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Financial Services Law Insights and Observations

OFAC sanctions persons connected to Burma’s military regime

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 six individuals and three entities connected to Burma’s military regime. The sanctions, taken in coordination with the United Kingdom and Canada, come on the eve of the two-year anniversary of the military coup d’état that deposed Burma’s democratically elected government. Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson stressed that the “United States will continue to promote accountability for those who provide financial and material support to, and directly enable, the violent suppression of democracy in Burma.” As a result of the sanctions, all property and interests in property belonging to the sanctioned persons that are in the U.S. or in the possession or control of U.S. persons 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 persons, unless authorized by a general or specific OFAC license, or if otherwise exempt.