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Financial Services Law Insights and Observations

OFAC sanctions additional individuals and entities connected to Burmese military coup

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

Financial Crimes

On March 22, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14014 against two individuals and two entities connected to the Burmese military’s “repression of pro-democracy protests.” The sanctions follow previous actions taken by OFAC earlier this year against several individuals and entities (covered by InfoBytes here and here). As a result of the sanctions, all property and interests in property belonging to the sanctioned persons and “any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons,” 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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