Following up on our previous post, on October 7, 2016, President Obama issued an Executive Order (which we will refer to as the New EO), lifting all US economic and financial sanctions on Myanmar. This order follows a September 14, 2016 announcement on which we previously advised. The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a fact sheet, frequently asked questions (FAQ), and delisting announcement; the Financial Crimes Enforcement Network (FinCEN) issued a press release and an exceptive relief announcement implementing and explaining these changes.
The most significant change in the New EO is the termination of the national emergency involving Myanmar and the revocation of previous executive orders imposing economic and financial sanctions on the country. These sanctions are set forth in OFAC’s Burmese Sanctions Regulations, which OFAC should soon remove from the Code of Federal Regulations (CFR). With the issuance of the New EO, OFAC no longer administers any economic or financial sanctions on Myanmar. However, certain restrictions on commerce and financial activity, detailed in our new in-depth advisory, will remain.