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Financial Services Law Insights and Observations

OFAC sanctions officials and entities connected to Burmese military

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

Financial Crimes

On January 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14014 against seven individuals and two entities connected to Burma’s military regime. The sanctions coincide with the one-year anniversary of the military coup d’etat of Burma’s democratically elected government, and are part of a joint action taken with the UK and Canada. Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson stated that the U.S. “will continue to target those responsible for the coup and ongoing violence, enablers of the regime’s brutal repression, and their financial supporters.” As a result of the sanctions, all property and interests in property belonging to the identified persons subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated individuals, unless exempt or authorized by a general or specific license. Prohibitions “include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person or the receipt of any contribution or provision of funds, goods, or services from any such person.”