US Government Adds 4 Military-Connected Entities In Burma To Entity List And Sanctions 22 Burmese Individuals
03 August 2021
Husch Blackwell LLP
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As part of the U.S. Government’s ongoing response to the
military coup in Burma (Myanmar), the Department of Commerce’s
Bureau of Industry and Security (“BIS”) added four entities to the Entity List
effective July 6, 2021 and the Department of Treasury’s Office
of Foreign Assets Control (“OFAC”) added twenty-two individuals to the Specially
Designated Nationals & Blocked Persons List (“SDN
List”) effective July 2, 2021.
Commerce Secretary Gina M. Raimondo noted that the four entities
include a satellite communications services provider to the Burmese
military and three entities that have revenue-sharing agreements
with Myanmar Economic Holdings Limited (“MEHL”), an
entity that generates revenue for the Burmese military and which
was previously added to the Entity List. As a
result of the additions, licenses are required for exports,
reexports, and in-country transfers of all items “subject to
the EAR” to the four entities and BIS will employ a
presumption of denial license review policy. The entities are:
- King Royal Technologies Co., Ltd.;
- Myanmar Wanbao Mining Copper, Ltd.;
- Myanmar Yang Tse Copper, Ltd.; and
- Wanbao Mining, Ltd.
The twenty-two individuals added to the SDN List under Executive
Order 14014 include two members of the State Administrative Council
currently participating in governance of Burma and the Ministers of
Information; Investment and Foreign Economic Relations; Labor,
Immigration, and Population; and Social Welfare, Relief, and
Resettlement. Fifteen of the twenty-two added to the SDN List were
added because of being either spouses or adult children of persons
on the SDN List.
As a result of the SDN designations, all property and interests
in property of these persons in the US or controlled by US persons
must be blocked and reported to OFAC. US persons are prohibited
from sending or receiving any provision of funds, goods, or
services to/from these newly designated SDNs. According to
OFAC’s “50% Ownership Rule,” these sanctions also
extend to any subsidiaries in which these SDNs directly or
indirectly hold, either individually or in the aggregate with other
SDNs, an ownership interest of 50% or more.
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