Myanmar sanctions: 12 people, 3 companies added

Summary#

These final rules, the Regulations Amending the Special Economic Measures (Burma) Regulations (SOR/2022-263), add people and companies to Canada’s Burma sanctions list. The amendments took effect when they were registered on December 7, 2022 and were published in the Canada Gazette on December 21, 2022.

What it does#

• Adds three companies to the list of sanctioned entities:

  • Dynasty International Company Limited
  • International Gateways Group
  • Asia Sun Group

• Adds twelve individuals to the list of sanctioned persons:

  • Zaw Min Tun
  • Maung Maung Ohn (also known as Mg Mg Ohn)
  • Tun Tun Naung
  • Khin Maung Yi
  • Myo Myint Oo
  • Thaung Han
  • Win Shein
  • Ko Ko Lwin
  • Aung Soe
  • Zin Min Htet
  • Hlaing Moe Myint
  • Myo Thitsar

• Places these named people and companies on the Schedule to the Special Economic Measures (Burma) Regulations, which is Canada’s legal sanctions list for Myanmar/Burma.

• Reinforces that Canada may freeze assets and prohibit most dealings with listed people and entities. Enforcement is carried out by the Royal Canadian Mounted Police and the Canada Border Services Agency. Criminal penalties include fines up to $25,000 or imprisonment up to one year on summary conviction, and up to five years on indictment.

• The rules include exemptions and a permitting process (for example for humanitarian work) managed by the Minister of Foreign Affairs.

Who's affected#

• The 12 named individuals and 3 named companies — they are now subject to Canada’s sanctions measures.
• Canadian banks and financial institutions — required to screen for and block dealings with listed parties.
• Canadian businesses and people who do, or might do, business with the listed persons or companies — they will face prohibitions unless they obtain a permit or fit an exemption.
• The wider public in Canada is indirectly affected by these enforcement and compliance measures. It is unclear how many Canadian businesses had existing ties to the newly listed names; the government says that is likely to be limited.

Why it matters#

• These amendments are meant to put pressure on Myanmar’s military regime by cutting off people and companies that Canada says help the regime obtain arms, spread disinformation, or otherwise support abuses.
• In practice, the listing can freeze Canadian assets and block transactions tied to the listed names. That raises the legal and compliance risk for banks and companies that might unknowingly interact with them.
• The government included exemptions and a permitting route so that legitimate humanitarian assistance and other narrow activities can continue despite the sanctions.
• This action aligns Canada with similar steps taken by other countries to respond to the violence and human rights concerns in Myanmar.