Expanded Myanmar Sanctions

Summary#

The federal government has finalized the Regulations Amending the Special Economic Measures (Burma) Regulations: SOR/2025-82, renaming them the Special Economic Measures (Myanmar) Regulations and widening who can be sanctioned. The changes came into force when they were registered on March 6, 2025 and were published in the Canada Gazette on March 26, 2025.

What it does#

• Renames the rules from "Burma" to Myanmar and updates language to match current usage.
• Expands who can be listed as a "listed person" to include people and entities outside Myanmar and people who are not Myanmar nationals. This lets Canada target third-country actors who help the regime.
• Clarifies that the rules block dealing in property that is owned, held or controlled, directly or indirectly, by a listed person.
• Adds new prohibitions, including broad limits on:
  • dealing with the property of listed persons;
  • exporting or supplying arms and aviation fuel to Myanmar;
  • providing technical data or services related to military activities; and
  • providing insurance or reinsurance for ships transporting aviation fuel to Myanmar.
• Creates specific exemptions so certain payments and activities can continue, including:
  • pensions, benefits and disability payments;
  • loan repayments and enforcement for loans made before listing;
  • legal services needed for listed persons to challenge their listing; and
  • limited transactions for diplomatic missions and certain international organizations.
• Requires banks and other financial institutions and certain businesses to check if they control property of listed persons and to report it without delay to the Commissioner of the Royal Canadian Mounted Police or the Director of the Canadian Security Intelligence Service.
• Adds 16 new entries to the sanctions list: three entities — the Ministry of Defence of Myanmar, the Armed Forces of Myanmar, and the 33rd Light Infantry Division of the Burmese Army — and 13 individuals (senior military figures named in the schedule).
• Makes listed individuals inadmissible to Canada under the Immigration and Refugee Protection Act.
• Reinforces enforcement powers and penalties: on summary conviction up to $25,000 or one year in jail (or both), or on indictment up to five years in jail.

Who's affected#

• People and companies in Canada, and Canadians abroad, who would otherwise do business with the newly listed people or entities. They are prohibited from dealing in listed persons’ property or providing services to them.
• Canadian banks and financial institutions and other regulated financial entities, which must screen for and report control of listed persons’ assets.
• The three named entities (the Ministry of Defence of Myanmar, the Armed Forces of Myanmar, and the 33rd Light Infantry Division of the Burmese Army) and the 13 individuals added to the schedule — they face asset freezes and transaction bans.
• Global Affairs Canada, which manages the sanctions list and outreach, and enforcement agencies such as the Royal Canadian Mounted Police and the Canada Border Services Agency, which have roles in enforcing the rules.
• Unclear or indirect effects could touch Canadian businesses with supply-chain links to Myanmar or to third parties that support the military regime.

Why it matters#

• The changes let Canada more easily block money, goods, services and insurance that support Myanmar’s military regime. That makes it harder for the regime to buy arms, fuel and other resources used in attacks on civilians.
• By allowing sanctions on people outside Myanmar who help the regime, Canada can coordinate more closely with allies and target foreign enablers of violence and corruption.
• The exemptions aim to reduce harm to ordinary people and to allow humanitarian work, diplomatic functions and certain legal and pension payments to continue.
• For Canadians, the practical impacts are mostly on businesses and financial institutions that must screen and report potential links to listed persons. For the listed individuals and entities, the measures can freeze assets and restrict travel to Canada.