Clifford Chance

Myanmar Sanctions: Unlike Anything You Know About

27 February 2013

Rudyard Kipling’s description of the land of Burma in 1898 aptly describes the landscape of US sanctions on the country 115 years later. Those sanctions, imposed since 1988, have been lifted, suspended, and waived over the last year in a systematic effort to reward the country for its political reforms. However, the sanctions were not revoked or removed, significant conditions and exceptions were imposed, the number of Burmese individuals and entities included on the list of Specially Designated Nationals (SDN) has been expanded, and the country remains the fifth most corrupt country in the world. Accordingly, while the easing of restrictions creates new opportunities, U.S. persons must approach Myanmar with care, understanding that the sanctions and risks that remain are unlike any other that you know about. But, so too may be the rewards.

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