Sanctions Evasion Reference

Vietnam Beverage: alcohol to North Korea, paid by 17 firms

A Vietnamese drinks holding company paid OFAC $860,000 in 2024 after its subsidiaries invoiced North Korean buyers in dollars and were paid by 15 third-party companies in Hong Kong, China and Turkey, plus two more in Singapore and the Seychelles.

period

2016–2024

outcome

Settlement

parties

Vietnam Beverage Company Limited

programmes

Democratic People's Republic of Korea

reviewed

2026-09-20

Cite this page
APA 7 
Sanctions Evasion Reference. (2026, September 20). Vietnam Beverage: alcohol to North Korea, paid by 17 firms. https://sanctionsevasion.org/cases/vietnam-beverage-north-korea-2024/
Chicago 
Sanctions Evasion Reference. “Vietnam Beverage: alcohol to North Korea, paid by 17 firms.” Last reviewed September 20, 2026. https://sanctionsevasion.org/cases/vietnam-beverage-north-korea-2024/.
BibTeX 
@misc{ser-cases-vietnam-beverage-north-korea-2024,
  author = {{Sanctions Evasion Reference}},
  title  = {Vietnam Beverage: alcohol to North Korea, paid by 17 firms},
  year   = {2026},
  note   = {Last reviewed 2026-09-20},
  url    = {https://sanctionsevasion.org/cases/vietnam-beverage-north-korea-2024/}
}

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

Penalties imposed

AuthorityDate AmountNote
OFAC 2024-10-17 $860,000 43 apparent violations; non-egregious, not voluntarily self-disclosed. Base penalty $1,720,000.

A small case with an unusually clear picture of the payment pattern.

What happened

Vietnam Beverage acquired a majority stake in several Vietnamese alcohol companies in late 2017. Those subsidiaries had legacy customers in or connected to North Korea. Between January 2016 and September 2018 they signed 26 contracts to sell beer and spirits to North Korea, with two North Korean firms and two third-party companies, in Singapore and the Seychelles. Senior managers approved the contracts, and OFAC says nearly all the paperwork referred to North Korea and to payment in US dollars.

The subsidiaries issued 47 invoices under those contracts. The 43 payments that followed, totalling about $1,141,547 between April 2016 and October 2018, came from 15 different third-party companies, seven in Hong Kong, four in China and four in Turkey, plus the two companies in Singapore and the Seychelles. All were paying on behalf of the North Korean buyers or unknown entities in North Korea, and all 43 transfers went through US correspondent banks or, in one case, a foreign branch of a US bank.

Neither the holding company nor the subsidiaries had a sanctions compliance programme. New management learned of the sales in December 2019, ended them, and told OFAC.

The penalty

Non-egregious and not voluntarily self-disclosed. The base was the sum of the schedule amounts, $1,720,000, and the settlement was half of that, $860,000. OFAC credited substantial cooperation, including information on similar violations, and remedial measures. See how penalties are decided.

What the record shows

  • The documents named North Korea and the payments came from elsewhere. Payment by unrelated third parties in several countries is what separated the paperwork from the money.
  • The dollar was the hook. The sales were in dollars, so each payment had to clear in the US.

See third-country bank accounts, correspondent banking abuse, and the Hong Kong and Türkiye pages.

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.
  • Hong Kong — A major financial and trading centre whose company formation regime, banking sector and re-export role place it in a large share of published corporate concealment cases.
  • Türkiye — A large manufacturing and transit economy whose trade with several restricted destinations has grown substantially, making it central to third-country routing analysis.

Enforcement documents and sources

  1. Enforcement release: Vietnam Beverage Company Limited settles with OFAC for $860,000. U.S. Department of the Treasury, Office of Foreign Assets Control, 2024. Enforcement release, 2024-10-17, US$860,000.
  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