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Financial Services Law Insights and Observations

OFAC sanctions individuals and entities connected to Burmese military coup under new executive order

Financial Crimes OFAC Designations Department of Treasury Enforcement Sanctions Of Interest to Non-US Persons Burma OFAC

Financial Crimes

On February 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against 10 current and former military officials and three entities connected to a Burmese military coup. The sanctions—which “specifically target those who played a leading role in the overthrow of Burma’s democratically elected government”—were announced in coordination with President Biden’s issuance of a new Executive Order (E.O.), “Blocking Property With Respect To The Situation In Burma.” As a result of the sanctions all property and interests in property belonging to the sanctioned individuals and entities, and “any entities that are owned, directly or indirectly, 50 percent or more by them,” subject to U.S. jurisdiction are blocked and must be reported to OFAC. U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons, unless exempt or authorized by a general or specific license.

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