International Law Advisory - Burma Sanctions General License

General License Authorizations Issued Pursuant to Burmese Sanctions Regulations
On August 28, 2003, the US Treasury Department, Office of Foreign Assets Control ("OFAC") issued a new General License under the Burmese Sanctions Regulations (31 C.F.R. Part 537).  General License No. 9 authorizes the importation into the US of information and informational materials from Burma (Myanmar), and allows all transactions directly incident to such importation.1  Payments made pursuant to General License No. 9 are authorized, even if they involve the account of a financial institution whose property is blocked pursuant to Section 1 of Executive Order 13310,2 provided that the account is not on the books of a US financial institution.

Another general license (General License No. 10) authorizes the importation of certain personal and household effects by residents and citizens of Burma.

Companies should update their OFAC compliance screening mechanisms to ensure that any existing business relationships or future transactions are in compliance with the Burmese Sanctions Regulations.

We will continue to keep you apprised of sanctions and export control developments.  If you have any questions, please feel free to contact Ed Krauland at 202.429.8083 or Meredith Rathbone at 202.429.6437.

Footnotes
1 The term "information and informational materials" includes, among other things, "publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact discs, CD ROMs, [certain] artworks, and news wire feeds."
2 Individuals and groups named include: senior officials of the Government of Burma; the State Peace and Development Council (SPDC); the Union Solidarity and Development Association (USDA); the Myanma Economic Bank, the Myanma Foreign Trade Bank; the Myanma Investment and Commercial Bank; and any entity owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, any person whose property or interests in property are blocked pursuant to the order.