Canada, in coordination with the United Kingdom and the United States, imposed additional sanctions targeting military entities responsible for supporting Myanmar’s armed forces, including by securing arms and military equipment and providing technical assistance.

Canadian Minister of Foreign Affairs, The Honourable Mélanie Joly, announced on International Human Rights Day that additional sanctions had been imposed against four entities under the Special Economic Measures (Burma) Regulations (“Regulations”). She stated that the sanctions come in response to the “Myanmar military’s ongoing repression of the people of Myanmar and the escalating violence, eroding human rights situation and worsening humanitarian crisis in the country, as well as the regime’s refusal to take concrete action to restore democracy.”

The specific prohibitions are set out in the Regulations. The following individuals have been added to the schedule of these regulations:

• Dr. Thida Oo, Union Minister for Legal Affairs and Attorney-General of the Union
• Htun Htun Oo, Chief Justice of Myanmar (also spelled Tun Tun Oo)
• U Tin Oo, Chairman of the Anti-Corruption Commission of Myanmar

Previously, on December 10, 2021, four (4) further entities were added to the Schedule in the Regulations, targeting key Myanmar military and defence-related entities. The entities subject to the sanctions supported and enable the continued abuse of human rights and ongoing insecurity in Myanmar.

The readers would recall that on February 18, 2021, in response to the coup d’état, Canada imposed sanctions against 9 Myanmar military officials, under the Regulations (see Canada Imposes Sanctions on Myanmar Military Officials).

Why does it matter for your organization or your proposed business activity?

To avoid breaching sanctions, companies need to screen new customers or existing customers whose Know Your Customer (KYC) profiles have changed, to check that they are not on a list of prohibited organizations or individuals. Companies also need to keep their sanctions lists up to date and, in the event of an update, check it against their customer database.

The lawyers at Tereposky & DeRose have significant experience in the design and implementation of sanctions-related compliance programs, including policies, procedures, employee training, and internal control mechanisms. They also regularly assist both Canadian and international businesses, financial institutions, and individuals with internal investigations when “red flags” appear and provide advice on compliance in these areas. Where breaches have occurred, they have worked closely with their clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada.