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Sanctions Targeting Myanmar

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On February 10, 2021, President Biden issued Executive Order 14014 “Blocking Property with Respect to the Situation in Burma” (“EO 14014”), which provides for the imposition of sanctions on certain Burmese parties in response to the Burmese military’s coup against the democratically elected civilian government in Burma. In parallel with the issuance of EO 14014, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated thirteen parties on February 10, 2021 and two parties…

On 7 October 2016, following his prior announcement (see prior blog post here) of the intention to terminate US sanctions targeting Myanmar (also known as Burma), President Obama issued an Executive Order (“the 7 October Executive Order”) terminating US sanctions targeting Myanmar. As a result of this action, the sanctions that previously restricted US Persons (i.e., US citizens or permanent residents, wherever located or employed; entities organized under US law (and their non-US branches); and persons located in the United States) from engaging in certain activities involving Myanmar or specific entities associated with Myanmar are no longer in effect. The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) simultaneously published a Fact Sheet explaining these changes and updated its list of Frequently Asked Questions regarding Myanmar.

On September 14, 2016, President Obama announced his intention to terminate US sanctions targeting Myanmar, also known as Burma (“Myanmar”), completing the process of relaxing US sanctions against Myanmar that began in July 2012.  In a joint statement issued by the United States and Myanmar, President Barack Obama and State Chancellor Daw Aung Sun Suu Kyi announced the US-Myanmar Partnership, which will ultimately allow for deepened economic ties across a range of sectors between the countries.  As an initial step for implementing the partnership, the President announced that the United States will terminate US sanctions and will revoke the Executive Order-based framework of the Myanmar sanctions program.

On 17 May 2016, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced amendments to the Burmese Sanctions Regulations (“BSR”), 31 C.F.R. Part 537, by issuing new and amending existing general licenses intended to, support trade with Burma, facilitate the movement of goods within Burma, allow most transactions involving designated Burmese financial institutions, and allow certain transactions related to “U.S. Persons” (defined below) residing in Burma. These BSR amendments take effect today (18 May 2016) and are summarized in more detail by OFAC here.