This page covers the programme currently administered as the Burma Sanctions Regulations. It is the United States’ programme; this site has not built out the parallel UK and EU measures.
What the regulations block
The prohibition in 31 CFR 525.201 rests on E.O. 14014, cited in the regulations’ authority line. It blocks all property of any person the Secretary of the Treasury determines, in consultation with the Secretary of State, to:
- operate in the defence sector or the jet fuel sector of the Burmese economy, or any other sector the Secretary so determines;
- be responsible for or complicit in actions or policies that undermine democratic processes or institutions in Burma, threaten its peace, security or stability, limit freedom of expression or assembly, or involve arbitrary detention, torture or other serious human rights abuse;
- be or have been a leader or official of the military or security forces, or of the Government of Burma on or after 2 February 2021;
- be a political subdivision, agency or instrumentality of the Government of Burma, or the spouse or adult child of a blocked person; or
- have materially assisted or provided support to a blocked person.
Why it matters for evasion analysis
Two features shape the exposure. It is partly a sector programme: a company can be blocked because it operates in the defence or jet fuel sector, not because of anything it did to a named person, so the counterparty’s line of business is itself a screening input. And its definition reaches family members and successor entities, which puts ownership and control questions, of the kind described on the fifty percent rule page, at the centre of any review.
This page records the programme’s legal structure only. It describes no enforcement case, because none in this site’s OFAC penalty record is tied to it, and it does not characterise conditions in Myanmar.