Key Notes:

  • Several federal agencies recently released a business advisory emphasizing the heightened risk of doing business in Burma.
  • Four key areas of risk were identified: (1) state-owned enterprises (SOEs); (2) gems and precious metals; (3) real estate and construction projects; and (4) arms, military equipment, and related activities.
  • U.S. businesses with supply chains tied to the Burmese military regime, other SOEs, or key Burmese sectors should be wary of reputational, financial, and legal risks, including violations of U.S. sanctions.
  • U.S. anti-money-laundering and forced labor laws present other significant legal risks of doing business with or having supply chains connected to the Burmese individuals/entities.

On January 26, several U.S. agencies published a Burma Business Advisory focused on heightened risk associated with doing business in the country. The business advisory follows Executive Order 14014 (February 11, 2021) authorizing blocking sanctions against certain entities and individuals involved in the military coup that took place on February 1, 2021, and OFAC’s subsequent designations of various Burmese entities and individuals in the Specially Designated Nationals and Blocked Persons list.

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