International sanctions programmes targeting Myanmar have been in place since 2003, when they were imposed following a violent crackdown on opposition in the country. A US programme was discontinued in 2016 as the country began to liberalise under Aung San Suu Kyi from 2011. As state-backed ethnic violence against the country’s Rohingya minority has increased since 2018, the US has begun to impose sanctions against Burmese individual under its Global Magnitsky programme.
In 2021 the EU and the US introduced new designations targeting individuals deemed to be connected to the country’s February 2021 military coup.
Sanction Name
Restrictive Measures In Respect Of Myanmar/Burma
First Imposed
Last updated
Targets
Travel Ban and Asset Freeze:
•On 21st February 2022 the EU imposed sanctions on 22 persons in Myanmar, including government ministers and senior armed forces members, as well as four entities, including state-owned energy company Myanmar Oil and Gas Enterprise.
Arms Embargo:
• Prohibition on the sale of arms or related materiel to the Myanmar military junta or its key officials.
Exemptions
1. The provision of technical assistance and financing for non-lethal military equipment intended solely for humanitarian purposes or protective use is allowed. The provision of the same, including protective clothing, is also permitted for UN personnel, representatives of the media and humanitarian and development workers.
Sanction Name
Regulation on measures against Myanmar
SANCTIONS
First Imposed
Last updated
Targets
Arms Embargo:
• A ban on the sale and transit of arms and goods that could be used for internal repression to individuals linked to political repression and human rights abuses under the country’s ruling military junta.
Trade Restrictions:
• A ban on the sale, supply, export or transit to Myanmar of technology or software that could be used to intercept or monitor communications. A ban is also in place on technology destined for military purposes and on the provision of services, including financial assistance, relating to the supply of such technology.
Exemptions
1. Non-lethal equipment intended solely for humanitarian or protective use; assets for crisis management operations of the UN, EU or Switzerland; demining equipment; and protective clothing for use by media, humanitarian, UN, EU or Swiss personnel are exempt.
On 31st January 2024, marking the three-year anniversary of the military coup in Myanmar, OFAC designated two entities closely associated with Myanmar’s military regime that maintain relationships with Myanma Economic Holdings Public Company Limited (“MEHL”), which was designated by OFAC on 25th March 2021, as well as four individuals who are closely related to the regime through their business relationships and activities. OFAC also issued General License 6 authorising the wind down of transactions involving one of the designated entities – the Shwe Byain Phyu Group of Companies.
On 10th February 2024 the US extended Executive Order 14014 with respect to the situation in Myanmar for a further year until 10th February 2025.
Sanction Name
Burma-Related Sanctions Program
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated National:
• Targeted at those who “played a leading role in the overthrow of Burma’s democratically elected government” in the coup on 1st February 2021.
Exemptions
On 25th March 2021 OFAC issued 4 General Licences authorising the following exemptions to its Burma Sanctions Program:
– Official Business of the United States Government
– Official Activities of Certain International Organizations and Other International Entities
– Certain Transactions in Support of Nongovernmental Organizations’ Activities
– Authorizing the Wind Down of Transactions Involving Myanmar Economic Corporation Ltd and Myanmar Economic Holdings Public Company Ltd
Links 1
Sanction Name
Myanmar (Sanctions) Regulations 2021
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze:
• Those involved in undermining democracy, the role of law or good government in Myanmar, the repression of the civil population, the obstruction of proper investigation or the committing of human rights abuses. The asset freeze has been extended to holding companies owned by the country’s military and other state owned entities.
Exemptions
1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings.
