U.S. Parties Authorized to Transact Business in Burma’s Largest Banks

Today, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), issued General License No. 19, authorizing additional U.S. economic activity in Burma.  The general license permits individuals, companies, and financial institutions to conduct business with Burma’s four major banks:  Asia Green Development Bank, Ayeyarwady Bank,  Myanma Economic Bank, and Myanma Investment and Commercial Bank.  This new General License will ease the ability with which U.S. companies can do business in and with Burma.  Last year, the U.S., the EU, and other countries eased economic sanctions against Burma to authorize investment and greater economic activity with Burma.

While General License No. 19 allows U.S. companies to transact business with these banks, there are restrictions.  General License No. 19 can be found here, http://1.usa.gov/YIl6jV.  This serves as a reminder that U.S. companies must carefully conduct business in Burma to comply with the remaining OFAC sanctions and the State Department’s Reporting Requirements for Responsible Investment in Burma.


OFAC Authorizes Imports of Products of Burma

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has issued General License No. 18, authorizing the importation of products from Burma.  The General License can be relied on by U.S. and non-resident importers into the U.S. to increase U.S.-Burma trade.  The only items not authorized for importation under General License No. 18 are jadeite or rubies mined or extracted from Burma or jewelry containing jadeite or rubies mined or extracted from Burma, unless these items are being reimported to the U.S. by the same party that exported them and they are reimported in the same condition and are of the same value as when exported from the U.S.

Importantly, General License No. 18 states that “product of Burma” has the meaning ascribed to it under the rules of origin set forth by U.S. Customs and Border Protection (CBP).  The rules of origin for Customs purposes can require a complex analysis of the imported article and should be carefully addressed by importers of products from Burma so as to not violate the terms of General License No. 18.

For questions or assistance with importing products of Burmese origin into the U.S., including rule of origin questions, and other assistance with OFAC regulations, sanctions, and licenses and Customs issues, please contact Jon P. Yormick, Attorney and Counsellor at Law, [email protected]

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