The Treasury Department's OFAC Issues General Licenses For Export Of Financial Services To Burma And New Investment In Burma

Originally published in V&E Export Controls and Economic Sanctions E-communication, July 16, 2012

On July 11, 2012, President Obama issued an Executive Order, and the Department of the Treasury, Office of Foreign Asset Control (OFAC) issued two General Licenses (GL-16 and GL-17), authorizing both the export of financial services to Burma and "new investment" in Burma, both of which were previously prohibited by the Burmese Sanctions Regulations. "New investment" in Burma is broadly defined and involves the development of Burma's resources. Generally, the licenses authorize these transactions unless they are in connection with blocked parties or property, the Ministry of Defense, or other any "armed groups," including the military. For "new investment" in Burma, there is an affirmative reporting requirement to the Department of State if the investment exceeds $500,000, or if the investment is pursuant to an agreement with the Myanma Oil and Gas Enterprise (MOGE). The executive order...