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State of Financial Crime 2023 Report

Myanmar Sanctions: What You Need To Know

Sanctions Knowledge & Training

Numerous countries have imposed sanctions against Myanmar in response to its government’s violent suppression of pro-democratic movements, institutional corruption, and human rights abuses. Also known as ‘Burma’, Myanmar has struggled with internal conflict since the mid-20th century: after it gained its independence from the UK in 1948, Myanmar entered a period of political transition that saw several ethnic groups vying for control and often engaging in violent conflict. Myanmar’s military junta took control of the country in 1988 and has subsequently been accused of numerous human rights violations and the political oppression of opponents. The actions of the Burmese government have prompted a collective response from the international community and a range of economic sanctions measures. Notable sanctions programs against Myanmar are enforced by the US, the EU, the UK, Australia, and Canada and include measures such as arms embargoes, trade embargoes, asset freezes, travel bans, and investment bans. To ensure compliance with Myanmar sanctions, firms should be familiar with the relevant restrictions applicable in their jurisdiction.

Landscape of Myanmar: Sanctions

Myanmar Sanctions: US

The United States implemented sanctions against Myanmar in 2003, imposing a ban on imports from Myanmar, a ban on financial service exports to Myanmar, asset freezes on Burmese financial institutions, and travel bans on Burmese officials. The US imposed another round of sanctions in 2007, with asset freezes on a further 25 senior officials, and the authorization for asset freezes on any individuals deemed responsible for human rights abuses in Myanmar. 

While the US has eased some Myanmar sanctions since 2007, it has also expanded and added new restrictions in response to ongoing human rights abuses and acts of political oppression. In 2021, President Biden imposed new restrictions in response to a military coup d’état against Myanmar’s democratically elected government. The 2021 sanctions targeted the parties responsible for the military coup and essentially reintroduced previous sanctions measures with new licenses authorizing certain economic activities, including the provision of legal services and medical services.

EU Sanctions on Myanmar

The EU has imposed economic sanctions on Myanmar since 2008 as a response to the government’s ongoing oppression of pro-democracy groups and its human rights abuses. Since then, the EU has strengthened and added additional rounds of Myanmar sanctions, with restrictive measures including import and export bans, bans on the provision of certain services, travel bans, and asset freezes against Burmese government officials and companies. 

In 2021, the EU joined the US in imposing a new round of sanctions on Myanmar following the military coup and the subsequent violent repression of pro-democracy protests. The EU’s 2021 sanctions expanded existing measures against Myanmar, targeting 8 Burmese individuals and 4 state-owned (or military-controlled) organizations for asset freezes and investment prohibitions.

Myanmar Sanctions: UK

The UK’s economic sanctions against Myanmar reflect those of the US and the EU with restrictive measures that include asset freezes, investment prohibitions, and travel bans against certain Burmese government officials. 

Previously an EU member state, the UK complied with the European Parliament’s Myanmar sanctions up to 2021, at which point HM Treasury implemented autonomous UK Myanmar sanctions. The UK’s Myanmar (Sanctions) Regulations 2021 are intended to promote peace, stability, and democracy in Myanmar, and ensure respect for international human rights law. The 2021 sanctions impose ‘financial, trade, and immigration’ restrictions, including the prohibition on the export and transfer of military and communications technology and financial services to Myanmar.

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Australia Sanctions on Myanmar

Australia’s autonomous sanctions against Myanmar date back to the 1990s and were originally imposed in response to the Burmese government’s efforts to undermine the results of democratic elections. Australia eased some sanctions against Myanmar in 2012 following the Burmese government’s implementation of democratic reforms, but introduced new sanctions in 2018 after a UN report revealed human rights abuses perpetrated by the Burmese military.    

The Australian autonomous Myanmar sanctions regime involves an arms embargo, prohibitions on the provision of financial services, asset freezes for certain Burmese individuals and entities, trade restrictions, and travel bans.

Myanmar Sanctions: Canada

Canada initially imposed sanctions on Myanmar in 2007 with the introduction of the Special Economic Measures (Burma) Regulations. The restrictive measures included an arms embargo, asset freezes against Myanmar nationals, and a prohibition on the export of financial services relating to military activities. 

In 2021, in coordination with the US, the UK, and the EU, Canada expanded its Myanmar sanctions regime in response to the military coup d’état and ongoing human rights abuses. The 2021 sanctions entailed additional asset freezes for 16 individuals and 10 entities in Myanmar.

Myanmar Sanctions Screening

Firms must ensure that they do not violate sanctions regulations when doing business with customers from Myanmar or that have business connections with Myanmar. To ensure compliance, firms should integrate a sanctions screening solution that is informed by the latest Myanmar sanctions data, and that is capable of managing specific challenges such as the use of Burmese naming conventions and nicknames, and the use of characters in the Burmese Brahmic alphabet.

Originally published 03 August 2021, updated 22 May 2022

Disclaimer: This is for general information only. The information presented does not constitute legal advice. ComplyAdvantage accepts no responsibility for any information contained herein and disclaims and excludes any liability in respect of the contents or for action taken based on this information.

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