On January 26, 2022, the Department of Treasury announced the release of a business advisory on the heightened risks associated with doing business in Burma, which was published in cooperation with the Departments of State, Commerce, Homeland Security, Labor, and the Office of the US Trade Representative. The advisory was issued to address the overthrow of Burma’s democratically-elected, civilian government that occurred on February 1, 2021, approximately one year before.
According to the advisory, the entities and sectors of greatest concern and which are primarily responsible for providing economic resources to Burma’s military regime are state-owned enterprises, the gems and precious metals sectors, real-estate and construction projects, and arms/military equipment and related activity. The advisory warns that businesses and individuals that transact with entities in Burma and fail to conduct appropriate due diligence are most susceptible to being involved with operations or supply chains tied to the military regime and have an increased risk of violating US anti-money laundering and sanctions laws. The advisory also warns of significant anti-money laundering risks related to Burma’s inability to adequately implement its anti-money laundering (AML) and counter financing of terrorism (CFT) legal frameworks and reveals that a number of goods imported into the US from Burma have ties to labor abuses including child labor and forced labor.