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The Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) has formally issued the <a href="https://home.treasury.gov/system/files/126/fr86_29197.pdf" target="_blank" rel="noopener">Burma Sanctions Regulations</a> to implement Executive Order 14014 of February 10, 2021, &ldquo;Blocking Property With Respect to the Situation in Burma.&rdquo; See SmarTrade Update of <a href="https://www.thompsonhinesmartrade.com/2021/02/president-biden-issues-executive-order-regarding-military-coup-in-burma-and-sanctioning-military-leaders/">February 11, 2021</a>. These regulations took effect on June 1, 2021, and are now codified in the Code of Federal Regulations at 31 C.F.R. Part 525. The Burma Sanctions Regulations set forth formal definitions; provide the scope of prohibited transactions; detail the general and specific license procedures; and provide limited details on available interpretations. OFAC states that these regulations are being published &ldquo;in abbreviated form at this time for the purpose of providing immediate guidance to the public,&rdquo; but that the agency intends to supplement Part 525 &ldquo;with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licenses, and other regulatory provisions.&rdquo;
Currently, OFAC has issued four general licenses in order to authorize activities that would otherwise be prohibited with regard to the Burma Sanctions Regulations. General licenses allow U.S. persons to engage in the activity described in the general license without needing to apply for a specific license.
<ul>
<li><a href="https://home.treasury.gov/system/files/126/burma_gl_1.pdf" target="_blank" rel="noopener">Burma General License Number&nbsp;1</a>&nbsp;&ndash; &nbsp;Official Business of the United States&nbsp;Government&nbsp;(March 25, 2021)</li>
<li><a href="https://home.treasury.gov/system/files/126/burma_gl2.pdf" target="_blank" rel="noopener">Burma General License Number 2</a>&nbsp;&ndash;&nbsp;Official Activities of Certain International Organizations and Other International Entities&nbsp;(March 25, 2021)</li>
<li><a href="https://home.treasury.gov/system/files/126/burma_gl_3.pdf" target="_blank" rel="noopener">Burma General License Number 3</a>&nbsp;&ndash;&nbsp;Certain Transactions in Support of Nongovernmental Organizations&rsquo; Activities&nbsp;(March 25, 2021)</li>
<li><a href="https://home.treasury.gov/system/files/126/burma_gl_4.pdf" target="_blank" rel="noopener">Burma General License Number 4&nbsp;</a>&ndash; Authorizing the Wind Down of Transactions Involving Myanmar Economic Corporation Limited and Myanmar Economic Holdings Public Company Limited (March 25, 2021)</li>
</ul>
OFAC has also issued limited <a href="https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/1536" target="_blank" rel="noopener">FAQs</a> on the Burma sanctions.
As a reminder, BIS previously announced actions to limit exports and reexports of sensitive goods to Burma&rsquo;s military and security services and suspended certain license exceptions for the country in the wake of the Burmese military&rsquo;s February 1 coup to overthrow the civilian government of Burma. However, actual regulations had not been formalized. BIS&rsquo;s policy remains a &ldquo;presumption of denial&rdquo; for any licenses for export and reexport to select Burmese government departments and agencies. See SmarTrade Update of <a href="https://www.thompsonhinesmartrade.com/2021/02/bis-restricts-exports-of-sensitive-items-to-burmas-military-and-security-services/">February 12, 2021</a>.
NOTE: While the U.S. government and its regulations still reference &ldquo;Burma,&rdquo; the country since 1989 has been known as Myanmar.

OFAC Publishes Formal Burma Sanctions Regulations

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