Our Island Plan

Sanctions Update: Cyber

Wednesday, 19 November 2025

This news release is issued to publicise the addition of six entries and the amendment of 1 entry under the Cyber Sanctions Regime.

The Cyber (Sanctions) (EU Exit) Regulations 2020 have effect in the Isle of Man by the Sanctions (Implementation of UK Sanctions) Regulations 2024 ('the Regulations'), which are made under the Sanctions Act 2024. These Regulations impose financial and immigration sanctions for the purposes of furthering the prevention of cyber activity.

Those persons who are designated under this regime are included on the UK Sanctions List.

Types of sanctions applicable under this regime:

  • Asset freeze
  • Immigration

On 19 November 2025 the Foreign, Commonwealth and Development Office updated the UK Sanctions List. This list provides details of those designated under sanctions legislation.

Addition

Six entries have been added to the UK Sanctions List and are now subject to an asset freeze. Further information can be found in the Annex to this notice.

Amendment

One entry has been amended from the UK Sanctions List and is still subject to an asset freeze.

Deleted information appears in [square brackets]. Additional information appears in italics.

Entity

  1. [CHOSUN EXPO (APT 38)] CHOSUN EXPO a.k.a: (1) Chosen Expo (2) Korean Export Joint Venture Address: North Korea. Other Information: (UK Sanctions List Ref): CYB0004. (UK Statement of Reasons): [The Lazarus Group was responsible for relevant cyber activity that resulted in data interference which directly or indirectly caused, or is intended to cause, economic loss to, or prejudice to the commercial interests of, those affected by the activity through stealing money from Bangladesh Bank, attempting to steal money from Vietnam Tien Phong Bank and targeting the Polish Financial Conduct Authority information systems. Through the WannaCry attack they undermined the integrity of the United Kingdom through interfering with an information system so that it prevented the provision of essential healthcare services to the population.] Chosun Expo, a front company used by malicious cyber actors operating under the Reconnaissance General Bureau (RGB), has been responsible for, engaging in, providing support for, or promoting the commissions, planning or preparation of relevant cyber activity, including data interference and accessing information systems. Such activity that Chosun Expo is or has been involved in undermines, or is intended to undermine, the integrity, prosperity or security of the United Kingdom or a country other than the United Kingdom and directly or indirectly caused economic loss to, or prejudice to the commercial interests of, those affected by the activity. (Type of entity): Company (Subsidiaries): Reconnaissance General Bureau Listed on: 31/07/2020 UK Sanctions List Date Designated: 31/12/2020 Last Updated: [31/12/2020] 19/11/2025 Group ID: 13910

What you must do

If you suspect a person or entity is a match to a person or entity included in the UK Sanctions List, and you hold or otherwise deal with funds or economic resources of that person:

  1. You must freeze the assets immediately

  2. You must review the information you hold for that person against the UK Sanctions List to ensure you do not have a false positive identification

  3. Do not deal with those assets or make them available to, or for the benefit of the designated person unless:
    • You have a legal exemption
    • You have a licence

  4. You must report the frozen assets to the FIU

If you have a suspicion or knowledge that there has been a breach of sanctions law, or any attempted transactions that you have blocked, report your suspicions to the FIU.

Failure to comply with financial and trade sanctions legislation or to attempting to circumvent its provisions is a criminal offence.

Where a relevant institution has already reported details of accounts, other funds or economic resources held frozen for the designated person, you are not required to report these details again.

Note: determining if a customer is on the UK Sanctions List includes whether any corporate entity is owned or controlled, directly or indirectly, by a person on the UK Sanctions List.

Further guidance on false positives and delistings and what to do can be found in the Financial Sanctions General Guidance page.

Further information

Further details on the UN measures in respect of Cyber sanctions can be found on the relevant UN Sanctions Committee webpage.

Further information on the sanctions regime related to Cyber and other sanctions related guidance can be found on the Sanctions and Export Control website on the Sanctions Guidance page.

Contact details for enquiries

If you require any further information or guidance, please contact the Sanctions Team on:

Telephone: +44 1624 648109
Email: sanctions@gov.im

Please note: We are unable to provide legal advice. You may need to seek independent legal advice.

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