcement issues and national security issues, and then really use the case of North Korea and the counterfeiting of U.S. currency as a good case study in how that works, why it works, and what the future for these types of actions is.
So let me just start with my office. I am the Deputy Assistant Secretary for Terrorist Financing and Financial Crimes within an office at Treasury called "TFI." The Office of Terrorism and Financial Intelligence. TFI was created by the U.S. Congress in March of 2004, so it's a very new component of the Treasury Department. It was established in recognition of the fact that the international financial systems represents both a tool, but also a vulnerability to any individual or entity who seeks to engage international illicit activity. TFI has two goals: our goals are - 1. to identify vulnerabilities in the international financial system that can be exploited by terrorists, by organized criminals, by rogue regimes, by kleptocrats (?), by anyone engaged in international illicit activity; identify and close those vulnerabilities in the U.S. and international financial system. And 2. to develop and implement strategies to disrupt and dismantle the financial networks that provide the underpinning for terrorists, organized criminals, rogue regimes - again, any entity involved in international illicit activity. So you could think of it as a defensive mission and an offensive mission. On the defensive side we identify and close vulnerabilities, and then on the offensive side, we identify, disrupt and dismantle the financial networks that support these groups and these jurisdictions and these individuals.
The ultimate goal of the whole enterprise is to make it costlier, riskier, harder, and less efficient for terrorists, organized criminals and the like to move their money through the international financial system.
This is really in a lot of respects a new approach to law enforcement and a new approach to international security, but it is one that is catching on and it is one that the international community is turning to more and more to face virtually any problem. If you look at the U.N. Security Council recently, virtually every international crisis that the U.N. Security Council has addressed, they have addressed at least in part with a financial component. The U.N. Security Council Resolutions 1267 and 1373 relating to terrorism have financial components to them. U.N. Security Council Resolution 1540 relating to WMD proliferation has a financial component to it. U.N. Security Council Resolution 1636 relating to the H....... assassination has a financial component to it. The U.N. Security Council Resolution relating to Liberia has a financial component to it. More and more and more we see the international community as recognizing that the international financial system - again, as I said before - represents not just a tool for illicit actors and an opportunity for illicit actors, but a vulnerability, because it is one of the times where any illicit actor, again - be it a terrorist, be it an organized criminal, be it a rogue regime - has to come up above the surface and interact, and interact with the system. And that provides us opportunities. And really, again, as we - and by creating TFI, I think Congress recognized that, the Treasury Department recognized that, the Administration recognized that. And as we work together with our partners, both in the Agency community in the U.S. and our counterparts throughout the world, we're going to be able to continually put pressure on illicit activities worldwide through our ability to affect the international financial system and the U.S. financial system.
So that's just a little bit of background as to who we are, how we're approaching these issues and a bit of context.
Now North Korea I think presents a good example of how all of this works, how the international financial system can facilitate illicit activity, and how the international community, working together, both the public sector and the private sector, to put pressure and make the international financial system again not an opportunity but a vulnerability for illicit activity.
The real fundamental place where they all comes together is in the case of North Korea and the counterfeiting of U.S. currency. The brand, the type, the series of counterfeit note has become known as "super notes." I'll just use the term "super note" to refer to the notes that are produced by North Korea. There really is very little question is involved in both the manufacture and distribution of counterfeit U.S. currency and there's very little question that this has been going on for many, many years. The first time that super note was detected was in 1989. Since that time there have been multiple investigations, there have been multiple arrests, there have been multiple seizures totaling $48 million in counterfeit U.S. currency represented as super note. These investigations, these arrests, these seizures have spanned the last 16, now close to 17 years. They have spanned geography throughout the world. The one thing that they have - the two things that they have linked to each other is - every seizure of these notes has been forensically linked to each other. All of these notes have been forensically to each other and all of them have involved distribution by North Korean diplomats. So we think that the evidence here is rather clear. In fact, last year Interpol issued an orange notice, an orange alert warning the international law enforcement community of the risks posed by North Korean efforts to obtain the materials needed to counterfeit U.S. currency.
I think that - I'll give one more example, because I think it's an interesting one. In 1996, the U.S. switched design of our $100 note from the little head to the big head, as they say. If you'll remember, we went to the big portrait. At that time, we switched to optically variable ink - OVI. It's a very, very expensive brand of ink. Extraordinarily expensive, and it is inserted into our currency as an anti-counterfeiting device. We have exclusive rights internationally to green-to-black color-shifting ink.
The same year, 1996, North Korea decided to re-design its currency; also decided to include optically variable ink in its currency. Green to magenta were the colors that they choose, magenta being the closest color to black in the ink spectrum. I don't think - I suppose I can't say this for sure - I don't think that there are criminal organizations out there seeking to counterfeit the North Korean Won. So one has to wonder why North Korea would invest so much money into incorporating optically variable ink as close to the color as they could get to the optically variable ink used by the United States to produce our currency. So this is what we face, and this is what we've faced for many years. And for many years we've been trying to persuade North Korea to cease this type of activity.
Our response to this type of activity changed and the decision was taken to apply the types of tools and authorities that we have at the Treasury Department that I discussed previously in terms of identifying vulnerabilities in the international financial system and targeting financial networks to disrupt and dismantle illicit activity. And that's what we did in this case, and I think we did so quite successfully.
On September 15, 2005 the U.S. Treasury Department designated Bank of Delta Asia in Macao - it's a primary money-laundering concern. The designation was based largely, primarily on the fact that Bank of Delta Asia served as a facilitative environment for North Korean illicit financial activities, including laundering the proceeds of counterfeit currency. This, I think, was a surprise to some people that we took this action. Frankly, anyone who had been watching the Treasury Department over the past couple of years should not have been surprised by this type of action. Section 311 is a relatively new authority. It comes from the Patriot Act of October 2001 but we've been applying it with increasing frequency. We've applied it to a number of jurisdictions and we've applied it to a number of institutions. We've applied it to two institutions in Latvia, an institution Belarus, an institution in Northern Cyprus, an institution in Syria, and now two institutions in Burma who were involved in narcotics trafficking, and now most recently we've applied it in the case of Bank of Delta Asia, as I said, for providing a facilitative environment for illicit North Korean activities including the laundering of the proceeds of counterfeit currency.
There's a number of things that I should emphasize about Section 311 so I'm going to talk in some detail about it because it's often mis-characterized, but it is unique authority. There is not a finance ministry in the world that has authority similar to Section 311, so it's not surprising that when you listen to public discourse about it, that people don't get it exactly right, exactly what it is, exactly what it isn't, exactly what it accomplishes.
The first thing to point out is - Section 311 is not a sanction. Almost universally, when I read the newspaper and see discussions about Section 311 it is referred to as a sanction. The Treasury Department does administer U.S. sanctions so we are quite familiar with the characteristics of a sanction. Section 311 is not a sanction. We refer to Section 311 as a defensive measure. There are two components to Section 311. The first component is identifying a vulnerability in the international financial system, which we did when we designated Bank of Delta Asia as a primary money laundering concern, and when we issued our proposed rule, we went into some detail, and I'll go into that in a second, as to why we regarded it as a primary money laundering concern. So that's the first component of it - identification.
Simultaneous with that identification - that identification then empowers the Secretary of the Treasury, in this case acting through the Director of FinSen (?), to issue a proposed rule to U.S. financial institutions, that if made final, would in this case require them to cut off correspondent relationships with the identified entity, essentially cutting the identified entity off from the U.S. financial system. No, it is not a freeze, it is not reaching out beyond the borders of the United States. It is an identification of a vulnerability followed by a regulation on U.S. financial institutions instructing them to take action to protect themselves from the identified vulnerability. That is what Section 311 is and that's how it worked in this case.
Our concerns with Bank of Delta Asia, as we discussed publicly in the Notice of Proposed Rule Making, which was put in the Federal Register on September 20, 2005, was that, as I said, Bank of Delta Asia provided a facilitative environment to illicit North Korean financial activity. Our concerns about Bank of Delta Asia are two-fold. Our concerns that led to the overall designation were two-fold. We had jurisdictional concerns regarding Macao and we had specific institutional concerns regarding the actual entity itself. And in many ways, the jurisdictional concerns about Macao could be thought - or the specific concerns about Bank of Delta Asia could be thought of as a microcosm of the larger concerns that we had about Macao. The concerns were both operational - or were both systemic and also more specific. Systemically, in the case of Macao, Macao had inadequate anti-money laundering, a counter-terrorist financing regime, and we felt that North Korea was operating within Macao in quite a tolerant environment.
Likewise, in the case of Bank of Delta Asia, Bank of Delta Asia was not living up to even the lax anti-money laundering regime that was present in Macao - that's the systemic concern - and also presenting of quite a facilitative environment for North Korean activities. That's the specific concern, and I'll give an example, and this is an example that was in the Notice of Proposed Rule Making that was published in the Federal Register on September 20.
In 1994 a North Korean front company called Nusoc (?) Won Trading Company had an account at Bank of Delta Asia. Two North Korean diplomats were apprehended attempting to pass hundreds of thousands of dollars of counterfeit U.S. currency through the Nusoc Won Trading Company account at Bank of Delta Asia. Those individuals fortunately were prevented from doing so.
Now you might ask, why am I giving this example? This is 1994 - so this is 12 years old now. Don't I have a better example? Don't I have something else that I could show you to demonstrate some sort of problem over the past 12 years? Well, the reason why I like to focus on this particular example is - the bank's reaction in 1994 to what had happened, because when we designated Bank of Delta Asia in September of this past year, the Nusoc Won Trading Company still had an account at Bank of Delta Asia. So I just put the question to you and let you work through it in your own head. If you were the owner of Bank of Delta Asia, if you were the compliance officer, and two North Korean diplomats attempted to move hundreds of thousands of dollars of counterfeit U.S. currency through Soc Won Trading Company's account at your bank, what would your reaction be? What would you do to protect yourself? What would you do to try to prevent this - your bank being used in the future?
Well, unfortunately in the case of Bank of Delta Asia, they didn't do anything. They continued the account relationship, they continued other problematic account relationships, and again, the facilitative tolerant environment that was present at Bank of Delta Asia continued up until the designation occurred. And so that's why I think it's a good example, because a lot of times again, when you listen to the public discourse on this, there's a lot of focus on the money laundering transaction. "Show us the money laundering transaction." And that's important - it's important to be able to pick specific instances out, but even more important are the systemic risks that Bank of Delta Asia presented to the U.S. and to the international financial community. After all, that's what Section 311 is all about - identifying vulnerabilities, and closing those vulnerabilities, and that's what we think we did with this designation.
Since the designation, as far as the jurisdictional issues, Macao has made great strides, we believe, both in dealing with its systemic issues and dealing with the specific issues. We have a very good working relationship with the Macanese authorities and we think they've done a really impressive job to try to address the systemic issues with respect to their legislative and regulatory regime, and also the Macanese authorities, as people probably know, did step in shortly after the designation and took over management of Bank of Delta Asia and continue to run that bank to this day. And there's a very good close relationship on that matter.
What it also did was trigger market forces. One of the powers of Section 311 and a lot of the financial tools that we have is it alerts the financial community to risks that they face, both specific risks but also broad risks. And I think that what you've seen in particularly the Asian financial market since the Bank of Delta Asia designation is more and more financial institutions are re-examining how they're doing business, and saying to themselves, "Gosh, there really is a risk that I'm involved in some sort of illicit activity. North Korea is a high risk customer. And what types of enhanced procedures do I need to have in place in order to do this type of business?" And I think that you've seen some financial institutions decide, "Well, the extra cost of ensuring that I'm engaged in a legitimate activity is not really worth the business - is not really worth the business profit that I'm making from the relationship." So I think that you've seen quite a displacement effect, quite a disruptive effect on the ability of North Korea, not only to engage in illicit financial activity simply through Bank of Delta Asia, but also in Macao and also, frankly, in Asia and the international community as a whole. On December 13, 2005 the Financial Crimes Enforcement Network, which is another office of the Treasury Department, issued an advisory to U.S. financial institutions, but it's on their Treasury website - it's available to all international financial institutions to read, says that we believe or at least are concerned that North Korea is going to attempt to find other vulnerable points of entry into the international financial system now that this particular point of entry has been disrupted. And so we are continuing to monitor this matter and we are continuing to work with our partners, both in governments and in private institutions worldwide to ensure that they have the information they need and to assure that they are taking protective measures that they need to take to protect themselves from money laundering and other types of financial crime.
We see this as, again, quite a good example of how effective we could be at the Treasury Department and how effective the international financial community - and when I say the "international financial community," I mean both the public sector and the private sector, exchanging information, working together, communicating with each other, taking advantage of market forces, to ensure that illicit actors do not have unfettered access to the financial system in order to engage in illicit activities.
So those really are my remarks. I'd be happy to take a couple of questions.
QUESTION: Richard Finney with Radio Free Asia. Has there been any evidence of Chinese government support for North Korean counterfeiting efforts, at any stage of this behavior that you've been watching?
GLASER: We've worked very closely with the Chinese government on this matter and particularly with the Peoples Bank of China. I think they're quite aware of the risks that North Korean counterfeiting presents. After all, if it's being passed in China, then it's the Chinese individuals and institutions and entities that are the victims of that crime. In fact, the Chinese - the Peoples Bank of China recently issued an advisory to certain Chinese entities warning them about North Korean counterfeiting. So I think that the Chinese government has responded quite appropriately to the risks that the North Korean counterfeiting has presented to them.
QUESTION: Okay - if I could follow up. There was an article which you may have seen by John Tassik (?) at the Heritage Foundation which said that this North Korean Trading Company relocated very quickly and with very little apparent trouble into the Juhai (?) economic zone after the Bank of Delta Asia was closed off to them. Are they still there, do you know? Or whatever became of them?
GLASER: I don't know the particular article that you're referring to but I can say more generally only that we are working very closely with our Chinese counterparts. I think that they are fully aware of the threat to the international financial system that illicit North Korean activities faces. China very much wants to be a full partner in the international financial system, the international financial community, and I have every confidence that China will take all actions it needs to take to make sure that its financial system is not being misused.
GLASER: When the Macanese authorities took control of Bank of Delta Asia they froze North Korean-related funds that were at the bank. And they are conducting an investigation right now into the activity within that bank. So that's what that's all about.
GLASER: Well, with respect to your first question on the types of tools we have at the Treasury Department - again, we have a whole wide variety of tools ranging from advisories to the financial sector which I mentioned that FinSen issued. We have Section 311. And then we do have at our disposal real financial sanctions, both targeted and more jurisdictional. Executive Order 13382, for example, relates to WMD proliferation and we have targeted numerous entities related to North Korea which respect to WMD proliferation. So we do have a range of tools starting from advisories and going through Section 311 all the way up and including targeted financial sanctions. In the case of North Korea, to deal with different types of concerns, we've employed a whole wide range of these types of activities, and again, I think it's a great example of how, approached strategically, we can choose from a range of tools in our arsenal to be very, very strategic and tactical in our approach to dismantling these types of financial activities. With respect to the Macanese monetary authority, I do believe they are independent from Beijing. Everything that I've seen has indicated it, but on the other hand, I'm not really an expert to internal Chinese politics.
GLASER: Sure. I'm going to answer your second question first. The United States implements UNSCR 1540 through our Executive Order on WMD proliferation. So we are leading the international community in implementing U.N. Security Council Resolution 1540. Through our targeted financial sanctions program related to WMD, the Treasury Department has designated entities related to Iran, related to Syria, and - I'm sorry, relating to Iran, relating to Syria and North Korea. And so we are continuing to do this. Clearly, the threat of WMD proliferation that it poses both to the U.S. and to our partners, and the community as a whole, is among if not the primary international security threat that we face, and so we have been moving very, very aggressively in this area and are certainly working closely with our partners around the world to try to persuade them to implement targeted financial sanctions programs along the same lines that we have. We think that the international legal basis for that is already there in 1540. Now it's just a matter of following through on that. As far as intelligence sharing within the U.S. Government, I'm really the wrong person to pose that question to. I can say that the case of Bank of Delta Asia demonstrates that when it works well, it could be highly successful.
GLASER: Well, thanks for that question. I'm actually glad you asked it because it gives me an opportunity to again try to unwind some of the different concepts that get tangled up in this issue when people talk about it. We have a targeted financial sanctions program relating to WMD proliferation that is different from the action that we took with respect to Section 311 of the Patriot Act targeting Bank of Delta Asia. Bank of Delta Asia was targeted because it was engaged in illicit financial activity relating to counterfeiting, relating to narcotics trafficking, relating to counterfeit cigarette smuggling, relating to a full range of illicit financial activity that North Korea engages in. We also have a targeted financial sanctions program grounded in UNSCR 1540, implemented through Executive Order 13382 that was signed by President Bush on June 30, 2005. Through that program, we have targeted a number of entities, many of which are related to North Korea, but that is separate. Now, a lot of - there's a lot of public discussion on the linkage between the Section 311 designation and the six-party talks. From our perspective, and I have said this every time I've spoken, every U.S. official has said this every time they have spoken - we could not be more clear on this particular issue. There is no linkage. And as I said - and that's kind of why I said this in my opening remarks - if you've been watching the Treasury Department over the past few years - if you haven't been watching the Treasury Department over the past few years, maybe this seems like it's emerging from somewhere else. If you've been watching the Treasury Department, how we've been operating, how we've been applying our authority, what we've been doing, this really shouldn't have come as a surprise. There is no linkage between our right and, frankly, our obligation to protect the U.S. financial system from abuse, which is our job at the Treasury Department, and the very important work that Ambassador Hill and others are doing in the political negotiations that they have. There is no linkage at all. Again, I've said that many times. I've been to Asia and engaged with our partners in South Korea and in Beijing. I've spoken in Japan. We have reiterated this to our partners, and they have all agreed with us, that this action should have no impact on the six-party talks, that we're fully within our rights and frankly, again, our responsibilities to protect the U.S. financial system from abuse.
QUESTION: . . . from Brookings, and I have two questions. As you mentioned, there has been some evidence about North Korean counterfeiting since the late 1980s, and as you mentioned, in 1996 when the United States changed its $100 bill, there was a corresponding change in the North Korean currency. And my first question is, before the United States finally took the financial regulatory action against Bank of Delta Asia in 2005, what were the assumptions within the government about North Korea's counterfeiting activities? Did the United States think that the magnitude of the counterfeiting wasn't large enough to warrant some kind of regulatory action or sanction? Or did the United States assume that this problem would go away if North Korea undertakes economic reform and managed to earn money sort of the old-fashioned way? That's my first question. Second question follows up on Mr. Joe .......'s $24 million question, and also another question posed right afterwards too. If there was no linkage between the Bank of Delta Asia action, advisory, and the six-party talks, was Ambassador Chris Hill sort of blind-sided in some way? I mean, how well informed was he prior to the authorities taking the financial regulatory action against North Korea, and moving forward, it seems that although you emphasized there's no linkage between the financial regulatory action and the six-party talks, North Koreans see a linkage, and in fact as was mentioned, they see this as evidence of sort of U.S. hostile policy (?) toward North Korea and unfreezing of this amount is going to be sort of a pre-condition for them to come back to the talks. And my second question is that according to the Department of Treasury Advisory, there's a specific passage that says - proceeds from North Korea's precious metals trade wound up in some of these accounts at the Bank of Delta Asia - that is licit trade, some proceeds from licit trade have also wound up there. So in order to - even if there's no linkage, in order to encourage North Koreans to come back to the talks, is there any possibility that the United States would encourage the Macao authorities un-freeze part of these accounts that have more to do with licit activities but not illicit activities?
GLASER: I tried to write down some of your questions to make sure I could respond to as much of it as possible. I think your first question was - if I could paraphrase it - the U.S. has known about this North Korean conduct for a long time. Why did it choose September 15, 2005 to finally act upon it? And again, I've been trying to answer this. It's a legitimate question to ask and I get asked it a lot and I always try to give a good answer. This is a new approach. The approach we're taking here is a new approach to the international financial system, to law enforcement, to national security. The Office of Terrorism and Financial Intelligence at the Treasury Department was established in March 2004. This is - it's a new office. These are new authorities that we have. So this is - again, if you've been following developments at the Treasury Department, if you've been following the way we've been trying to undermine terrorist financing networks, trying to undermine narcotics trafficking networks, trying to undermine WMD networks, if you've been looking at how we've been doing this, it's actually quite a logical straightforward step that we've taken here, and perfectly consistent with why this office was created, with the tools that Congress has given us to employ - I think this has been an example of a very effect employment of those tools. I can assure that all actions that we take are fully coordinated within the U.S. Government and particularly with the State Department. We are fully aware that any international step that we take has consequences that are relevant to the State Department, and our relationship with the State Department on this matter could not be better. I'm sorry - I don't remember what other questions there were, but I think that goes to most of it. Oh, yes, it really wouldn't be responsible for me to discuss ongoing developments with respect to ongoing investigations. It wouldn't be responsible for me to do that. The matter of Bank of Delta Asia is being looked into right now and we have good cooperation with the Macanese authorities. We're sure that cooperation is going to continue, and nobody wants more than us for there to be a speedy resolution to this overall matter. That being said, this has to be handled according to the law, it has to be handled comprehensively, and it has to be handled in a - we have to go through the process, and we will do that and we will wrap it up when we can, but it really wouldn't be responsible for me to speculate on any outcomes.
QUESTION: Good morning. My name is Jay Kong. I'm a retired professor. Do you know what type of major purchases they have made with that large sum of money? Do you know any cases that were major purchases they have made with their counterfeit notes?
GLASER: When we find the counterfeit money, we seize it. I don't know what happens to the money that we don't find. I do know that we have seized $48 million of super notes over the years.
QUESTION: I am a Korea correspondent for the CBS Christian Broadcasting System. Many people, especially Korean journalists working here, estimate that the United States will take other steps, or other sanctions toward North Korea. Do you have a plan to take those steps or other sanctions toward North Korea in the coming days or in coming months?
GLASER: Well, if you're asking about Section 311, I hate to come back to it, but Section 311 is not a sanction. And I wouldn't comment in any case on whether we have intentions to employ Section 311. As we've said publicly, we are continuing to monitor the international financial system, and we will take any appropriate steps that need to be taken in order to protect the U.S. financial system from . . . .with respect to our targeted financial sanctions program relating to WMD proliferation, we have designated North Korean entities and as I said, we'll continue to designate entities as we discover them and as we determine that's the appropriate response.
QUESTION: My question focused on the United States ..... sanctions. You didn't say. What do you think about other sanctions toward North Korea? Do you have a plan?
GLASER: I think I've responded to that question.
QUESTION: No, no, no. Many people, Korean journalists and Asian journalists working here want to know about the U.S. position about North Korea.
GLASER: I don't know how I could be more clear. With respect to Section 311, which is not a financial sanction, we don't announce our intentions to take future action. All we say is that we monitor the international financial system -
QUESTION: Is the United States investigating other illicit activity of North Korea? .......
GLASER Are we looking into illicit North Korean activities?
QUESTION: Yeah, now. Now. Right now.
QUESTION: Your job.
QUESTION: My name is Yuri (?). I'm a Japanese correspondent with NHK - Japan Broadcasting Corporation. I have two questions. First question is, have you seen any indication that North Korea has suspending the counterfeiting operation, or do you still see any concern (?) of banks in Asia? That's my first question. And my second question is: what other currencies do you believe that North Korea is counterfeiting?
GLASER: With respect to your first question, we do believe that they are continuing to counterfeit U.S. currency. If you want more details on that, I'd actually recommend you contact the U.S. Secret Service, which is the law enforcement agency here in the States that's charged with primary investigative authority into counterfeiting. With respect to other currencies that they're counterfeiting, I've heard lots of rumors about North Korea counterfeiting other currencies. I can't confirm any of those, other than to say that we know that they're counterfeiting the U.S. dollar.
QUESTION: Do you still have any concerned banks in Asia which facilitate North Korea to have the counterfeited money?
GLASER: I'm sorry - are you asked if we're concerned about any other banks in Asia? Is that the question?
GLASER: Again, I'm sorry to keep giving the same answer to this question. We are monitoring the entire international financial system and we will take appropriate action as we deem necessary.
QUESTION: Do you now where Kim Jong Il and his cohorts have their financial assets abroad? And do you know of any legal authority, that under the proper circumstances would allow you to seize his personal assets?
GLASER: That would allow us to seize them? Well, we couldn't seize them unless they were within U.S. jurisdiction. But I would speculate that he does have substantial assets outside of North Korea, and I don't know what his annual salary is, but I suspect it greatly exceeds his annual salary. So that brings in - the U.N. has promulgated a convention on corruption, and certainly international financial institutions have anti-money laundering compliance programs that would hopefully prevent them from being unwittingly implicated in such activity.