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Directive 1 Under Executive Order 14014 (the "MOGE Financial Services Directive")

Date issued: Oct. 31 2023

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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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TURBOFAC Commentary (1108 words)

Notes:

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 the provision of “financial services” to a given person or place.

OFAC provides guidance at FAQ # 1138 and FAQ # 1139 concerning the scope of the prohibition. OFAC clarifies in FAQ # 1139 that the 50 Percent Rule applies, and in FAQ #...