In December, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a six-month general license authorizing certain trade-related transactions supporting exports to Myanmar (Burma) otherwise prohibited by sanctions.

General License 20 allows companies to conduct most transactions involving blocked parties when those prohibited parties are incident and not directly involved to the export of goods, technology, or non-financial services to or from Burma.

The license is effective until June 7, 2016, but may be extended.

Sanctions against Myanmar were first instituted in 1997 in response to human rights violations by the country’s military junta. November 2010 elections led to a peaceful transition from military rule to a quasi-civilian government and to political and economic reforms. In 2012, the U.S. began easing some financial and investment sanctions on Myanmar in response to these reforms.

Since 2012, the U.S. has waived virtually all of its economic sanctions on Myanmar, other than transactions with persons and entities on the Specially Designated Nationals (SDN) List.

Despite the removal of most sanctions, trade with Myanmar has remained complicated. For example, most import and export trade moves through an Asia World terminal in the port of Rangoon. Asia World is owned by Steven Law, who has been on the SDN List since 2008.

Banks, exporters, and financial institutions have refrained from transactions involving Burma where SDNs were involved, even if these parties were incidental to the transaction.

The OFAC General License 20 comes in response those concerns. General License 20 does not authorize any transactions to, from or on behalf of an SDN, or any other person whose property or interests in property are blocked.