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Daniel Andreeff

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On June 1, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published the Burma Sanctions Regulations at 31 C.F.R. Part 525 (the “BSR”) to implement Executive Order 14014, “Blocking Property With Respect to the Situation in Burma” (“EO 14014”). EO 14014 imposed sanctions on certain Burmese parties in response to the Burmese military’s coup against the democratically elected civilian government. The BSR do not expand upon the sanctions previously imposed under EO…

On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (“SDNs”), and entities in which they own a 50 percent or greater interest. The revocation of GL 2G effectively strengthens US sanctions against Belarus, and may make it more difficult for US Persons to conduct…

On April 1, 2021, President Biden revoked Executive Order 13928 “Blocking Property of Certain Persons Associated with the International Criminal Court” (the “ICC EO”), which authorized the imposition of sanctions and visa restrictions on non-US ICC officials. The US Treasury Department’s Office of Foreign Assets Control concurrently removed two senior ICC officials from the Specially Designated Nationals and Blocked Persons List (“SDN List”), including Fatou Bensouda, the ICC’s chief prosecutor. The ICC EO was signed…

The US Government has imposed a series of sanctions against Myanmar Economic Corporation Limited (“MEC”) and Myanma Economic Holdings Public Company Limited (a.k.a. Myanmar Economic Holding Limited) (“MEHL”), two military-affiliated conglomerates, in response to the February military coup in Burma (Myanmar). The combined restrictions are likely to have a significant impact on business activities in Burma as these conglomerates have substantial interests and joint ventures in several sectors of the Burmese economy, including trading, natural…