That is a fantastic question. Yes, holes in the sieve is, I think, what I referred to.
There are different gaps in different parts of the world and various levels of severity depending on where we're looking. Broadly, I would say the three largest regions we need to focus on, not only because they are critical pathways for North Korea, but also because of the implementation gaps, are Southeast Asia, the Middle East, and Africa. I realize that covers a large section of the world, but it gives you a sense of the scale of the problem. Issues in those jurisdictions are quite wide ranging.
I'll give you a very small sample. Finance is one of the areas that we need to be able to restrict with regard to North Korea. North Korea has become very good at circulating money offshore. Measures that restrict North Korea's ability to have North Korean bank accounts operate overseas are only going to be partially effective, because they're already putting their money overseas into accounts that don't have a North Korean label on them and circulating it in that way. To be effective in implementing some of the restrictions that acknowledge that limitation at the national level, you need to have regular communication with banks. You need to make sure that banks know that they can and can't do certain things related to North Korea. When you travel to parts of Southeast Asia and have conversations with monetary authorities and financial regulators and indeed with the banks in those jurisdictions, it's quite clear that those conversations are just not happening. In some places you still even have North Korean companies creating joint venture banks with other foreign companies, so we have some work to do.
In some places gaps in legislation mean that when a country does want to take enforcement action, it doesn't have the legal ability to. Scrutinizing the movement of North Korean diplomats or cash couriers is one example of how legislation and gaps therein frequently create obstacles rather than facilitate action. Model legislation, outreach on export controls, outreach on countering financial crime, and specifically counter-proliferation finance if we're talking about the most important part of the threat picture in the financial space, are all extremely important initiatives that we need to advance. You can pretty much choose your place in Africa, Southeast Asia, or the Middle East where you want to do that outreach.