On October 7, 2016, President Obama signed a much anticipated executive order formally terminating U.S. sanctions against Burma. While the intent to lift sanctions had been announced by the president on September 14, during an Oval Office meeting with Burmese leader Aung San Suu Kyi, the termination did not become effective until the executive order was signed.

In addition to terminating the national emergency declared by President Clinton in 1997, the new executive order revokes several related orders and waives the financial and blocking provisions in the Tom Lantos Block Burmese JADE Act of 2008. As a result, the U.S. sanctions on Burma administered by OFAC are no longer in effect. In short, this means:

• All individuals and entities blocked pursuant to the Burmese Sanctions Regulations have been removed from OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List.
• All property and interests in property blocked pursuant to the Burmese sanctions are unblocked.
• The ban on the importation into the United States of Burmese-origin jadeite and rubies, and any jewelry containing them, has been revoked.
• All OFAC-administered restrictions under the Burma sanctions program regarding banking or financial transactions with Burma are no longer in effect.
• Compliance with the State Department’s Responsible Investment Reporting Requirements is no longer required by OFAC regulations and is now voluntary.

We would note that many Burmese individuals and entities will likely remain on the SDN list pursuant to other sanctions programs, such as those relating to counter-narcotics, counter terrorism, etc. In addition, corruption within the region is still troublesome. Accordingly, persons interested in engaging in transactions involving Burma should continue to exercise care.