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Follow the proposal to its actual beneficiary

A Myanmar technical-services business proposes remote support for an American operator. The operator suggests paying a regional distributor with an unrelated-looking name. In this fictional example, the new name supplies no answer about ownership, benefit or the activity being paid for.

Identify the contracting company, owners, banks, intermediaries, currency and ultimate recipient, alongside the support, equipment and end users. The Burma regulations address specified blocked-person property interests and dealings; other directives and sanctions programmes may also matter. The actual U.S. connection must be assessed.

Sources: U.S. Treasury, Office of Foreign Assets Control: 31 CFR §§525.201,525.405–525.407,525.411–525.412 and 525.502 U.S. Treasury, Office of Foreign Assets Control: Legal framework; directives; general licence archive; recent actions

An unlisted name can still lead to a blocked entity

OFAC says an entity can be blocked when one or more blocked persons own 50% or more of it in aggregate, directly or indirectly. That is why a name search alone cannot settle the question: ownership through other companies matters too. Control, designation and directive issues require separate attention.

A previous successful transfer is not permission for this one. If ownership or authorisation remains unresolved, resolve it or pause the proposal rather than route money around an alert. Any general or specific licence must cover the actual activity and conditions; an expired wind-down licence is not current permission.

Sources: U.S. Treasury, Office of Foreign Assets Control: Question, explanation and five ownership examples U.S. Treasury, Office of Foreign Assets Control: 31 CFR §§525.201,525.405–525.407,525.411–525.412 and 525.502 U.S. Treasury, Office of Foreign Assets Control: Legal framework; directives; general licence archive; recent actions

A bank’s answer and the legal answer may differ

A bank can refuse under its own risk policy. That refusal does not establish a universal legal ban, just as bank acceptance does not establish legal permission. Obtain a transaction-specific sanctions assessment before committing to the contract, support or payment.

Sources: U.S. Treasury, Office of Foreign Assets Control: Question, explanation and five ownership examples U.S. Treasury, Office of Foreign Assets Control: 31 CFR §§525.201,525.405–525.407,525.411–525.412 and 525.502

Scope

  • No person has been screened or declared blocked here. Other sanctions, export controls, Myanmar foreign-exchange/tax rules and U.S. operating or work permissions are not fully researched. A resolved sanctions question alone does not establish commercial feasibility.

Next step

Resolve the actual ownership, beneficiaries, activities and authorisation before committing to the intermediary payment.

Sources & review notes

The source records distinguish access dates from substantive review dates. Updating an explanation does not itself recheck the law.

31 CFR Part 525: Burma Sanctions Regulations

U.S. Treasury, Office of Foreign Assets Control

Passage, dates and research notes

primary · 31 CFR §§525.201,525.405–525.407,525.411–525.412 and 525.502

All property and interests in property that are in the United States

Accessed: 2026-11-12T21:22:48.428669+00:00 · Meaning reviewed: 2026-11-12 · Next review target: 2026-12-12

Read prohibited-transactions provision and ownership/control distinctions in current eCFR. Designation criteria are not a blanket ban on every person/business from Myanmar. Licences, other programmes, goods/export controls and bank policies remain transaction-specific.

FAQ 401: indirect ownership under OFAC’s 50 Percent Rule

U.S. Treasury, Office of Foreign Assets Control

Passage, dates and research notes

official-guidance · Question, explanation and five ownership examples

50 percent or more in the aggregate by one or more blocked persons

Accessed: 2026-11-12T21:20:40.835579+00:00 · Meaning reviewed: 2026-11-12 · Next review target: 2026-12-12

Read full ownership explanation and examples. This source explains blocking ownership; control below 50%, other directives and designation grounds require separate analysis. No list search or ownership clearance was performed.

Burma-Related Sanctions programme

U.S. Treasury, Office of Foreign Assets Control

Passage, dates and research notes

official-guidance · Legal framework; directives; general licence archive; recent actions

Directive 1

Accessed: 2026-11-12T21:20:40.609726+00:00 · Meaning reviewed: 2026-11-12 · Next review target: 2026-12-12

Programme page read through recent actions dated 9 October 2026. Contains multiple authorities and specific MOGE financial-services directive. No expired general licence is treated as present authorisation; no transaction-specific screening result is asserted.

Detailed rule records (1)
Myanmar-linked transactions require actor, ownership and activity analysis Depends on the facts

31 CFR §525.201 blocks the specified property/interests of designated persons within U.S. jurisdiction or U.S.-person possession/control and prohibits stated dealings. OFAC’s 50 Percent Rule can block entities through aggregate direct/indirect ownership. Analyse parties, banks, ownership, goods/services and authorisations; nationality alone is not the test.

When to check: Entering U.S.-linked contracts or payment flows involving Myanmar-linked parties. Source review: 2026-11-12.

31 CFR Part 525: Burma Sanctions Regulations FAQ 401: indirect ownership under OFAC’s 50 Percent Rule Burma-Related Sanctions programme
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