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Financial Services Law Insights and Observations

OFAC sanctions additional individuals and entities connected to designated Burmese military coup leader

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

Financial Crimes

On March 10, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order (E.O.) 14014 against two individuals along with six of their companies. The individuals are the adult children of a previously designated Commander-in-Chief of the Burmese military forces (covered by InfoBytes here)—an individual OFAC claims is “the leading actor in the overthrow of Burma’s democratically elected government.” Under E.O. 14014, foreign persons may be sanctioned who are the spouses or adult children of a person whose property and interests in property are blocked. 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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