Eagerly awaited changes to U.S. financial and investment sanctions on Burma have finally arrived. U.S. businesses are now able to engage in new investment in Burma and provide financial services for the first time since the United States implemented sanctions against the country fifteen years ago. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License Nos. 16 and 17 on July 11, 2012, which amend the Burmese Sanctions Regulations (BSR) (31 C.F.R. Part 537) and now authorize certain long-restricted activities. Important compliance and reporting obligations for U.S. companies remain, however. In looking toward potential opportunities, U.S. companies must vet business partners and investments carefully, and consider numerous corporate governance matters raised by new Reporting Requirements associated with the changes.
As Venable previously reported, the United States initiated its sanctions program in 1997 in response to the Government of Burma’s large-scale repression of democratic opposition. The issuance of these General Licenses constitutes the latest step in the Obama Administration’s efforts to ease U.S. sanctions against Burma in recognition of the Government’s progress toward political reform. In April 2012, OFAC issued General License 14-C, which permitted the provision of financial services to Burma, but only with respect to designated not-for-profit activities. The new General Licenses include the most expansive authorizations to date; however, the authorized activities are still subject to certain limitations.
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