The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published on 11 July 2012 long-awaited General Licenses
to lift certain Burma sanctions. Specifically, OFAC implemented the easing of certain sanctions with respect to financial services and new investments that were initially announced in May 2012 by President Obama and Secretary of State Clinton in response to political reforms by Burma’s government. Unlike the parallel EU measures, these new U.S. authorizations are not limited to a 12-month period.
OFAC also added two new entries to the list of Specially Designated Nationals (SDNs), prohibiting U.S. persons from engaging in transactions with those entities. Moreover, the President issued a new Executive Order on the same day, providing additional legal basis for imposing sanctions against persons and entities that threaten the peace, security, or stability of Burma, including those responsible for human rights abuses in Burma and those who conduct arms trade with North Korea.
For more information on the scope of authorized activities under these new General Licenses, including the reporting requirements that apply to certain new investments in Burma, please see Hogan Lovells Economic Sanctions Alert.