Myanmar sanctions: four individuals, two entities

Summary#

These are final amendments to the Special Economic Measures (Burma) Regulations, registered March 24, 2022 and published April 13, 2022. The changes add 4 individuals and 2 entities to Canada’s Burma sanctions list and update the names of several Myanmar-linked companies already listed.

What it does#

• Updates the sanctions list under the Special Economic Measures (Burma) Regulations by replacing or updating several company listings (Part 1), including:
  • Burma Ar (Power) Construction Services (also known as Myanmar Ar (Power) Construction Services)
  • Burma Brewery Ltd. (also known as Myanmar Brewery Ltd.)
  • Burma Daewoo International (also known as Myanmar Daewoo International)
  • Burma Imperial Jade Co. Ltd. (also known as Myanmar Imperial Jade Co. Ltd.)
  • Burma Nouveau Steel Co. Ltd. (also known as Myanmar Nouveau Steel Co. Ltd.)
  • Burma Posco Steel Co. Ltd. (also known as Myanmar Posco Steel Co. Ltd.)
  • Burma Rubber Wood Co. Ltd. (also known as Myanmar Rubber Wood Co. Ltd.)
  • Burma Ruby Enterprise (also known as Myanmar Ruby Enterprise)
  • Burma Segal International Ltd. (also known as Myanmar Segal International Ltd.)
• Replaces item 42 with Union of Burma Economic Holding Ltd. (also listed as Union of Myanmar Economic Holding Ltd. and Myanma Economic Holdings Ltd. (MEHL)).
• Adds these two entities to Part 1 of the schedule:
  • Myanmar Chemical & Machinery Company Limited
  • Yatanarpon Aviation Support Company Limited
• Adds these 4 individuals to Part 2 of the schedule:
  • Aung Hlaing Oo
  • Sit Taing Aung
  • Aung Moe Myint
  • Htun Aung
• Restates core prohibitions already in the regulations: people and companies in Canada — and Canadians abroad — must not deal in property of, or provide funds, goods or services to, listed persons or people acting for them.
• Confirms the amendments apply from their registration date (they came into force on registration).
• Notes penalties for wilful breaches: on summary conviction a fine of up to $25,000 or imprisonment for up to 1 year, or both; on indictment, imprisonment for up to 5 years.

Who's affected#

• The named Myanmar companies and the four named individuals — they are newly subject to Canadian sanctions.
• Canadian banks and financial institutions and other businesses that screen clients and transactions. They must update compliance systems to block prohibited dealings.
• Canadian businesses that might have commercial links to the newly listed entities. Government guidance says such links are unlikely, so impacts should be limited.
• Global Affairs Canada, the Royal Canadian Mounted Police, and the Canada Border Services Agency, which handle implementation, enforcement and enquiries.
• Humanitarian organizations and ordinary civilians are not the intended targets; the regulations include exemptions for humanitarian assistance and permit processes for specific cases.

Why it matters#

• The amendments further restrict the ability of the Myanmar military and its supporters to acquire funds, goods or services from Canada. In practice, that can make it harder for listed entities and people to buy arms, equipment or financial services.
• They are part of Canada’s effort to pressure the Myanmar military over ongoing violence and human rights abuses. The changes align Canada with similar measures by allies.
• For most Canadians the effect will be invisible. Banks and businesses may face small compliance costs. For the named persons and companies, the measures mean loss of access to Canadian financial and commercial services.