Pending OFAC enforcement matters will proceed irrespective of the termination of OFAC-administered sanctions on Burma, and OFAC will continue to review apparent violations of the BSR, whether they came to the agency’s attention before or after the Burma sanctions program was terminated. Under longstanding practice, apparent sanctions violations are analyzed in light of the laws and regulations that were in place at the time of the underlying activities, and civil and criminal enforcement authorities are applied accordingly. Current or future investigations regarding apparent violations of the BSR will not be impacted by its termination and may result in OFAC enforcement actions after the termination of the BSR.
For an organizational chart of the United Nations, which lists the Programmes, Funds, and Other Entities and Bodies, as well as the Specialized Agencies and Related Organizations covered by this GL, see the following page on the United Nations website: https://www.un.org/en/pdfs/un_system_chart.pdf.
Burma General License (GL) 4authorizes, subject to certain conditions, all transactions and activities prohibited by Executive Order (E.O.) 14014, that are ordinarily incident and necessary to the wind down of transactions involving, directly or indirectly, Myanmar Economic Corporation Limited (MEC) or Myanma Economic Holdings Public Company Limited (MEHL), or any entity in which MEC or MEHL owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m., eastern daylight time, June 22, 2021. Persons unable to wind down transactions prohibited by E.O. 14014 in which such blocked persons have an interest before that time are encouraged to seek formal guidance from OFAC.
For the duration of GL 4, non-U.S. persons may wind down transactions involving, directly or indirectly, MEC or MEHL, or any entity in which MEC or MEHL owns, directly or indirectly, a 50 percent or greater interest, without exposure to sanctions under E.O. 14014, provided that such wind down activity is consistent with GL 4.
While GL 4 is in effect, wind down transactions may be processed through the U.S. financial system or involve U.S. persons, as long as the transactions comply with the terms and conditions in GL 4.