U.S. Sanctions Update

The United States has lifted most of its sanctions on Myanmar: the country is now open for U.S. business. It is a formative environment, however, and the U.S. sanctions that remain makes a Myanmar investment more challenging for U.S. companies and multinationals with U.S. affiliates than for companies elsewhere. The EU, UK and Australia have lifted their sanctions and no Asian country maintains sanctions. For most companies subject to the reach of U.S. law, however, the remaining sanctions, such as the Specially Designated Nationals (SDN) list discussed below, should be manageable.

Current U.S. Sanctions

Prior to July 2012, the Burmese Sanctions Regulations (BSR) prohibited transactions with and blocked the property of certain entities and individuals associated with the previous military government. Sanctions prohibited exports of financial services, new investment and imports from Myanmar to the United States. In addition, the U.S. Treasury Department imposed “special measures” under the USA PATRIOT Act, which imposed heightened due diligence obligations on U.S. banks and prohibited them from opening or maintaining correspondent accounts with banks in Myanmar.

Download: U.S. Sanctions Update: Remaining Sanctions Manageable