Blog Post 04.26.21
Alert
Alert
02.24.22
Businesses with exposure in the region should review the designations to assess exposure to the latest EU restrictions.
Just over a year after the military coup by the Myanmar Armed Forces (the Tatmadaw) in February last year, the EU has adopted further sanctions in view of the intensifying human rights violations in the region.
The new restrictions, which were adopted on February 21, 2022, target companies providing substantive resources, or closely connected, to the Tatmadaw.
The restrictive measures include asset freezes, and a prohibition on making funds available to listed individuals and entities, as well as a travel ban.
The newly listed entities are:
Thus, the sanctions include important state energy and mining companies, as well as large industrial conglomerates associated with the Tatmadaw and regime crony Tay Za (Htoo Group). This reflects a significant step in the economic significance of EU sanctions measures for Myanmar. The full list of the new designations is included as an annex to the implementing regulation, which can be accessed here.
Existing EU measures, including an embargo on arms and equipment, an export ban on dual-use goods, export restrictions on equipment for monitoring communications, and prohibitions on military training, remain in full effect.
The EU has accompanied the new restrictions with a call for an immediate cessation of all hostilities and an end to the disproportionate use of force and the state of emergency.
The measures include a grandfathering provision such that payments due under a contract or agreement concluded by the relevant sanctioned person prior to the date of their designation may be permitted to the extent certain conditions are met.
Pillsbury’s International Trade lawyers remain on hand to guide your business through the evolving global regulatory landscape. For advice on how this latest development may impact your business, please reach out to your usual Pillsbury contact.