On March 24, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated and sanctioned six entities and two individuals connected to Burma’s military “that have enabled the military regime’s continuing atrocities.” The entities have been designated for operating in the defense sector of the Burmese economy, “specifically based on their involvement in the importation, storage, and distribution of jet fuel to Burma’s military.” The sanctioned individuals are associated with or have provided equipment to Burma’s military. Additional identifying information on these entities and individuals is available here.
As a result of this action, all property and interests in property of these entities and individuals placed on OFAC’s SDN List that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50% or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt. These prohibitions include the making of any contribution or provision of funds, goods or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods or services from any such person.
OFAC has also published a Burma Jet Fuel Sanctions Alert to inform individuals, businesses and other persons of the sanctions risks associated with providing jet fuel to Burma’s military regime. The alert notes that providing jet fuel to Burma’s military regime could be sanctionable under various executive orders and sanctions regulations as it could be viewed as materially assisting sanctioned entities.
For additional background on the risks of doing business in Burma, see Update of February 14, 2022.