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Sanctions – Burma/Myanmar

Overview

While there is a history of sanctions imposed against various Myanmar governmental regimes since the late 1980s, a concerted multi-state sanction initiative began in 2021 as a result of the military coup which took place on 1 February 2021 ending the rule of a democratically elected government. A state of emergency was declared by the new military leadership, initially for a period of one year but later extended to three years and six months.

In response, the United States, the United Kingdom and the European Union have each established targeted sanctions regimes directed at those individuals and entities responsible for enabling the coup, sustaining the military regime and committing or facilitating human rights abuses.

Member Advisory

Members conducting business with or involving Myanmar are advised to undertake and maintain the following due diligence measures:

  • Cargo due diligence: Carefully assess the nature of all cargoes intended to be shipped to or from Myanmar. Be alert to any commodities or items that could be used by the military government for ethnic or political repression, including arms, dual-use goods, jet fuel, and surveillance equipment.
  • Jet fuel: Given OFAC FAQ 1132 and 1133, and the October 2024 UK designations targeting aviation fuel supply chains, Members should treat any shipment of jet fuel to Myanmar as presenting an extremely high sanctions risk. As noted in the United States section below: “In practice, it may prove impossible for Members to obtain sufficient comfort that any jet fuel carried is only for use in civil aviation, and it is therefore highly likely that any carriage of jet fuel to Burma will trigger Clubs’ sanctions exclusions in light of the US legislation and associated FAQs.”
  • Aviation fuel supply chains: The October 2024 UK designations specifically name entities involved in the supply of aviation fuel to the Myanmar security forces. Members should conduct enhanced due diligence on all parties in aviation fuel supply chains involving Myanmar.
  • Supply chain and beneficial ownership: Conduct enhanced scrutiny of the corporate ownership structure of Myanmar counterparties. Military-linked entities frequently operate through complex holding structures. The 50% rule (US) and equivalent provisions (UK and EU) mean that unlisted subsidiaries of designated persons may nonetheless be subject to sanctions.

United States

The US sanctions regime against Myanmar/Burma is administered by the Office of Foreign Assets Control (OFAC) within the US Department of the Treasury. The primary legal instrument is Executive Order 14014 ("Blocking Property With Respect to the Situation in Burma"), signed on 11 February 2021 by President Biden, and subsequently elaborated through sector-specific Determinations, Directives, and the Burma Sanctions Regulations (BSR) codified at 31 CFR Part 525.

The Burma Sanctions Regulations were most recently amended and reissued in their entirety in 13 November 2024. Amended regulations are published in the Code of Federal Regulations and notices of amendment appear in the Federal Register.

The US sanctions apply to all US persons wherever located in the world and to any transaction involving US persons, US-incorporated entities, or property within the United States. Non-US persons may also be subject to secondary sanctions in specified sectors (see jet fuel sector determination below).

Key Prohibitions

Myanmar Oil and Gas Enterprise (MOGE) Financial Services Directive (Directive 1, effective 15 December 2023)

Pursuant to Directive 1 under E.O. 14014, the provision, exportation, or re-exportation, directly or indirectly, of financial services to or for the benefit of MOGE are prohibited for US persons, on or after 15 December 2023.

For the purposes of this Directive, "financial services" is construed broadly to include: loans, transfers, accounts, insurance, investments, securities, guarantees, foreign exchange, letters of credit, and commodity futures or options.

Jet Fuel Sector Determination (effective 23 August 2023)

As set out in our Notice to Members No.8 2023/24, on 23 August 2023 OFAC issued a determination that allows sanctions to be imposed on any foreign individual or entity that operates in the jet fuel sector of the Burmese economy by expanding Executive Order 14014 (the “EO”). The expansion of the EO by the U.S. authorities is “complementing existing provisions for sanctions against those that operate in the defence sector of the Burmese economy” (press release 23 August 2023).

Pursuant to the Determination made under Section 1(a)(i) of E.O. 14014, OFAC may impose sanctions on any foreign individual or entity that operates in the jet fuel sector of the Burmese economy.

The term "jet fuel sector of the Burmese economy" is defined to include activities related to the importation, exportation, re-exportation, sale, supply, or transport, directly or indirectly, of jet fuel in or involving Burma.

Practical guidance: OFAC FAQ 1132 and FAQ 1133 confirm that any person supplying jet fuel to entities in Burma must exercise extreme caution to ensure supply is only for civil aviation purposes. In practice, obtaining sufficient assurance that jet fuel will not reach military regime end users may prove impossible, and such carriage is therefore highly likely to engage sanctions exclusion provisions.

Although it was clarified that OFAC does not intend to target persons for engaging in activities related to civil aviation, including the sale, provision, or purchase of jet fuel to or for commercial airlines for air transport to and from Burma, the OFAC FAQs indicate that: “Anyone supplying jet fuel to individuals or entities in Burma should exercise extreme caution to ensure jet fuel is provided only for use in civil aviation and not to military regime users”.

In practice, it may prove impossible for Members to obtain sufficient comfort that any jet fuel carried is only for use in civil aviation, and it is therefore highly likely that any carriage of jet fuel to Burma will trigger Clubs’ sanctions exclusions in light of the US legislation and associated FAQs.

Relevant Resources

OFAC Burma-Related Sanctions Programme Page - central hub for all OFAC Burma programme materials, general licences, directives, and sign-up for e-mail updates (ofac.treasury.gov).
OFAC Sanctions List Search Tool - search the SDN List and all OFAC consolidated sanctions lists (sanctionssearch.ofac.treas.gov).
OFAC Recent Actions - Burma filter - filterable log of all Burma-related designation actions and
Executive Order 14014 - Blocking Property With Respect to the Situation in Burma (11 February 2021), the primary legal authority for the US Burma sanctions programme.
Burma Sanctions Regulations, 31 CFR Part 525 - full text of the BSR as amended and reissued in their entirety on 13 November 2024.
Supplemental Burma Business Advisory (26 January 2024, issued jointly with the UK) — highlights continuing risks for businesses with exposure to military-linked entities.
OFAC Burma Sanctions FAQs (including FAQ 1132 and 1133 on jet fuel)

European Union

The EU's sanctions regime against Myanmar/Burma is founded upon two principal instruments operating in tandem:

The EU sanctions were comprehensively strengthened by EU Regulation 2023/2789.

Prohibitions

Arms Embargo and Military Equipment

The direct or indirect sale, supply, transfer, or export of all arms and military materiel — including weapons and ammunition, military vehicles, paramilitary equipment, and spare parts — to any person or entity in Myanmar/Burma, or for use in Myanmar/Burma, are prohibited.

Dual-Use Goods - Military End-Users

The direct or indirect sale, supply, transfer, or export of dual-use goods and technology (as listed in Annex I to Council Regulation (EC) No 428/2009) are prohibited where the goods are for military use in Myanmar/Burma, or for a military end-user or the Border Guard Police. Any dual-use goods procured by the Myanmar military are deemed to be for military use.

Equipment for Internal Repression

The sale, supply, transfer, or export, directly or indirectly, of equipment that might be used for internal repression (as listed in Annex I to Regulation (EU) No 401/2013) is prohibited, unless intended for military use. Prohibited items include:

  • Firearms and ammunition; weapon sights; bombs and grenades.
  • Riot control vehicles equipped with water cannons; armoured or protected vehicles.
  • Explosives designed to initiate explosions by electrical or non-electrical means (except specific commercial uses such as car airbag inflaters).
  • Helmets and shields providing ballistic or fragmentation protection.

Surveillance and Monitoring Technology

The sale, supply, transfer, or export of equipment, technology, or software that could be used to monitor or intercept internet or telephone communications is prohibited unless prior authorisation is obtained from the relevant Member State authority. Authorisation shall not be granted where there are reasonable grounds to believe the equipment would be used for internal repression by the Myanmar government or its agencies. Member States that grant such authorisation must inform the other Member States and the European Commission within four weeks.

Relevant Resources

EU Council - Sanctions Against Myanmar - official Council page covering the Myanmar sanctions regime, current designated persons list, and regime timeline (consilium.europa.eu).
EU Sanctions Map - Myanmar - interactive tool showing all EU sanctions regimes including Myanmar measures and designated persons (sanctionsmap.eu).
Council Decision 2013/184/CFSP (as amended to 29 April 2025) - the political framework instrument establishing the EU Myanmar sanctions regime (EUR-Lex).
Council Regulation (EU) No 401/2013 (as amended to 29 April 2025) - the directly applicable Regulation giving legal effect to EU Myanmar sanctions across all Member States (EUR-Lex).
Council Implementing Regulation (EU) 2025/822 (25 April 2025) - most recent implementing regulation; also extended measures until 30 April 2026 (EUR-Lex).

United Kingdom

The UK's Myanmar sanctions regime is established under the Myanmar (Sanctions) Regulations 2021 (S.I. 2021/496), made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018). These Regulations came into force on 29 April 2021 and superseded the Burma (Sanctions) (EU Exit) Regulations 2019 (which themselves had replicated the EU sanctions regime following Brexit).

The Myanmar (Sanctions) Regulations were amended in 2024 (pursuant to the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024) to strengthen OFSI's enforcement powers, intelligence-gathering capacity, and licensing efficiency.

Key Prohibitions

Trade Sanctions - Military and Dual-Use Goods

The Regulations impose the following trade prohibitions:

  • Export prohibition: The sale, supply, transfer, or export, directly or indirectly, of military goods and technology (as specified in the relevant schedules) to Myanmar is prohibited.
  • Dual-use goods: The sale, supply, transfer, or export of dual-use goods and technology to any military end-user, the Myanmar Armed Forces, or the Border Guard Police is prohibited. Note: any dual-use goods procured by the military are deemed to be for military use.
  • Goods for civilian repression: Export of specified goods and technology that could be used to repress the civilian population of Myanmar is prohibited.
  • Surveillance and monitoring goods: Export of equipment, technology, or software capable of being used to intercept or monitor internet or telephone communications is prohibited without prior authorisation from the competent authority.
  • Aviation fuel (jet fuel): The making available of economic resources, including aviation fuel, to or for the benefit of the Myanmar security forces is prohibited. Recent designations (October 2024) specifically target entities involved in the supply of aviation fuel to the Tatmadaw.

Relevant Resources

FCDO Myanmar Sanctions Guidance - official UK government guidance on the Myanmar sanctions regime, including scope, prohibitions and licensing (gov.uk).
UK Sanctions List - sole authoritative list of all UK designations across all regimes (effective 28 January 2026, replacing the OFSI Consolidated List).
Myanmar Sanctions Notices and Designations - complete list of UK Myanmar designations with individual sanctions notices (gov.uk).
Myanmar (Sanctions) Regulations 2021 (S.I. 2021/496) - primary statutory instrument establishing the UK Myanmar sanctions regime (legislation.gov.uk).