Yesterday, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) further escalated sanctions on Burma by adding two large Burmese military holding companies to its List of Specially Designated Nationals (“SDNs”).  Myanmar Economic Holdings Public Company Limited (“MEHL”) and Myanmar Economic Corporation Limited (“MEC”) both dominate large sectors of the Burmese economy, with vast business interests.  MEHL operates in the banking, trade, logistics, construction, mining, tourism, agriculture, tobacco, food, and beverage sectors, while MEC has interests in mining, manufacturing, and telecommunications.

Until June 22, 2021, companies are permitted to wind-down any transactions with MEHL or MEC or any entities owned 50 percent or more by the two companies. After that date, U.S. persons are broadly prohibited from doing business with either entity or with any company owned 50 percent or more by the sanctioned holding companies.  Any of the sanctioned companies’ property or interests in property in the United States or within the possession or control of U.S. persons must be formally blocked and reported to OFAC.

OFAC also issued several general licenses authorizing activities related to the official business of the United States government, activities of international organizations and entities, and transactions in support of non-governmental organizations.

Companies doing business in Burma should carefully review their business relationships for the involvement of sanctioned parties.

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