Sanctions Risks Associated with Provision of Jet Fuel to the Burmese Military

Date issued: Mar. 24 2023

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TURBOFAC Commentary (248 words)

Notes:

1) Read in conjunction with Business Advisory on Heightened Risks Associated with doing Business in Burma, referenced in this Alert, and the designation notice in which OFAC announces its designation of various Burmese entities involved in the provision of jet fuel to the Burmese military (https://home.treasury.gov/news/press-releases/jy1364). Following Notice of Fraudulent Communications Requesting Payments Involving OFAC, this is the second similarly styled "OFAC Alert". Here, the alert serves a purpose usually served by FAQs, i.e. to warn non-U.S. persons that a class of transactions having no U.S. nexus will be subject to designation actions. Where OFAC intends on sanctioning non-U.S. persons for international trade transactions using “derivative designation” criteria such as the material assistance provision, it is not uncommon for OFAC to provide a warning of this sort.

2) On August 23, 2023, OFAC...