US Government Adds 4 Burma Army Related Entities To Its Entity List And Sanctions 22 Burmese People | Husch Blackwell LLP


Effective July 2, 2021, as part of the US government’s continued response to the military coup in Burma (Myanmar), the Commerce Department’s Office of Industry and Security (“BIS”) added four entities to the list of entities and to the Office of Foreign Assets Control (“OFAC”) of the Department of the Treasury added twenty-two people to the list of specially designated nationals and blocked persons (“SDN list”).

Commerce Secretary Gina M. Raimondo noted that the four entities include a provider of satellite communications services to the Burmese military and three entities that have revenue sharing agreements with Myanmar Economic Holdings Limited (“MEHL” ), an entity that generates income for the Burmese military. and who was previously added to the list of entities. As a result of these additions, licenses are required for exports, re-exports, and in-country transfers of all “AEOI” items to the four entities and the BIS will use a deemed-refusal review policy. licenses. The entities are:

  • King Royal Technologies Co., Ltd .;
  • Myanmar Wanbao Mining Copper, Ltd .;
  • Myanmar Yang Tse Copper, Ltd .; and
  • Wanbao Mining, Ltd.

The twenty-two people added to the SDN list under Executive Decree 14014 include two members of the State Administrative Council currently involved in the governance of Burma and the Ministers of Information; Investment and foreign economic relations; Labor, immigration and population; and social protection, relief and resettlement. Fifteen of the twenty-two added to the SDN list were added because they were either spouses or adult children of people on the SDN list.

Due to SDN designations, all property and interest in the property of such persons in the United States or controlled by American persons must be blocked and reported to OFAC. Persons in the United States are prohibited from sending or receiving any funds, goods, or services to / from these newly designated SDNs. According to OFAC’s “50% ownership rule”, these sanctions also extend to all subsidiaries in which these SDNs hold directly or indirectly, individually or collectively with other SDNs, a stake of 50% or more. .

For other recent developments related to US actions regarding international trade implications arising from the situation in Burma, see here, here, and here.

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