The EU today made permanent its action last year in suspending the EU sanctions against Myanmar except those relating to arms, military equipment and equipment that can be used for internal repression. Sanctions relating to arms, military equipment and internal repression remain in place.

In the meanwhile, U.S. sanctions relating to Myanmar continue to prohibit (a) the provision of “financial services … in connection with the provision of security services” to or (b) any new investment with (i) the Myanmar Ministry of Defense, (ii) any Myanmar armed group or (iii) any entity in which the Ministry of Defense or armed group owns a 50% or greater interest. U.S.sanctions relating to Myanmar also continue to prohibit (a) the provision of “financial services” of any kind to or (b) any new investment with (i) someone whose property or interests in property are blocked or (ii) any entity in which a blocked person owns a 50% or greater interest.

As indicated in an earlier memorandum, U.S. sanctions also require any U.S. person making a permissible new investment in Myanmar to file reports on the investment with the U.S. State Department. State, however, has yet to issue final instructions on how the reporting requirement is to be fulfilled.