OFAC Myanmar Sanctions Screening

Screening under the targeted sanctions on Myanmar's military regime, military-owned enterprises, and officials tied to human rights abuses.

TL;DR

TL;DR: Myanmar sanctions target the military regime, its owned enterprises, and officials involved in abuses, rather than the whole country. Screening catches counterparties linked to those listed parties.

What the program targets

Myanmar sanctions are targeted, not comprehensive: they name the military leadership, military-owned enterprises, and officials connected to human rights abuses. Because ownership links matter, screening must look beyond the counterparty's own name to whether it is owned or controlled by a listed party, consistent with the 50 Percent Rule.

Why it matters for agent payments

A counterparty that seems unrelated to the regime can still be blocked if it is owned by a listed enterprise. An agent paying across borders needs a screening call that checks the name, the wallet, and the ownership chain against current SDN data, refreshed hourly. The control is to BLOCK before funds move, because once a payment settles into a listed party's hands, the violation has already occurred.

What to check

• Counterparty against SDN entries
• Ownership links to listed enterprises
• Destination wallets

Ownership links in practice

Ownership links are where Myanmar screening gets hard. A listed enterprise may own a network of subsidiaries whose names share nothing with the parent, and the 50 Percent Rule blocks any entity a listed party controls by majority ownership. Screening must therefore resolve ownership, not just match names, and an agent should treat a positive ownership link the same way it treats a direct name match.