Sanctions Evasion Reference

Bukit Muria Jaya: cigarette paper for North Korea, paid in dollars

An Indonesian paper manufacturer paid OFAC $1.0 million in 2021 after selling cigarette paper to North Korea, swapping DPRK names for intermediaries on its paperwork and taking payment through a dollar account that cleared in the US.

period

2016–2018

outcome

Settlement

parties

PT Bukit Muria Jaya (BMJ); Korea Daesong General Trading Corporation

programmes

Democratic People's Republic of Korea

reviewed

2026-10-01

Cite this page
APA 7 
Sanctions Evasion Reference. (2026, October 1). Bukit Muria Jaya: cigarette paper for North Korea, paid in dollars. https://sanctionsevasion.org/cases/bukit-muria-jaya-dprk-2021/
Chicago 
Sanctions Evasion Reference. “Bukit Muria Jaya: cigarette paper for North Korea, paid in dollars.” Last reviewed October 1, 2026. https://sanctionsevasion.org/cases/bukit-muria-jaya-dprk-2021/.
BibTeX 
@misc{ser-cases-bukit-muria-jaya-dprk-2021,
  author = {{Sanctions Evasion Reference}},
  title  = {Bukit Muria Jaya: cigarette paper for North Korea, paid in dollars},
  year   = {2026},
  note   = {Last reviewed 2026-10-01},
  url    = {https://sanctionsevasion.org/cases/bukit-muria-jaya-dprk-2021/}
}

The date is when this page was last reviewed, not when it was first published.

Penalties imposed

AuthorityDate AmountNote
OFAC 2021-01-14 $1,016,000 28 apparent violations; not voluntarily self-disclosed, non-egregious. Base penalty $1,270,000; statutory maximum $8,621,816. OFAC's claim was deemed satisfied by a greater payment to the Department of Justice for the same conduct.

The goods never touched the United States. The invoices did, in the form of dollar wires.

The sales

PT Bukit Muria Jaya (BMJ), an Indonesian paper-products maker, exported cigarette paper worth about $959,000 to entities in or acting for North Korea. Some went to an intermediary in China that bought on behalf of Korea Daesong General Trading Corporation, which OFAC had designated in 2010 as controlled by Office 39 of the Korean Workers’ Party. Daesong was operating under an alias.

The paperwork

BMJ’s sales documents first named DPRK entities. At customers’ request, BMJ sales employees later replaced those names with intermediaries in third countries, on invoices, packing lists and bills of lading. Management knew the goods were for the DPRK and knew the nexus had been removed from the documents. See third-country transshipment and the China page.

The dollars

BMJ told customers to pay into its US dollar account at a non-US bank. That put 28 wire transfers through US banks between March 2016 and May 2018, including payments connected to shipments for a blocked North Korean person. OFAC treated that as BMJ causing US banks to deal in blocked property and to export financial services to the DPRK. See third-country bank accounts.

The penalty

Non-egregious and not self-disclosed, at $1.0 million against a $1.27 million base, with credit for cooperation and a remedial programme: a new compliance head reporting to the president, third-party screening, a written sanctions policy, know-your-customer escalation, and anti-diversion agreements for any trading company buying on behalf of end users. The payment was deemed satisfied by a larger payment to the Department of Justice.

What the record shows

  • Editing names out of documents is the signature. The record does not show an outsider forging anything; it shows sales staff changing a customer name on request.
  • The same exposure through a different product. Compare the British American Tobacco case: tobacco-related trade with the DPRK and US dollar clearing.
  • OFAC points to its own Framework. It notes that non-US persons are repeatedly caught by causing US persons to take part, and that the risk is “particularly acute” with DPRK companies and those acting for them.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • North Korea sanctions — The most comprehensive UN-mandated regime, prohibiting most trade with North Korea, backed by Panel of Experts reporting that documents evasion in unusual detail.
  • China — A very large manufacturing exporter, named as a transshipment point in US export-control alerts on Russia and described in Multilateral Sanctions Monitoring Team reporting as the place North Korea's stolen cryptocurrency is cashed out.

Enforcement documents and sources

  1. OFAC Settles with PT Bukit Muria Jaya for Apparent Violations of the North Korea Sanctions Regulations. U.S. Department of the Treasury, Office of Foreign Assets Control, 2021. Enforcement release, 2021-01-14, US$1,016,000.
  2. A Framework for OFAC Compliance Commitments. U.S. Department of the Treasury, Office of Foreign Assets Control, 2019. Risk Assessment, Mergers and Acquisitions (M&A); Root Causes, item III; General Aspects of an SCP, Testing and Auditing.

All enforcement cases