Introduction
1. The Myanmar (Sanctions) Regulations 2021 (the “UK Regulations”) were made under the Sanctions and Anti-Money Laundering Act 2018 and provide for the imposition of financial sanctions, namely the freezing of funds and economic resources of persons involved in undermining democracy, the rule of law or good governance in Myanmar; the repression of the civilian population in Myanmar; the commission of, or the obstruction of an independent investigation into, a serious human rights violation or abuse in Myanmar; the commission of a violation of international humanitarian law in Myanmar; the obstruction of a humanitarian assistance activity in Myanmar; any other action, policy or activity which threatens the peace, stability or security of Myanmar.
2. On 31 October 2023 the Foreign, Commonwealth and Development Office updated the UK Sanctions List to reflect changes to those persons designated under the UK Regulations. A link to the UK Sanctions List can be found below.
3. The Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (the “Order”), made under the Sanctions and Asset-Freezing (Jersey) Law 2019 (“SAFL”), links to the UK Regulations.
4. Any changes to asset-freeze designations made under the UK Regulations are effective immediately by virtue of the ambulatory provisions in Jersey’s sanctions legislation.
5. An asset freeze now applies to the individuals and entity listed in the Annex to this Notice under Part 3 of SAFL.
Notice summary
6. Find full details in the Annex to this notice.
7. The following designations have been made and are now subject to an asset freeze:
• HTOO HTET TAY ZA (UK Consolidated Group ID: 16188)
• KYAW MIN OO (UK Consolidated Group ID: 16191)
• MYO THITSAR (UK Consolidated Group ID: 16190)
• PYE PHYO TAY ZA (UK Consolidated Group ID: 16189)
• SIT TAING AUNG (UK Consolidated Group ID: 16186)
• INTERNATIONAL GROUP OF ENTREPRENEUR SERVICES COMPANY LIMITED (UK Consolidated Group ID: 16192)
What you must do
8. You must:
• immediately check whether you maintain any accounts or hold any funds or economic resources for the persons set out in the Annex to this Notice.
• freeze such accounts, and other funds or economic resources without prior notice and without delay.
• refrain from dealing with the funds or assets or making them available (directly or indirectly) to such persons unless licensed by the Minister for External Relations (“MER”).
• report any findings to MER, together with any additional information that would facilitate compliance with SAFL.
• provide any information concerning the frozen assets of designated persons that MER may request. Information reported to MER may be passed on to other regulatory authorities or law enforcement.
9. Failure to comply with sanctions legislation or to seek to circumvent its provisions is a criminal offence.
Further Information
10. Find guidance on unfreezing assets for delisted persons or entities.
11. Find more information on sanctions at gov.je or sanctions on Jersey Financial Services Commission (JFSC).
12. Jersey guidance on the Myanmar sanctions regime is available on sanctions by country and category on JFSC.
13. A copy of the UK Regulations can be obtained from legislation.gov.uk. Other relevant information about this regime can be found on financial sanctions targets by regime on GOV.UK.
14. The UK Sanctions List on GOV.UK
15. The UK Office of Financial Sanctions Implementation Consolidated List on GOV.UK
Enquiries
16. Non-media enquiries, sanctions compliance reporting, and licence applications should be emailed to the Financial Sanctions Implementation Unit at sanctions@gov.je.
Annex
17. Annex to Financial Sanctions Notice Myanmar 31 October 2023