On May 17, 2012, the Obama Administration announced that it would begin the process of suspending sanctions against Burma. On July 11, 2012, the Administration issued two general licenses authorizing both the exportation of financial services to Burma and new investment by US persons in Burma, subject to certain limitations and reporting requirements. The Administration simultaneously issued a new Executive Order, which blocks the property and interests in property of individuals and entities found to be a threat to the peace, security and stability of Burma.

The Administration notes that apart from these modifications, the sanctions regime against Burma will remain in effect in order to provide the US Government with leverage to reinstate full sanctions should political progress in Burma stall. Further, the general licenses expressly do not authorize investments or financial services involving the Burmese Ministry of Defense, state or non-state armed groups, or entities owned by the foregoing, or transactions with, directly or indirectly, blocked persons, which include both individuals and entities listed on the Specially Designated Nationals List (“SDN List”), as well as any entities 50 percent or more owned by a Specially Designated National (“SDN”).

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