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Financial Services Law Insights and Observations

OFAC Issues General License Authorizing Certain Exports to or from Burma

OFAC

Federal Issues

On December 7, OFAC issued a six-month general license authorizing trade transactions involving Specially Designated Nationals and SDN-owned entities that would otherwise be prohibited by the Burmese Sanctions Regulations. The general license authorizes certain transactions that are “ordinarily incident to an exportation to or from Burma of goods, technology, or non-financial services” and also permits U.S. financial institutions to “unblock and return transactions blocked on or after April 1, 2015 that would have qualified as authorized had they been engaged in pursuant to the authorization in the general license.” U.S. financial institutions that unblock transactions blocked on or after April 1, 2015 must submit to the Department of the Treasury a report to include the following: (i) a copy of the original blocking report filed with OFAC; (ii) the date the transaction was unblocked; (iii) the amount unblocked, if applicable; (iv) the name of the party to whom the blocked property was returned; and (v) a reference to the general license as the legal authority under which the transaction was unblocked and the blocked property was returned. The general license is effective through June 7, 2016.