Updates to the U.S. Sanctions Regime in Myanmar

On 17 May 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control amended the “Burmese Sanctions Regulations, 31 C.F.R. part 537” (“BSR”), and updated the Specially Designated Nationals and Blocked Persons (“SDN”) List. While the primary sanctions prohibiting U.S. persons from dealing with “blocked persons”, including persons on the SDN list (as well as any entity owned in the aggregate, directly or indirectly, 50% or more by one or more such persons, commonly known as 50% rule) still remain, the amendments to the BSR support trade and facilitate the movement of goods within Myanmar to a greater extent. For example, the amendment now permits U.S. persons residing in Myanmar to conduct a wider range of transactions, and allow most transactions with Myanmar financial institutions.