New Burmese Sanctions Include Sky Aviator Company

The U.S. Treasury Department’s Office of Foreign Asset Control (OFAC) is issuing new sanctions against Burmese people and entities, including a business known as Sky Aviator Company.

The new sanctions are scheduled to be published tomorrow, but the sanction orders were effective as of November 8th, 2022.

OFAC sanctions typically prohibit all U.S. persons from engaging in transactions with the blocked parties. If you have a potential transaction with a blocked person or entity (blocked under OFAC sanctions), then you typically need to obtain an OFAC license (or identify an applicable OFAC general license) before you may complete the transaction.

As always, we recommend carefully performing export due diligence on every export transaction. The sanctions lists change almost every day, and many aviation companies are subject to U.S. sanctions. If you are not sure how to perform this due diligence, then we strongly recommend watching our export videos through ASA’s Webinar Series. These videos are free to ASA members and available at a nominal charge to non-members. The on-demand ASA export webinars include:

• Export Training
• Export Compliance – A Step-By-Step Approach (Part One: OFAC)
• Export Compliance – A Step-By-Step Approach (Part Two: BIS)
• Export Compliance – Licensing and Exceptions: Jason’s Favorite Licensing Exceptions (Part Three)
• Exporting Defense Material and Complying with the ITAR (Part Four)
• Exporting Successfully in a Challenging Global Environment (by Elena Mendez, Regional Director, The Export-Import Bank of the United States)