Sanctions Evasion Reference

Mondo TV: paying a North Korean studio through a US company

An Italian animation company paid OFAC $538,000 in 2024 after making 18 payments to a North Korean government studio through two Chinese firms and a US company's American bank accounts, on the studio's invoices.

period

2019–2024

outcome

Settlement

parties

Mondo TV, S.p.a.

programmes

Democratic People's Republic of Korea

reviewed

2026-09-20

Cite this page
APA 7
Sanctions Evasion Reference. (2026, September 20). Mondo TV: paying a North Korean studio through a US company. https://sanctionsevasion.org/cases/mondo-tv-north-korea-2024/
Chicago
Sanctions Evasion Reference. “Mondo TV: paying a North Korean studio through a US company.” Last reviewed September 20, 2026. https://sanctionsevasion.org/cases/mondo-tv-north-korea-2024/.
BibTeX
@misc{ser-cases-mondo-tv-north-korea-2024,
  author = {{Sanctions Evasion Reference}},
  title  = {Mondo TV: paying a North Korean studio through a US company},
  year   = {2026},
  note   = {Last reviewed 2026-09-20},
  url    = {https://sanctionsevasion.org/cases/mondo-tv-north-korea-2024/}
}

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

Penalties imposed

AuthorityDate AmountNote
OFAC 2024-06-26 $538,000 Payments of about $537,939 between May 2019 and November 2021; non-egregious, not voluntarily self-disclosed. Base penalty $725,000.

An EU company’s case, and a plain one: the counterparty was known, and the only question was how to pay it.

What happened

Mondo, headquartered in Rome, had subcontracted animation work to a studio owned by the North Korean government since the 1990s. It paused the relationship in 2016 over human rights concerns, and in July 2019 agreed to pay a debt of about $1.1 million in monthly instalments and to commission new projects.

Before each payment the studio issued an invoice that named a third-party company and its bank account. The studio named two companies in China and one in the United States, with accounts at several US financial institutions. Mondo paid those accounts, believing the payments settled debts the studio owed them. OFAC says Mondo “understood it was paying a DPRK company” throughout: the CEO signed the 2019 agreement, which referred explicitly to North Korea, and emails named Pyongyang and the US company and banks.

Between May 2019 and November 2021 Mondo made 18 wire transfers destined for the studio that were processed or settled at US institutions: 12 to the US company’s account at a US bank, one clearing through a US correspondent bank, and five to a foreign company’s account at a US bank. OFAC designated the studio in December 2021.

The penalty

Non-egregious and not voluntarily self-disclosed: the base was $725,000, the settlement $538,000. OFAC described the conduct as reckless disregard, noted that senior management knew, and credited cooperation and Mondo’s assistance with wider US government objectives. Mondo had no sanctions compliance policy at the time.

What the record shows

  • The invoice told the payer where to send the money. The instruction to pay a third party came from the sanctioned party itself.
  • Knowing the counterparty was not enough of a control. Senior management knew, and the payments still went through US banks.

See third-country bank accounts.

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.

Enforcement documents and sources

  1. Enforcement release: Mondo TV, S.p.a. Settles with OFAC for $538,000. U.S. Department of the Treasury, Office of Foreign Assets Control, 2024. Enforcement release, 2024-06-26, US$538,000.
  2. Economic Sanctions Enforcement Guidelines, Appendix A to 31 CFR Part 501. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026. Sections I (definitions), II (responses), III (general factors), V.B (penalty calculation).

All enforcement cases