- within International Law, Intellectual Property, Litigation and Mediation & Arbitration topic(s)
Six U.S. federal executive departments collectively issued an Advisory on the risks associated with doing business in Burma. In the Advisory, the executive departments recommended that businesses and individuals conduct appropriate due diligence to ensure they are not engaging with Burma in ways that that may expose them to various reputational, financial and legal risks, including violations of U.S. AML and sanctions.
The Advisory highlighted four primary industries in Burma that have been of particular concern since the Burma military overthrew the country's democratically elected government in 2021: (1) state-owned enterprises, (2) gems and precious metals, (3) real-estate and construction projects, and (4) arms, military equipment, and related activity. According to the Advisory, these industries not only provide economic resources to Burma's military regime, which has committed egregious human rights violations, but also are associated with child and forced labor, corruption, money laundering, and illegal arms trade and trafficking.
The executive departments called on those who work within the abovementioned sectors to undertake appropriate investigations to ensure that their conduct is in compliance with U.S. sanctions and money laundering controls.
Primary Sources
- OFAC Final Rule: Burma Sanctions Regulations
- Collective Federal Agencies: Risks and Considerations for Businesses and Individuals with Exposure to Entities Responsible for Undermining Democratic Processes, Facilitating Corruption, and Committing Human Rights Abuses in Burma (Myanmar)
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