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OFFICE OF FOREIGN ASSETS CONTROL
DIRECTIVE 1 UNDER EXECUTIVE ORDER 14014
Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise
Pursuant to sections 1(a)(iv), 1(b), and 8 of Executive Order 14014, “Blocking Property With Respect to the Situation in Burma” (the “Order”), the Director of the Office of Foreign Assets Control (OFAC) has determined, in consultation with the Department of State that the Myanma Oil and Gas Enterprise (MOGE) is a political subdivision, agency, or instrumentality of the Government of Burma, and that the following activities by a U.S. person are prohibited on or after December 15, 2023 except to the extent provided by law, or unless licensed or otherwise authorized by OFAC:
the provision, exportation, or reexportation, directly or indirectly, of financial services to or for the benefit of MOGE or its...
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[Update – on 11-12-24, OFAC implemented Directive 1 into the CFR at 525.202, and defined the term “financial services” (for purposes of the Directive) at 525.305. The below has not yet been updated to reflect the addition of 525.305]
1) Directive 1 Under Executive Order 14014 (the “MOGE Financial Services Directive”) is unlike any other active sanctions prohibition in force as of the date of its October 21, 2023 date of issuance. This is for two reasons: first, there is no type of service-specific prohibition that applies on a targeted basis (contrast the Russia-related service prohibitions that apply to all “persons located in the Russian Federation”, e.g. the May 8, 2022 professional services determination pursuant to EO 14071). In addition, this is, as of October 21, 2023, the only prohibition that applies only to...