Sanctions Round Up First Quarter 2022

Shearman & Sterling LLP

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8 MYANMAR (BURMA) OFAC Continues to Target Myanmar Military and Its Support Networks On March 25, OFAC designated five individuals and five entities connected to the military regime in Myanmar after the US concluded that the "Burmese military committed genocide, crimes against humanity, and ethnic cleansing against [the] Rohingya." Among those designated was the 66 th Light Infantry Division, a military unit allegedly responsible for serious human rights abuses. The 66 th Light Infantry Division purportedly played a role in the 2021 Christmas Eve massacre, in which numerous civilians were killed, burned alive, captured, and tortured. OFAC also designated two military leaders: Ko Ko Oo, the Commander of Central Command and the head of the Ministry of Defense's Technologies Department, and Major-General Zaw Hein, the Commander of the Nay Pyi Taw Command. OFAC designated an additional three arms dealers and their companies pursuant to E.O. 14014 for operating in the defense sector of the Myanmar economy. Specifically: • Naing Htut Aung and his company International Gateways Group of Company Limited were designated for, among other reasons, operating as an arms dealer who procured equipment from Chinese companies; • Aung Hlaing Oo and his company Myanmar Chemical & Machinery were sanctioned for allegedly setting up a manufacturing facility to produce military arms and equipment; and • Sit Tain Aung was designated for using his companies as fronts to broker arms deals. Finally, OFAC designated Htoo Group of Companies and its controlled-affiliate Asia Green Development Bank Ltd, for being owned or controlled by, Tay Za, who was designated in January 2022 for operating in the defense sector of the Burmese economy.

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