On December 7, 2015, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a six-month general license (“General License 20”) to allow certain transactions otherwise prohibited by the Burmese Sanctions Regulations (“BSR”) that are incidental to permissible exports to or from Burma. OFAC’s statement on the issuance of General License 20, which was issued to support US and Burmese exporters and to facilitate trade with Burma, is available here.

General License 20 authorizes all transactions until June 7, 2016 ordinarily incident to an export to or from Burma of goods, technology, or non-financial services, provided the export is not to, from, or on behalf of a person whose property is blocked. Permitted transactions include trade financing, payment of port fees, and payment of shipping and handling charges. Subject to certain reporting requirements, the general license also authorizes US financial institutions to engage in transactions necessary to unblock and return funds blocked after April 1, 2015 that would have qualified as authorized had they been engaged in under the general license.

According to the State Department, General License 20 is aimed at correcting the unintended burden on Burmese trade caused by sanctions concerns related to one of Rangoon’s most commercially-viable ports, i.e., Asia World Port Terminal (“AWPT”). AWPT is purportedly owned and operated by Asia World Port Management, a subsidiary of the group AsiaWorld Co. Ltd, which is a Specially Designated National (“SDN”) under the BSR. Prior to the general license, exports transiting critical Burmese infrastructure in which an SDN had an interest, such as AWPT, may have been subject to US sanctions and blocking requirements.

GL 20 is not a response to the recent election in Burma and does not signal a change in US sanctions policy toward Burma. US individuals, companies, and financial institutions are still prohibited from trading directly with or on behalf of sanctioned entities, and other prohibitions in the BSR remain in place.


Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.