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Sanctions Targeting Myanmar

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On January 26, 2022, the US Departments of State, Treasury, Commerce, Labor, Homeland Security and the Office of the US Trade Representative (“USTR”) issued a joint advisory (the “Advisory”) cautioning businesses, financial institutions, investors, consultants, research service providers, etc. of the heightened risks associated with doing business in Burma/Myanmar, especially wherever the Myanmar military is involved. This is a continuation of US Government’s actions to address the situation in Myanmar. Please see our blog posts…

On 21 June 2021, the UK and EU both announced further sanctions targeting individuals and entities linked to Myanmar’s military regime. The EU announced that it was imposing sanctions against an additional 8 individuals, 3 economic entities (Myanmar Gems Enterprise; Myanmar Timber Enterprise (“MTE”); and Forest Products Joint Venture Corporation Limited) and the War Veterans Organisation. All designated persons are subject to asset freezes, with individuals subject to travel bans. EU persons are prohibited from…

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 19 April 2021, the EU announced further Myanmar sanctions coming into force immediately, adding 10 further individuals to its sanctions list. These 10 individuals were targeted for the positions they hold as members of the State Administrative Council and, unlike previous rounds of designations, do not appear to be military or police officials. This brings the total number of sanctioned individuals to 35 (see our previous blog post here). The Council has also imposed…