Litigation

Sanctions Roundup Third Quarter 2021

Shearman & Sterling LLP

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5 MYANMAR (BURMA) OFAC Continues to Target Myanmar Military and Its Support Networks On July 2, OFAC designated twenty-two individuals pursuant to Executive Order 14014, which targets, in part, members of Myanmar's military allegedly responsible for suppressing democracy and committing human rights abuses against the people of Myanmar. Among those designated were several government cabinet members, including: the Minister of Labour, Immigration, and Population, Myint Kyiang; the Minister of Social Welfare, Relief, and Resettlement, Thet Khine; the Minister of Information, Chit Naing; and the Minister of Investment and Foreign Economic Relations, Aung Naing Oo. OFAC also targeted Saw Daniel, Banyar Aung Moe, and Aye Nu Sein, three members of the Military-led State Administrative Council, a political body created by the military to support its overthrow of the civilian government. The other fifteen designated individuals are the spouses and adult children of previously designated Myanmar government and military officials whose financial networks provide support for the military regime. On the same day, the U.S. Department of Commerce's Bureau of Industry and Security added four companies to the "Entity List." The additions included King Royal Technologies Co., Ltd., a telecommunications company that provides satellite communication services to Burma's military. BIS also added three copper mining companies: Wanbao Mining Ltd. and two of its subsidiaries, Myanmar Wanbao Mining Copper, Ltd. and Myanmar Yang Tse Copper, Ltd. According to BIS, these copper companies have revenue-sharing agreements with Myanmar Economic Holdings, a company designated by OFAC in March of this year. As a result of being added to the Entity List, a license is required to export, re-export, or transfer in-country any U.S.-origin item to any of the four entities, and BIS will apply a presumption of denial to any license application.

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