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On June 1, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published the Burma Sanctions Regulations at 31 C.F.R. Part 525 (the “BSR”) to implement Executive Order 14014, “Blocking Property With Respect to the Situation in Burma” (“EO 14014”). EO 14014 imposed sanctions on certain Burmese parties in response to the Burmese military’s coup against the democratically elected civilian government.

The BSR do not expand upon the sanctions previously imposed under EO 14014, but do introduce new general licenses authorizing:

  • the provision of certain legal services to Specially Designated Nationals (“SDNs”) designated pursuant to EO 14014, and payment for such services from certain funds originating outside the United States;
  • the provision and receipt of nonscheduled emergency medical services;
  • deductions from blocked accounts of certain service charges owed to US financial institutions; and
  • transfers of funds or credits between blocked accounts held by US financial institutions in their branches and offices, provided that no transfers are made from accounts held within the United States to accounts held outside the United States, and also provided that a transfer from a blocked account may be made only to another blocked account held in the same name.

OFAC also indicated that the BSR is being published in abbreviated form, and that it intends to provide more comprehensive regulations at a later date. Please see our prior blog posts on the sanctions imposed under EO 14014 here, and on two military-affiliated Burmese conglomerates here.

The authors acknowledge the assistance of Alexandra Pasch in the preparation of this blog post.


Kerry Contini is a partner in the Firm’s Outbound Trade Practice Group in Washington, DC. She has served as co-chair of the Firm's Pro Bono committee for several years and has managed award-winning pro bono work involving Baker McKenzie professionals in North America, Europe and Asia. She has written on export controls and trade sanctions issues for several publications, including The Export Practitioner and Ethisphere. Kerry is a co-chair of the Export Controls and Sanctions Section of the Association of Women in International Trade. She joined the Firm as a summer associate in 2005 and became a full-time associate in 2006.


Alexandre Lamy joined Baker McKenzie in 2009 and currently works in the Firm's International Trade Practice Group. He assists clients with sanctions and export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and he advises clients on corporate compliance matters. Since August 2011, Alex has served on the steering group for the ABA Section of International Law’s Export Controls & Economic Sanctions Committee and is currently a Vice Chair of the Committee. He has organized several events regarding recent developments in US trade sanctions and export controls for the Committee.


Daniel Andreeff is an associate in the Firm’s International Trade practice group in Washington, DC. Prior to joining the Firm, he interned with the Department of the Treasury’s Office of Foreign Assets Control.

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