On January 31, 2023, Canada announced additional sanctions under the Special Economic Measures (Burma) Regulations (the “Burma Regulations”) against six individuals in response to “the ongoing repression of the people of Myanmar by the military” as well as a dealings prohibition on aviation fuel to the Myanmar regime. The newly listed individuals are “senior figures in the Myanmar military responsible for such international humanitarian and human rights law violations”. The dealings prohibition targets the export, sale, supply, or shipment of aviation fuel to the Myanmar military regime.

These new sanctions were taken in coordination with Canada’s international partners, including the United Kingdom and the United States, in response to the “increased use of aerial attacks against civilians” in Myanmar as well as “deeply concerning reports of serious violations of international human rights law by the military regime”. This is the eighth round of sanctions imposed by Canada in response to the February 2021 military coup. To date, Canada has listed 95 individuals and 63 entities under the Burma Regulations.

We have significant experience in the design and implementation of sanctions-related compliance programs and internal investigations. Where breaches are identified, we work closely with clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada. We also regularly assist clients with the application for delisting process as well as applications for exemption permits.