The New Face of North Korean Sanctions Monitoring: Can the MSMT Pick Up Where the Panel of Experts Left Off?
In February 2025, the Steering Committee of the Multilateral Sanctions Monitoring Team (MSMT) held its inaugural meeting in Washington, DC. The MSMT is a voluntary collective of 11 member states (Australia, Canada, France, Germany, Italy, Japan, the Netherlands, New Zealand, South Korea, the United Kingdom, and the United States) that have committed to jointly monitor the implementation of United Nations (UN) sanctions against North Korea’s nuclear weapons and missile programs.
This sanctions monitoring function was previously performed by the UN Panel of Experts on North Korea (the Panel), a group of experts (including representation from the United States, South Korea, China, and Russia) that worked directly under the 1718 Committee of the UN Security Council but was disbanded in April 2024 after Russia vetoed the renewal of its mandate as part of its political alignment with North Korea. In response to the Panel’s dissolution, the MSMT emerged as a ‘coalition of the willing’ to continue its work, notably outside of the UN and without the participation of China and Russia.
The entry of the MSMT comes at a critical time, when the implementation of UN sanctions against North Korea is suffering from major gaps; when massive programs of state-sponsored sanctions violations are being reported; and when the sophistication, resilience, and efficacy of North Korean sanctions evasion tradecraft is reaching new heights. Effective sanctions monitoring is one of the few remaining tools to reign in such transgressions, thereby restricting North Korean access to the materials, technologies, and funds required to further develop its nuclear weapons and missile capabilities. However, questions remain as to whether the MSMT is up to the task: can a new body operating outside of the UN and without the participation of North Korea’s two largest trading partners establish itself as an effective and consequential alternative to the Panel?
Ultimately, the success of the MSMT will depend on its ability to maintain impartiality, secure cooperation from a wide range of stakeholders, and translate its findings into meaningful action.
How Will Russia and China respond?
Under the UN system, Russian and Chinese membership on the Panel and veto power in the 1718 Committee could be (and was) used by Moscow and Beijing to block from public UN reporting sanctions violations involving Russian and Chinese entities. As the Russians and Chinese will not enjoy such powers in the MSMT, we would expect MSMT reporting to be more forthcoming regarding such violations, which are many, high-value, and, in some cases, reportedly state-sanctioned.
How Moscow and Beijing respond to this increased scrutiny will be worth watching. They will almost certainly attempt to cast doubt on MSMT findings by accusing the MSMT of being illegitimate and driven by Western political interests—Russia even made such accusations against the Panel (on which it sat). But Moscow and Beijing may also take more aggressive actions, for example ramping up their anti-sanctions rhetoric; retaliating politically or economically against MSMT member states; or attempting to interfere with MSMT operations, for example through cyber-attacks or the intimidation of investigators.
To What Extent Will the MSMT Report on Russia and China?
The threat of such Russian orChinese retaliation risks may introduce discord into the MSMT. MSMT member states may be inclined to ‘pull their punches’ when reporting on Russian/Chinese sanctions violations if doing so would compromise political or economic relationships with Moscow or Beijing. Many member states, for example, are strong traders with China, and thus may fear trade sanctions from Beijing. Similarly, the United States may be reluctant to ‘go after’ Russian entities for fear of derailing ceasefire talks on Ukraine.
Thus, despite the like-mindedness of member states in their support for the rules-based international order and sanctions against North Korea, there is likely to be some amount of political horse-trading when it comes to reporting on Russian and Chinese entities. This risks weakening the MSMT’s capability for comprehensively reporting on sanctions violations involving North Korea’s two largest political and economic partners.
How Independent Will the Investigations Be?
One advantage of North Korean sanctions monitoring involving Russian and Chinese participation (as with the Panel) was that they “provided a challenge function within the panel which, while often inconvenient, made the final consensus more powerful.” No longer constrained by Russian and Chinese interference, it is reasonable to question whether the MSMT will pursue their mission with rigor and impartiality, or whether they will allow investigations and allegations of collusion with North Korea to become a cudgel with which to pursue foreign policy objectives against other states (while acknowledging that Moscow and Beijing will allege this either way). How MSMT member states safeguard the independence of their delegates will be critical.
What will the MSMT do with its findings?
There’s then the question of what the MSMT will do with the findings of its investigations. To be sure, simply publishing them has passive benefits: it alerts governments and industry to trends in sanctions evasion tradecraft; it names-and-shames entities involved in sanctions violations; and it signals an ongoing commitment (at least by MSMT member states) to nuclear non-proliferation.
But investigations will also open opportunities for active interventions by MSMT member states to improve sanctions compliance. For example, the findings may direct outreach and capacity building to entities and jurisdictions involved in sanctions violations. Or MSMT member states may issue recommendations that entities found to be in violation of UN sanctions be ‘designated’—designated entities typically face restrictions in their commercial dealings with the sanctioning authority. While recommendations for such designations will likely go unheeded by the UN 1718 Committee given Russian and Chinese veto powers, they may feed into the national sanctions regimes of those MSMT member states—including the United States, Japan, and Australia—who have their own, autonomous sanctions regimes against North Korea.
How Will ‘Neutral’ Entities Respond?
There are stakeholders in North Korean sanctions monitoring that operate outside of the East-West dynamic that precipitated the MSMT. These include politically neutral foreign government and industry bodies that respond to requests for information (RFIs) from sanctions monitors, provide intelligence to sanctions monitors, and implement the recommendations of sanctions monitors to improve their own compliance.
There is an open question as to how these entities will engage with the MSMT. At one extreme, foreign government and industry bodies may ignore RFIs and recommendations from the MSMT, viewing them as non-binding and ‘illegitimate’ given that the MSMT operates outside of the UN framework. Alternatively, they may view engagement with the MSMT as an effective, and perhaps even superior means of reducing exposure to potentially costly UN sanctions violations given that the MSMT operates outside of the political constraints of the UN system.
It is likely that neutral foreign government entities will tend toward the former. Neutral governments are likely to view additional sanctions enforcement measures (i.e. those recommended by the MSMT) as a financial and administrative burden, are unlikely to have strong interests in the North Korean nuclear issue and will be disinclined to brave the political hazards of being seen to ‘side with the West’ against Russian andChinese interests.
Instead, the most receptive audience for MSMT reporting is likely to be multinational corporations (MNCs). MNCs have a financial interest in minimising exposure to sanctions violations, specifically to minimise the reputational risks of alleged collusion with North Korea and to avoid being cut-off from Western financial systems through the autonomous sanctions programs of the United States, Japan, and others.
Will the MSMT Enjoy US Political Support?
While the logic of sanctioning North Korea appears uncontroversial in the capitals of MSMT member states, the political commitment of the United States to the MSMT mission may be derailed by President Trump’s North Korea policy.
During his first term, Trump blocked the imposition of autonomous sanctions against North Korea. And despite going hammer and tongs after the Iranian nuclear program since returning to office, he’s been shtum on non-proliferation in North Korea, instead playing down the North Korean threat and boasting of his ‘great relationship’ with Kim Jong Un. A lack of top-level political support may marginalise the MSMT in the US policy debate and hinder the US delegation from providing the strong leadership that the MSMT will need to succeed.
That being said, the degradation of the MSMT under Trump is not a foregone conclusion. Trump proved a shrewd negotiator with the North Koreans in his first term, electing to maintain US sanctions despite concessions offered by Pyongyang. Trump’s personal proclivity for ‘making a deal’ may also drive him to pursue maximum leverage over North Korea by doubling down on sanctions, which would elevate the MSMT to a core instrument of his foreign policy agenda.
Whether Trump will neglect or double down on sanctions against North Korea is difficult to predict, as is most of Trump’s foreign and domestic policy. At a minimum, we can say that Trump will face strong strategic incentives to bolster sanctions, specifically to slow North Korea’s development of its theatre and intercontinental strike capabilities which are now proceeding at breakneck speed.
Conclusion
The MSMT is a rational response to the collapse of the UN Panel of Experts on North Korea, bringing together a coalition of capable, like-minded states to monitor sanctions free from Russian and Chinese interference. However, its success is far from guaranteed. Whether the MSMT can establish itself as an effective and consequential alternative to the Panel will depend on its ability to maintain impartiality, secure cooperation from a wide range of stakeholders, and translate its findings into meaningful action. Such an outcome is crucial because, with denuclearisation talks moribund and military intervention too costly, effective sanctions are likely the only remaining check on North Korea’s weapons of mass destruction development.