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12 Aug 2025

Pathways to Accountability in the DPRK: Sanctioning the Facilitators of Forced Labour

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Accountability and Rule of Law

Pathways to Accountability in the DPRK: Sanctioning the Facilitators of Forced Labour

The Democratic People’s Republic of Korea (‘DPRK’ or ‘North Korea’) continues to operate one of the world’s most entrenched systems of state-imposed forced labour. Over 100,000 DPRK nationals are currently believed to be working overseas across a number of countries, although predominantly in Russia and China. These workers are subjected to 12- to 16-hour workdays under the constant surveillance of state security officers, are only allowed one or two rest days per month, and face constant threats, physical and mental abuse. Severely underpaid, much of their wages are appropriated by the State. In addition to these working conditions, DPRK nationals are stripped of their fundamental rights, including freedom of movement, expression, and association, enduring conditions akin to modern slavery.

This system is not an accidental by-product of authoritarian governance: it is a key pillar of DPRK’s economic structure, which heavily relies on the exploitation of its citizens both within the country’s borders and abroad. Since 2021, Global Rights Compliance (‘GRC’) has made significant progress in promoting justice for victims of human rights violations perpetrated by the DPRK, in collaboration with local partners. The team is currently investigating and mapping the DPRK’s overseas forced labour apparatus, including by identifying and exposing the networks of state-sponsored entities and individuals responsible for facilitating and profiting from these exploitative practices. Our work is grounded in rigorous evidence collection and legal analysis with the goal of triggering the action of accountability mechanisms. Sanctions play a central role in this accountability landscape, especially in a context like DPRK where the options to pursue justice are limited. They have become an increasingly important instrument for governments and international bodies in the fight against forced labour, designed to target individuals and entities complicit in human rights violations. Magnitsky-style sanctions – named after Sergei Magnitsky, a Russian lawyer who was tortured and killed after uncovering government corruption – are a particularly effective accountability tool. These targeted sanctions allow governments to freeze assets, restrict international travel, and publicly designate individuals and entities involved in serious human rights violations and abuses.

Both the United States and the European Union have adopted global human rights sanctions regimes that could be effectively applied to DPRK and associated actors. The U.S. Global Magnitsky Human Rights Accountability Act and the EU Global Human Rights Sanctions Regime have already been used in similar contexts, most notably in response to forced labour practices in China’s Xinjiang region.

The case of Uyghur population in Xinjiang: a powerful example of sanctions targeting forced labour About eleven million Uyghurs, a mostly Muslim, Turkic-speaking ethnic group, live in the northwestern region of Xinjiang. This region has become the centre of widespread human rights violations, with the Chinese government enforcing a policy of forced labour targeting the Uyghur minority. Many are detained in so-called “re-education camps” and forced to work in factories producing goods for both domestic consumption and export. These workers are often coerced into labour under threat of detention and torture. Once detained, they are subject to constant surveillance, as well as the use of fabricated administrative and criminal charges to justify their continued imprisonment. In response to these violations, in 2020, the U.S. placed sanctions on Chinese government officials and companies involved in forced labour, such as Xinjiang Production and Construction Corps (‘XPCC’), a state-owned enterprise heavily implicated in the exploitation of Uyghur labour. These sanctions froze the assets of individuals and entities linked to forced labour and barred them from entering the United States. The EU has followed suit with similar measures, imposing asset freezes and travel bans on Chinese officials associated with the repression of the Uyghur people. The Xinjiang precedent offers a compelling framework for action on DPRK. North Korea’s overseas labour system mirrors many of the same characteristics: centralised state control, mass surveillance, wage theft, and the deployment of ideological justification for exploitative practices. The legal basis for sanctions in the DPRK context is equally clear, and the practical mechanisms are already in place. What remains lacking is political will.

Whilst sanctions can effectively disrupt the financing of perpetrators and restrict their mobility, they should not be viewed as a standalone solution: they are just one piece of the puzzle. The international accountability system is inherently complex and demands a holistic approach to adequately address the wide-ranging human rights challenges posed by the DPRK. This comprehensive approach should also encompass diplomatic pressure, transitional justice initiatives, engagement with human rights mechanisms, and the establishment of procedures to ensure criminal accountability.

By Adele Macor,

August 2025.