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Financial Services Law Insights and Observations

OFAC sanctions additional persons connected to Burma’s military regime

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

Financial Crimes

On March 24, pursuant to Executive Order 14014, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against two individuals and six entities connected to Burma’s military regime. In announcing the sanctions, OFAC explained that the Burmese military, which overthrew the country’s democratic government in February 2021, has increased its reliance on air strikes in civilian populated areas and that the designated persons have provided assistance to military efforts through the importation, storage, and distribution of jet fuel. “Burma’s military regime continues to inflict pain and suffering on its own people,” Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson said in the announcement. “The United States remains steadfast in its commitment to the people of Burma, and will continue to deny the military the materiel it uses to commit these atrocities.”

In conjunction with the sanctions, OFAC published an alert warning of the sanctions risks associated with providing jet fuel to the Burmese military. 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.