Revamped Burmese Sanctions Regulations

On August 16, the Office of Foreign Assets Control reissued a thoroughly revised version of the Burmese Sanctions Regulations. OFAC says the extensive rewrite was needed in order to implement the Burmese Freedom and Democracy Act of 2003. One of the major provisions of the BFDA was to institute a ban on imports from Burma, a measure which remains in effect through today.

The revamped regulations do provide some important (and rather elementary) definitions, such as “exportation or reexportation of financial services to Burma” and “product of Burma”. They also codify a number of exemptions, including some for US citizens and diplomats in Burma and for certain humanitarian and publishing activities, some of which were previously permitted only under general licenses. It is also worth reminding our readers that OFAC’s sanctions on Burma remain somewhat less comprehensive than those applied to Cuba or Iran. For example, while imports and exports of financial services are generally banned, exports of goods and non-financial services are permitted, though exporters should proceed carefully to avoid transactions involving blocked property and the ban on new investment by US persons.