On February 11, 2021 President Biden signed Executive Order (“EO”) 14014, Blocking Property with Respect to the Situation in Burma, in response to the recent military coup in Burma. The same day it issued the EO, the U.S. Treasury Department designated thirteen new individuals and entities under the EO and added them to the Office of Foreign Assets Control’s (“OFAC”) list of Specially Designated Nationals (“SDN list”), and designated two more individuals on February 22, 2021. In a separate but coordinated move, the U.S. Commerce Department put in place new export controls against Burma while contemplating further action. The sanctions and export controls are limited in scope and target the Burmese military and actors deemed responsible for the coup.

The EU, which is Burma’s third largest trading partner, has condemned the violence but has been slower to impose sanctions. At the time of writing, no new EU sanctions have been imposed, and those expected are likely to be limited to visa-bans and asset-freezes on the new junta rather than any material trade controls. This is a step both Canada and the UK (whose sanctions policy is no longer driven by Brussels) have already taken unilaterally. 

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