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270. Can U.S. financial institutions enter into direct correspondent relationships with Burmese financial institutions that are not blocked?
Yes. U.S. financial institutions may enter into direct correspondent relationships with any non-blocked Burmese bank.
As a result of Burma GL 19, U.S. financial institutions also may enter into direct correspondent relationships with the following four blocked Burmese banks: Asia Green Development Bank, Ayeyarwady Bank, Myanma Economic Bank, and Myanma Investment and Commercial Bank.
As a result of Burma GL 16 and Burma GL 19, the special measures against Burma imposed under Section 311 of the USA PATRIOT Act no longer apply to the operation of correspondent accounts for those Burmese banking institutions, or to transactions that are conducted through such accounts, provided the transactions are authorized pursuant to the Burmese Sanctions Regulations. This does not affect any obligation of U.S. financial institutions processing such transactions to conduct enhanced due diligence under Section 312 of the USA PATRIOT Act.
U.S. persons generally remain prohibited from dealing with other blocked banks, including Myanma Foreign Trade Bank, Myawaddy Bank, and Innwa Bank, with the exception of funds transfers made pursuant to Burma GL 16. Because U.S. financial institutions are not permitted to open correspondent relationships with these blocked banks, funds transfers to or from these banks are routed through third countries (see Question 359 for more information). [04-01-14]
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1) Refer to comment to FAQ 269. FAQ appears to contain no guidance of cross-programmatic value.