From Cairo to Pyongyang via Jersey: A Case Study on Sanctions Compliance and Risk

Note: All information in this report is derived from publicly available sources through open-source intelligence (OSINT) research and credible news reporting. While this report highlights potential concerns regarding sanctions compliance involving entities in Jersey, Luxembourg, and the Cayman Islands, as well as links to U.S. defence contractors, it does not accuse any party of wrongdoing. There is no evidence of legal or regulatory actions being taken or reported against the individuals or entities involved.

Introduction

The Marchmont Trust, a family trust established in Jersey (a UK Crown Dependency), is the ultimate owner of Orascom Telecom Media and Technology Holding (OTMT). OTMT effectively lost control of Koryolink in North Korea in late 2015, though it did not formally divest or exit the venture.

Koryolink, North Korea's first wireless telecommunications provider, was launched in 2008 as a joint venture between:

• Orascom Investment Holding (75% ownership)
• Korea Post and Telecommunications Corporation (KPTC) (25% ownership)

The Jersey connection centres around Naguib Sawiris, a telecom magnate with Egyptian roots and a U.S. passport. He founded Orascom Telecom Holdings in the 1990s, which expanded into high-risk markets, including North Korea.

After selling most of Orascom to VimpelCom (now VEON) in 2011, Sawiris retained the North Korean assets (e.g., Koryolink) under OTMT, ultimately controlled by the Marchmont Trust in Jersey.

Marchmont Trust (Jersey)

The ultimate owner of OTMT is the Marchmont Trust, a family trust established in Jersey.

• https://opencorporates.com/companies/je/EXTUID_123549

This trust is part of a multi-jurisdictional corporate chain:

• Marchmont Trust (Jersey) owns entities in the Cayman Islands,
• Which owns OTMTI (Luxembourg),
• Which controls OTMT (Egypt),
• Which operated Orabank in North Korea.

February Private Trust Company (Jersey)

The trustee of the Marchmont Trust is the February Private Trust Company, based in Jersey. This company manages the trust’s assets and has directors with links to other Sawiris family businesses, including Contrack Watts, a U.S. defence contractor.

OTMT, through the Jersey-rooted structure, was connected to North Korea through the following ownership structures:

• Koryolink: A 75% stake in North Korea’s first mobile network.
• Orabank: A joint venture with the Foreign Trade Bank (FTB), a sanctioned North Korean entity.

These ventures were ultimately funded and controlled via the Jersey-based trust, raising concerns about sanctions compliance and financial transparency.

The Foreign Trade Bank (FTB) of North Korea

Up to 2016, there was a Jersey connection to the Foreign Trade Bank (FTB) of North Korea. The FTB was identified as contributing to North Korea’s nuclear-related, ballistic missile-related, and weapons of mass destruction (WMD) programs.

The FTB was designated (sanctioned) by:

• The United Nations (UN) in 2013 (UN Security Council Resolution 2094),
• The U.S. Treasury in 2013,
• The European Union (EU) on August 5, 2017.

Orabank and FTB

Orabank, established in 2009, was a joint venture between Orascom Telecom and North Korea’s FTB. The FTB was sanctioned by the U.S. Treasury in 2013 for its role in financing North Korea’s weapons programs. The Jersey-based trust structure indirectly owned and funded a venture with a sanctioned entity, raising concerns about sanctions compliance and financial opacity.

Orabank Closure Timeline

Orabank, the banking joint venture between Orascom Telecom and North Korea’s FTB, was officially shut down on December 4, 2016.

• Announcement Date: December 4, 2016
• Reason: Declared as an "Event of Force Majeure" due to escalating U.S. sanctions enforced by the Office of Foreign Assets Control (OFAC).
• Immediate Actions: Orascom announced it would transfer all cash and liquid assets from Orabank. The telecom subsidiary Koryolink was to continue operations despite the banking closure.
• Aftermath: Naguib Sawiris resigned as CEO of OTMT shortly after the closure announcement.

Pre-2016 Sanctions Framework in Jersey

Jersey had sanctions laws related to North Korea before 2016, primarily based on the implementation of EU and UN sanctions.

EU Legislation (Sanctions – North Korea) (Jersey) Orders

Jersey implemented Council Regulation (EC) No 329/2007, which imposed restrictive measures against North Korea, including asset freezes and trade bans. These were enforced locally through a series of Jersey Orders, such as:

• EU Legislation (Sanctions – North Korea) (Jersey) Order 2015,
• Amendment Orders in 2016, which updated the sanctions in line with evolving EU regulations.

Jersey Sanctions

Jersey used the European Communities Legislation (Implementation) (Jersey) Law 1996 to give effect to EU sanctions based on UN resolutions. Specifically:

• Jersey issued the Community Provisions (Restrictive Measures – North Korea) (Jersey) Order 2013 on April 12, 2013.
• Further Orders were made under the European Union Legislation (Implementation) (Jersey) Law 2014, which allowed Jersey to mirror EU sanctions.
• Jersey also followed UN Security Council Resolutions, particularly Resolution 1718 (2006), which formed the foundation for many international sanctions against North Korea.

References:

• EU Legislation (Sanctions - North Korea) (Amendment No. 4) (Jersey): https://www.gov.je/md/ministerialdecisions/external%20relations%20%28inc.%20financial%20services%20%28from%2027%20february%202024%29/decisions%20in%202017/mder20170007.doc
• EU Legislation (Sanctions – North Korea) (Jersey) Order 2017: https://www.jerseylaw.je/laws/current/PDFs/RO_97_2017.pdf

The EU sanctioned the FTB in August 2017, despite the UN having designated it in 2013. This delay stems from the EU’s process of transposing UN sanctions and its autonomous decision-making for additional listings.

Key Takeaways from the Case

This case:

• Illustrates the extreme political and financial risks of doing business in North Korea, even for well-connected, experienced investors like billionaire Naguib Sawiris, and jurisdictions such as Jersey.
• Underscores how sanctions, currency controls, and state interference can render even profitable ventures unviable.
• Highlights a standard family wealth vehicle at the centre of debates on corporate ethics, sanctions, and jurisdictional accountability.

Note: There is no record of legal actions against key actors, such as the trustees of the Jersey trust, Naguib Sawiris, or any other associated persons.

Background: Key Players

Naguib Sawiris, a telecom magnate with Egyptian roots and a U.S. passport, founded Orascom Telecom Holdings in the 1990s, which expanded into high-risk markets, including North Korea. After selling most of Orascom to VimpelCom (now VEON) in 2011, Sawiris retained the North Korean assets under OTMT, ultimately controlled by the Marchmont Trust in Jersey.

The following entities are part of or connected to the Sawiris family business empire, which has evolved over decades through mergers, demergers, and strategic restructuring:

• Orascom Telecom Holdings,
• Orascom Telecom Media and Technology Holding (OTMT),
• Orascom Investment Holding (OIH),
• OTMT Acquisition Sàrl,
• Orascom Construction.

1. Orascom Telecom Holdings (OTH). Founded in 1997 by Naguib Sawiris, it became one of the largest telecom operators in the Middle East and Africa. In 2011, OTH merged with VimpelCom (now VEON). As part of the merger, certain assets were excluded and spun off into OTMT.
2. Orascom Telecom Media and Technology Holding (OTMT) Created to hold excluded assets from the VimpelCom merger, including high-risk ventures like Koryolink in North Korea. OTMT was involved in telecom, internet, and cable investments across Egypt, Lebanon, and the North African region. It also owned Orabank, a joint venture with North Korea’s FTB.
3. Orascom Investment Holding (OIH) In 2018, OTMT changed its name to OIH to reflect a broader investment strategy beyond telecom. OIH now operates as a diversified investment holding company across various sectors, including financial services, real estate, logistics, and cultural development.
4. OTMT Acquisition Sàrl (OTMTAS) A Luxembourg-based subsidiary that owns a majority stake in OIH. It is part of a complex ownership structure involving entities in the Cayman Islands and ultimately controlled by the Marchmont Trust, a Jersey-based family trust established by the Sawiris family.
5. Orascom Construction: A separate branch of the Sawiris family empire, led by Nassef Sawiris (Naguib’s brother). It focuses on engineering, construction, and infrastructure projects globally. Though distinct from the telecom entities, it shares historical roots and family ownership, forming part of what some describe as an “Egyptian chaebol”—a diversified, family-controlled conglomerate (used metaphorically, as the term originates from South Korea).

Key Takeaways: The Sawiris family split their business empire into different sectors: telecom (Naguib), construction (Nassef), and hospitality (Samih). Orascom Telecom Holdings was the original telecom arm, which evolved into OTMT and later OIH. OTMT Acquisition Sàrl and the Marchmont Trust (Jersey) are part of the financial and ownership structure behind these entities. Orascom Construction is not directly linked to the telecom entities, but it shares a family origin.

British Financial Journalist George Turner

British financial journalist George Turner issued a report on Orascom Telecom, its owner Naguib Sawiris, and possible violations of U.S. and UN sanctions, based on official filings and UK court proceedings.

• https://www.financeuncovered.org/stories/the-north-korean-connection

Key Details from George Turner's Report

Naguib Sawiris is a prominent Egyptian billionaire, telecom magnate, and U.S. citizen, as well as a global investor, known for his ventures in high-risk markets, including North Korea, where his company, Orascom Telecom, played a pivotal role in establishing the country’s first mobile network.

Sawiris was introduced to North Korea through Ri Chol, a senior diplomat from the Democratic People's Republic of Korea (DPRK) and an alleged financial handler for Kim Jong Il. He founded CHEO Technology, a joint venture with North Korea’s KPTC, to launch Koryolink, the country’s first mobile network.

Despite initial success, Orascom faced major issues:

• $420 million in trapped profits due to repatriation restrictions.
• Emergence of a state-run competitor undermining Koryolink.
• Loss of operational control despite holding a 75% stake.

Timeline and Connection to North Korea

2008

Koryolink was launched in 2008 as a joint venture between Orascom Investment Holding (with a 75% ownership stake) and KPTC (with a 25% ownership stake). It operated under CHEO Technology and was the first 3G mobile operator in North Korea.

Naguib Sawiris, as chief executive of Orascom Investment Holding, announced in September 2008 that his company had begun operations in North Korea. (Note: No UN exemption was required at launch, as significant sanctions intensified later.)

2011

In a 2011 merger between Orascom and Russian telecom group VimpelCom, certain Orascom assets, including Koryolink, were excluded and spun off into OTMT.

OTMT is a holding company with investments in telecom, internet, and cable sectors in Egypt, Lebanon, and other North African and Middle Eastern countries, as well as the Koryolink investment in North Korea.

Naguib Sawiris indirectly owns 37% of OIH (which emerged from the VimpelCom merger and OTMT name change) through OTMT Acquisition Sàrl. He also serves as the Executive Chairman of OTMT and Chairman of OTMT Investments, which holds interests in ICT, finance, and infrastructure.

2009–2016: Orabank and Sanction Risks

As part of the Orascom Telecom deal with the North Korean government to establish the Koryolink subsidiary, Orabank was set up in 2009 as a joint venture between OTMT and North Korea’s FTB.

• Establishment and Structure: Established to support financial operations for Koryolink.
• Financial Commitment: OTMT committed $127 million to Orabank, though $48 million was later written off due to operational and repatriation challenges.
• Closure: Officially closed on December 4, 2016, due to sanctions pressures from OFAC and the UN Security Council. The closure was described as an “Event of Force Majeure,” and OTMT announced it would transfer all liquid assets while continuing telecom operations via Koryolink.
• Sawiris’s Resignation: Naguib Sawiris resigned as CEO of OTMT shortly after, nominating Tamer El Mahdy as his successor. He reportedly described his North Korean investments as a “curse,” citing difficulties in repatriating profits and navigating sanctions.

The Orascom case illustrates several key sanctions and compliance risks:

• Sanctioned Entity Involvement: The FTB was sanctioned by the U.S. in 2013. Any financial dealings with it by U.S. persons (Sawiris holds a U.S. passport) could potentially violate OFAC regulations. Even if the joint venture predated the sanctions, continued operations post-designation posed legal and reputational risks.
• Jurisdictional Exposure: The involvement of entities in Jersey, Luxembourg, and the Cayman Islands, and links to U.S. defence contractors, raised concerns about sanctions evasion and ethical governance. However, no legal action has been reported.

Cayman and Jersey Links

• Cayman: According to a Federal Communications Commission application submitted by another Sawiris company, Accelero Capital Investment Holdings, OTMTI is owned by companies based in the Cayman Islands.
• Jersey: The Marchmont Trust, based in Jersey, ultimately owns Orascom Telecom. The trustee administering the trust’s assets, the February Trust Company, is also headquartered in Jersey. Among its five directors is American Kevin Struve, who is also a director of Contrack Watts (a principal U.S. defence contractor and another Sawiris family-owned business). Orascom Construction is owned by Naguib Sawiris’ brother, Nassef Sawiris. (The Sawiris empire has been described metaphorically as an “Egyptian chaebol,” highlighting its scale, family control, and diversified global operations.)

In a 2013 AP story, Struve is identified as Orascom Construction’s strategic planning director. Contrack Watts (later Contrack International) was sued for fraud in connection with USAID-financed construction contracts in Egypt.

Marchmont Trust Overview

The Marchmont Trust is a family trust established in Jersey and serves as the ultimate owner of a complex international corporate chain linked to Naguib Sawiris's business interests. Established as part of the Sawiris family's wealth management structure, the trust has drawn scrutiny for its indirect ties to investments in North Korea, particularly in telecommunications and banking sectors, amid concerns over sanctions evasion and financial opacity.

Ownership and Structure

• Trustee: Administered by the February Private Trust Company Limited, headquartered in Jersey. This entity manages the trust's assets and has five directors, including Kevin Struve, who has roles in other Sawiris-linked businesses. Struve's involvement has raised questions about potential conflicts, given his directorship at Contrack Watts, a U.S. defence contractor that works on projects for the U.S. military.
• Corporate Chain: The trust owns intermediary entities, including companies in the Cayman Islands, which hold the majority stake in OTMTI (Luxembourg). OTMTI controls the majority of OTMT (Egypt). This layered structure is typical of high-net-worth family trusts but has been criticised for enabling opacity in cross-border dealings.

Concerns and Flags for Opaque Financial Dealings

Journalists and watchdogs have flagged the structure for potential use in evading scrutiny over North Korea ties, especially given international sanctions against the regime for its nuclear and missile programs:

• Sanctions Risks: The FTB was designated by the U.S. Treasury in 2013 as a key facilitator of North Korea's WMD programs. As a U.S. citizen, Sawiris is subject to U.S. sanctions that prohibit dealings with such entities, raising questions about whether OTMT's Orabank involvement violated these rules (although no violations were confirmed, and the JV predated or ended after the sanctions). OTMT's financial statements included disclaimers about challenges in fund transfers due to escalating UN and U.S. sanctions.
• U.S. Defence Links: The overlap via Kevin Struve between the trust's trustee and Contrack Watts has sparked concerns about indirect ties between North Korean revenue and U.S. military projects.
• Broader Implications: Reports suggest the structures could have helped North Korea generate foreign currency amid isolation. No legal actions against the trust or Sawiris related to these issues have been publicly documented.

Recent Updates (as of August 29, 2025)

Since the closure of Orabank in 2016 and loss of control over Koryolink in 2015, developments include:

• 2018 UN Exemption: Orascom received a UN exemption under Resolution 2375 (2017) to continue limited operations and attempt profit repatriation.
• 2022 Loan from Subsidiary: Orascom Investment Holding (OIH) received a loan worth approximately $80 million from its North Korean subsidiary, CHEO Technology (behind Koryolink). This may represent a partial workaround for repatriating trapped funds, given the limited banking channels available due to sanctions.
• Ongoing Repatriation Issues: As of recent financial disclosures (e.g., OIH's reports up to 2024), the group remains unable to repatriate cash from North Korea due to sanctions entirely.
• 2025 Meeting with Kim Jong Un: In February 2025, Naguib Sawiris met North Korean leader Kim Jong Un in a "historic" encounter. Sawiris discussed the economy as the true power of nations but provided no specific details on business outcomes, such as progress on Koryolink or fund repatriation. The meeting highlights the continued interest in North Korea, despite the risks.

Sources

• https://www.financeuncovered.org/stories/the-north-korean-connection
• https://en.wikipedia.org/wiki/Naguib_Sawiris
• https://opencorporates.com/companies/je/EXTUID_123549
• https://www.yahoo.com/news/apnewsbreak-iowa-unaware-companys-fraud-181954581.html
• https://en.amwalalghad.com/egypts-sawiris-to-keep-investing-in-north-korea-after-un-exemption/
• https://www.slideshare.net/slideshow/orascom-telecom-release/9877826
• https://www.marketscreener.com/quote/stock/ORASCOM-INVESTMENT-HOLDIN-11798426/news/Orascom-Telcom-Media-and-Tech-Hold-SAE-OTMT-changes-its-name-to-OIH-26947012/
• https://www.orascomih.com/
• http://www.otmtinvestments.com/OrascomInvestment.html
• https://www.nkeconwatch.com/category/organizaitons/orascom-telecom-holding/ora-bank/
• https://www.forbes.com/sites/mfonobongnsehe/2016/12/05/egyptian-billionaire-naguib-sawiris-steps-down-as-ceo-of-orascom/
• https://www.jerseylaw.je/laws/current/PDFs/RO_97_2017.pdf

OTHER SOURCES

• UN in 2013 (UN Security Council Resolution 2094), U.S. Treasury in 2013  (https://home.treasury.gov/news/press-releases/sm0165)

JERSEY NORTH KOREA SANCTIONS –

• EU Legislation (Sanctions - North Korea) (Amendment No. 4) (Jersey ... UN in 2013 (UN Security Council Resolution 2094) U.S. Treasury in 2013  (https://home.treasury.gov/news/press-releases/sm0165) 
• EU Legislation (Sanctions - North Korea) (Amendment No. 4) (Jersey ...https://www.gov.je/md/ministerialdecisions/external relations %28inc.
• Financial services %28from 27 February 2024%29/decisions in 2017/mder20170007.doc- EU Legislation (Sanctions – North Korea) (Jersey) Order 2017 https://www.jerseylaw.je/laws/current/PDFs/RO_97_2017.pdf
• Sawiris, chief executive of Orascom Investment Holding, announced in September 2008 that his company had received an exemption from international sanctions prohibiting joint ventures in North Korea. https://en.amwalalghad.com/egypts-sawiris-to-keep-investing-in-north-korea-after-un-exemption/ 
• In a 2011 merger between Orascom and Russian telecoms group Vimpelcom, certain Orascom assets, including Koryolink, were excluded and spun off into a new company,  https://www.piie.com/blogs/north-korea-witness-transformation/orascom-north-korea-dont-leave-me-hanging
• Naguib Sawiris indirectly owns 37% of Orascom Investment Holding (OIH), which emerged from the merger of Vimpelcom and Orascom Telecom Holding. This ownership is held through an entity called OTMT Acquisition Sarl -(OTMTAS) https://www.bloomberg.com/billionaires/profiles/naguib-o-sawiris/
• He also serves as the Executive Chairman of Orascom Telecom Media and Technology Holding (OTMT) and Chairman of OTMT Investments, which holds interests in ICT, finance, and infrastructure. https://www.theafricaceoforum.com/forum-2025/en/portraits/naguib-sawiris-2/
• In a 2013 AP story, Struve is identified as Orascom Construction’s strategic planning director. Contrack Watts, later known as Contrack International, made headlines when it was sued for fraud in connection with USAID-financed construction contracts in Egypt. https://www.yahoo.com/news/apnewsbreak-iowa-unaware-companys-fraud-181954581.html
• The Marchmont Trust Trustee: Administered by the February Private Trust Company Limited, headquartered in Jersey. https://opencorporates.com/companies/je/EXTUID_123549
• British financial journalist George Turner has issued a report. https://www.financeuncovered.org/stories/the-north-korean-connection
• Sawiris, chief executive of Orascom Investment Holding, announced in September 2008 that his company had received an exemption from international sanctions prohibiting joint ventures in North Korea.https://en.amwalalghad.com/egypts-sawiris-to-keep-investing-in-north-korea-after-un-exemption/
• In a 2011 merger between Orascom and Russian telecoms group Vimpelcom, certain Orascom assets, including Koryolink, were excluded and spun off into a new company,  https://www.piie.com/blogs/north-korea-witness-transformation/orascom-north-korea-dont-leave-me-hanging
• Naguib Sawiris indirectly owns 37% of Orascom Investment Holding (OIH), which emerged from the merger of Vimpelcom and Orascom Telecom Holding. This ownership is held through an entity called OTMT Acquisition Sarl -(OTMTAS) https://www.bloomberg.com/billionaires/profiles/naguib-o-sawiris/
• Executive Chairman of Orascom Telecom Media and Technology Holding (OTMT) and Chairman of OTMT Investments, which holds interests in ICT, finance, and infrastructure. https://www.theafricaceoforum.com/forum-2025/en/portraits/naguib-sawiris-2/
• In a 2013 AP story, Watts, later known as Contrack International, made headlines when it was sued for fraud in connection with USAID-financed construction contracts in Egypt. https://www.yahoo.com/news/apnewsbreak-iowa-unaware-companys-fraud-181954581.html
• The Marchmont Trust Trustee: Administered by the February Private Trust Company Limited, headquartered in Jersey. https://opencorporates.com/companies/je/EXTUID_123549