First, in updating the answer as to whether foreign financial institutions, including foreign-incorporated subsidiaries of U.S. Two of the amendments are specific to financial institutions' activities. financial institutions, and due diligence requirements. financial institutions, including foreign-incorporated subsidiaries of U.S. The amendments and additions primarily relate to banking transactions with or by non-U.S. OFAC also issued changes to its JCPOA FAQs on October 7, 2016-specifically, three amendments to current FAQs and three new FAQs. As a result, any activities that would have violated the Burmese sanctions during the past five years could still be subject to enforcement actions.Īdditional Guidance Regarding the Iran Sanctions Of note, OFAC has stated that, notwithstanding the termination of the Burmese sanctions, it will proceed with any active and ongoing investigations and enforcement actions involving violations of that sanctions program and will still investigate potential past violations that come to its attention. Companies should still conduct due diligence on such transactions as a best practice, though, including screening parties to transactions involving Burma against the SDN List because the SDN List still designates individuals and entities in Burma for reasons other than the now-terminated Burmese Sanctions Regulations. This means that, going forward, a company that transacts with Burma does not need to handle business with Burma differently than it would another nonsanctioned country. The property and interests in property of these individuals and entities are now unblocked.
In addition, OFAC removed approximately 200 Burmese individuals and entities who were designated on OFAC's List of Specially Designated Nationals and Blocked Persons ("SDN List") pursuant to the Burmese sanctions program. As a result, the OFAC-administered sanctions against Burma are no longer in effect, and the Burmese Sanctions Regulations, 31 C.F.R Part 537, will be removed from the Code of Federal Regulations. On October 7, 2016, President Barack Obama issued an Executive Order that revokes the Executive Orders that formed the basis of the sanctions against Burma and waives certain other statutory blocking and financial sanctions on Burma. Sanctions Under the Joint Comprehensive Plan of Action ("JCPOA") on Implementation Day ("JCPOA FAQs") relating to the Iranian Transactions and Sanctions Regulations. Separately, the Department of the Treasury's Office of Foreign Assets Control ("OFAC") amended its Frequently Asked Questions Relating to the Lifting of Certain U.S. government, consistent with previously stated intentions, lifted the economic and financial sanctions against Burma (Myanmar).
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