After issuing a general license last month allowing U.S. companies and individuals to conduct business in Burma, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) just posted new Burma FAQson its website. The FAQs discuss recent steps the United States has taken to ease economic and trade sanctions against Burma, including General License Nos. 16, 17, 18 and 19.Burma-specific information is addressed in questions 268 through 286 on the Department’s Resource Center FAQ page.
The general license issued February 22 authorizes individuals, companies and financial institutions to conduct most transactions – including opening and maintaining accounts and conducting a range of other financial services – with four of Burma’s major financial entities: Myanma Economic Bank, Myanma Investment and Commercial Bank, Asia Green Development Bank, and Ayeyarwady Bank. This action gives U.S. companies and non-governmental organizations greater access to some of Burma’s largest Burmese banks and lets those financial institutions entities access the U.S. financial system. Investment in Burma was permitted July 2012. According to the new FAQs, though, new investments in those banks remain prohibited.
Importantly, however, Americans and American companies are still prohibited from doing business with any person listed on the OFAC’s Specially Designated Nationals and Blocked Persons list (SDN list), “as well as any entities 50 percent or more owned by such persons, which are blocked by operation of law regardless of whether the entities themselves are listed.”