Myanmar Newsflash | March 2024 - This publication is was last updated on 3 August 2024

Myanmar sanctions
As many countries and international organisations have condemned the political events following the
declaration of a state of emergency on 1 February 2021, some foreign governments took action and imposed
sanctions. The United States of America (“US”) have been on the forefront and were subsequently followed
by the United Kingdom (“UK”), the European Union (“EU”) and other countries. Each of these countries
already had sanctions in place against certain Myanmar persons and organizations, but expanded them in
response to the escalation since 2021.
This publication provides an overview of the prohibitions and restrictions resulting from the latest sanctions,
guidance on key considerations for foreign investors, as well as a list of entities and individuals sanctioned
by the European Union, the United States of America and the United Kingdom.

In response to the political developments that took

I. Overview place since 1 February 2021, the EU imposed a total
1. EU Sanctions of eight (8) rounds of sanctions.
■ In 2021: 22 March, 19 April and 21 June;
Following the 2012 elections, with Council Regulation
(EU) No 401/2013 (“Regulation No 401/2013”), the ■ In 2022: 22 February and 8 November; and
EU had suspended the vast majority of its previous
■ In 2023: 20 February, 20 June and
sanctions and import, export and investment
11 December.
restrictions. Merely the embargo on arms and
equipment which might be used for internal repression Besides the Council Regulation No 401/2013, as
as well as the provision of technical services, financial amended, certain Myanmar individuals / entities are
services and financial assistance to military related sanctioned in accordance with EU Global Human
activities remained in place. Rights Sanctions Regime, as stipulated in Council
Decision (CFSP) 2020/1999 of 7 December 2020
Following the humanitarian crisis in Rakhine in 2017,
concerning restrictive measures against serious
the EU amended the Regulation No 401/2013 by
human rights violations and abuses.
Council Regulation (EU) No 2018/647, and expanded
its restrictive measures by adding a prohibition on The measures imposed on designated individuals
export of dual-use goods to military and border guard comprise movement restrictions (travel bans) and
police end users, restrictions on the export of financial sanctions (asset freeze). The asset freeze
equipment for monitoring communications that might blocks all funds (e.g., cash, shares, bonds, interests,
be used for internal repression, as well as military deposits, etc.) and other economic resources (e.g.,
training and military cooperation. The EU further non-financial assets such as immovable property or
implemented restrictive measures targeting vehicles, irrespectively of their location) of a
14 individuals with a military background. designated person, as well as entities which are,
directly or indirectly, “owned” or “controlled” by a
designated person.

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Myanmar Sanctions 3 August 2024

Accordingly, it is prohibited to make such funds or US persons are generally prohibited from making or
economic resources available to designated persons receiving any contribution or provisions of funds,
or entities owned or controlled by them. goods or services by, to, for the benefit of / from a
designated person.
The EU sanctions are binding for all citizens of the EU
and entities incorporated or constituted under the laws It is noteworthy that the prohibition to engage in
of a member state, regardless of whether they are transactions may also extend to non-US persons,
doing business within or outside of the EU. They also where such persons have a US nexus. US nexus
apply to any business carried out in whole or in part means a sufficient connection or link to the USA or
within EU territory. persons within the USA. This may include the
sourcing of goods or services from the USA or other
2. US Sanctions involvement of persons within the USA for export to or
other transaction with a designated person. A US
Following the democratic elections in 2015, the USA nexus could also exist if funds pass through the US
lifted most trade, export and investment restrictions on financial system or a US financial institution, which is
Myanmar. The main restriction maintained after the usually the case with US Dollar denominated
elections was the embargo on arms trade. transactions. Unlike past US sanctions, the current
In response to the Rakhine crisis, the USA designated measures do however not restrict investments or the
Myanmar as a country whose government has armed export of financial services to the Myanmar
forces or government supported armed groups that government per se.
recruit and use child soldiers. Pursuant to the Child On 18 February 2021, the U.S. Commerce’s Bureau
Soldier Prevention Act, certain security assistance of Industry and Security (“BIS”) separately imposed
and commercial licenses of military equipment for restrictions on exports of sensitive items to Myanmar’s
Myanmar were prohibited. On 18 December 2019, the Ministry of Defence, Ministry of Home Affairs, the
USA further designated Myanmar as a country of Myanmar armed forces and the Myanmar security
particular concern pursuant to the International services. As a result, the BIS applies a presumption of
Religious Freedom Act, leading to a ban on the denial for items requiring a license for export to these
provision of defence equipment and services, and authorities or agencies. In addition, BIS revoked
imposed sanctions targeting certain individuals, certain license exceptions in whole or in part, which
groups and entities associated with the Myanmar were previously available to Myanmar as a result of its
military under to the Global Magnitsky Act. country group placement under the Export
Following the violent developments since Administration Regulations (“EAR”) and previously
1 February 2021, Executive Order (“EO”) 14014 was issued licenses to the above authorities and agencies
issued, authorizing the Office of Foreign Assets that have not been fully utilized.
Control (“OFAC”) to impose new sanctions against On 8 March 2021, the BIS expanded its restrictions on
individuals, groups and entities designated on the exports and re-exports of sensitive items subject to
Specially Designated Nationals and Blocked Persons the EAR, downgrading Myanmar’s country group to a
List (“SDN-List”). more restrictive license application review group and
A designation on the SDN-List results in immigration applying a presumption of denial standard. It added
restrictions (travel bans) and financial restrictions Myanmar to the EAR’s category of arms-embargo
(asset freeze). The asset freeze blocks all property countries subject to BIS’ licensing policy for “military
and interest in property of a designated person within end use” and “military end users” as well as its
the USA or in the possession or control of a US person licensing policy for national security-controlled items.
(every individual or entity inside US territory, US
citizens, US permanent resident aliens outside US
territory and entities organized under the laws of the
USA or any jurisdiction within the USA, as well as their
foreign branches).

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Under these policies, BIS reviews all applications for 3. UK Sanctions

items destined for Myanmar involving “military end
use” and “military end users”, using a presumption of The UK imposes sanctions based on the Sanctions
denial standard. Accordingly, the BIS added the and Anti-Money Laundering Act (2018) and its
Ministry of Defence, the Ministry of Home Affairs, subordinate regulations. Based on the regulations, a
Myanmar Economic Corporation Limited and list of sanctioned individuals and entities is prepared.
Myanma Economic Holdings Public Company Both the Global Human Rights Sanctions
Limited, Myanmar Wanbao Mining Copper Company Regulations 2020 and the Myanmar (Sanctions)
Limited, Wanbao Mining Limited, and King Royal Regulations 2021 apply to Myanmar. The latter
Technologies Company Limited to the Entity List, superseded the Burma (Sanctions) (EU Exit)
essentially banning any exports under the EAR to Regulations 2019, under which the UK maintained
these recipients. On 2 March 2023, the BIS further pre-existing EU trade prohibitions. Both the Global
added FISCA Security & Communication Company Human Rights Sanctions Regulations 2020 and the
Limited, the Ministry of Transport and Myanmar (Sanctions) Regulations 2021 provide for
Communications and Naung Yoe Technologies immigration restrictions and certain financial
Company Limited to the Entity List. sanctions.
On 29 March 2021, the USA further suspended the The financial sanctions include asset-freeze and the
2013 Trade and Investment Framework (TIFA), which prohibition to make funds and economic resources
provides a bilateral platform for ongoing dialogue and available. The asset freeze blocks all funds (e.g.,
cooperation on trade and investment issues. The cash, shares, bonds, interests, deposits, etc.) and
Department of State reiterated that the USA will other economic resources (e.g., non-financial assets
“continue to take action to promote accountability from such as immovable property or vehicles) of the
the Myanmar military and support the democratically- designated person and further prohibits making such
elected government”. funds or economic resources available to a
On 17 May 2021 the US designated the State designated person.
Administrative Council (SAC) for being a political Only the Myanmar (Sanctions) Regulations 2021
subdivision, agency, or instrumentality of the provide for trade restrictions. These include an export
Government of Myanmar. However, the designation ban on “restricted goods” and “restricted technology”
does not automatically extent to all the members of to Myanmar and the prohibition to make restricted
the SAC, some of whom have been individually goods and technology otherwise available. The
designated. restricted goods and technology cover military,
Further rounds of sanctions took place, adding internal repression and interception / monitoring
several more individuals and entities to the SDN-List. goods / technologies.

■ In 2021: 2 July and 10 December; The imposed restrictions apply within the territory of
the UK and in relation to the conduct of UK persons
■ In 2022: 31 January, 25 March, 6 October and
outside the UK. The term “UK persons” refers to all
8 November; citizens as well as all entities incorporated or
■ In 2023: 31 January, 24 March, 21 June, constituted under the laws of any part of the UK
23 August and 31 October; and (including foreign branches of UK corporations).

■ In 2024: 1 February.
4. Other countries
Australia, New Zealand, Canada and Switzerland
have each imposed sanctions that may differ from the
above.

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5. FATF Blacklisting ■ Conducting enhanced monitoring of the business

relationship, by increasing the number and timing
Citing Myanmar’s persistent failure to combat money of controls applied, and selecting patterns of
laundering and terrorist financing, the Financial Action transactions that need further examination; and
Task Force (“FATF”) on 21 October 2022 announced
■ Requiring the first payment to be carried out
Myanmar’s addition to its category of “high-risk
jurisdictions subject to a call for action”, commonly through an account in the customer’s name with
known as the “FATF blacklist”. a bank subject to similar customer due diligence
standards.
While the FATF blacklisting does not constitute a
sanction, but merely a non-binding recommendation, Notably, the FATF did not call upon its members to
it urges countries to oblige its financial institutions to take counter-measures against Myanmar (as they did
apply enhanced due diligence for transactions that in the case of Iran and North-Korea).
involve Myanmar entities or citizens. Instead, the FATF highlighted that “when applying
Enhanced due diligence measures mean that enhanced due diligence measures, countries should
financial institutions should examine, as far as ensure that flows of funds for humanitarian
reasonably possible, the background and purpose of assistance, legitimate NPO activities and remittances
all complex, unusual and large transactions and all are not disrupted”.
unusual patterns of transactions, which have no This is to be understood as a general encouragement
apparent economic or lawful purpose. to ensure that remittances to and from Myanmar
Where the risk of money laundering or terrorist remain possible. The same holds true for
financing is higher, financial institutions shall conduct humanitarian aid and non-profit activities.
enhanced customer due diligence measures, While many international financial institutions had
consistent with the risks identified. In particular, they already introduced additional customer due diligence
should increase the degree and nature of the measures for Myanmar-related transactions following
monitoring of business relationships to determine the country’s addition to the grey-list of “jurisdictions
whether transactions or activities appear unusual or actively monitored” in February 2020, and particularly
suspicious. following the political events that took place since
Examples of enhanced customer due diligence February 2021, the FAFT blacklisting without doubt
measures that may be applied for higher-risk business had a considerable impact on banking transactions
relationships include: with Myanmar.

■ Obtaining additional information on the customer Not only did numerous international banks terminate
(e.g. occupation, volume of assets, information their correspondence bank relationships with
available through public databases, internet, Myanmar banks and ceased services for Myanmar
etc.), and updating the identification data of the customers; most USD clearing agents also stopped or
customer and beneficial owner more regularly; limited clearing of USD transactions to and from
Myanmar.
■ Obtaining additional information on the nature of
a business relationship; As a consequence, international financial transactions
with Myanmar are increasingly carried out in
■ Obtaining information on the source of funds or alternative currencies (such as Thai Baht and Chinese
source of wealth of the customer; Yuan) through regional correspondence banks,
■ Obtaining information on the reasons for intended e.g., in Thailand or China.
or performed transactions;
■ Obtaining the approval of senior management to
commence or continue the business relationship;

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The EU framework defines ownership by a designated

II. Guidance person as directly or indirectly holding more than 50%
Overseas investors should carefully consider potential of the propriety rights in an entity. Control is defined
implications for their existing and future business by a series of criteria, including the right to appoint a
activities related to Myanmar. majority of the board of directors or supervisory body,
the right to control a majority of shareholders' rights or
1. Scope of application the ability to exercise dominant influence over an
entity.
Restrictions may apply to investors either as a matter
of law, under the particular national sanctions law, or In the UK, an entity is considered owned by a
as a contractual obligation, if the parties have agreed designated person, if he or she directly or indirectly
to comply with specific sanctions. holds more than 50% of the shares and/or voting
rights in the entity, and/or has the right to appoint or
Overseas investors should review such contractual remove a majority of the board of directors of the
provisions carefully, as they may go beyond or entity. It is considered controlled by a designated
differentiate from the restrictions under the applicable person, if such person would be directly or indirectly
sanctions regime. The failure to comply with such able to influence the management of the entity.
contractual obligations may result in an event of
default or even a breach of contract. US laws refer to ownership of 50% or more in the
aggregate of an entity.
In relation to the international sanctions regime,
overseas investors should assess carefully whether Overseas investors should further keep in mind that
they, their portfolio of products and services, or their major conglomerates (e.g. Myanmar Economic
employees and business partners are subject to Corporation Limited (MEC) and Myanma Economic
statutory restrictions. Holdings Public Company Limited (MEHL)) have
investments and subsidiaries across a wide range of
Sanctions may apply beyond nationalities and place industry sectors. The UK sanctions list identifies 40 of
of incorporation (for example, US restrictions also MEHL’s subsidiaries and 64 of MEC’s subsidiaries,
apply to non-US persons with US-nexus) and operating in industries such a consumer products,
employees may be exposed due to nationality or tourism, telecommunications and mining.
place of residence.
Under the aforementioned criteria of ownership and
control, these subsidiaries may be subject to
2. Designated persons
sanctions as well.
Most western countries have added certain
individuals and entities to their national sanctions lists. 3. Trade prohibitions and export
The designated persons are subject to financial and
restrictions
immigration sanctions (please see above).
Most western countries have issued trade prohibitions
Overseas investors should perform rigorous due
and export restrictions on certain military associated
diligence checks of their existing and future Myanmar
goods, technologies and services (including dual use
business partners to ensure that they are not
goods and technologies, goods and technology which
engaging in prohibited transactions. This should
may be used for internal repression, as well as
extend to a careful screening of the ownership
financing or financial assistance related to military
structure of corporate entities. The US prohibition of
activities).
engaging in transactions extends to entities which are
not explicitly designated, but “owned” by a designated Overseas investors should consider the risk in relation
person. Both the EU and UK sanctions extend asset to their product and service portfolio and the sector
freezes and prohibitions on the provision of funds and they are operating in.
economic resources to entities “owned” or “controlled”
by a designated person.

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4. Prohibited transactions 6. Contractual protection

The EU, US and UK use so-called smart financial The international sanctions regime may have direct
sanctions, targeting specific persons, groups and implications on the movement of goods, materials,
entities in Myanmar. These financial sanctions include equipment and capital, and the aforementioned
an obligation to freeze all funds and economic restrictions may result in a delay or cancellation of
resources of the targets. Generally, an asset freeze contractual obligations.
imposes an across-the-board prohibition for the
In relation to contractual relief, overseas investors
person in possession or control of the designated
may be able to rely on contractual “force majeure”
person’s assets on transfers or dealings of any kind
provisions, specific contractual provisions dealing with
with regard to these assets.
the consequences of sanctions, or general regulations
The EU and UK sanctions also extend to a ban on under the applicable law (e.g., the doctrine of
making funds and economic resources available to a frustration). Such provisions may enable the investor
designated person. The broad term “economic to seek relief from performance, an extension of time
resources” comprises any tangible or intangible, or even a termination of the contract.
movable or immovable assets which are not funds but
While force majeure will often be the first option to
may be used to obtain funds, goods or services. The
consider, investors should keep in mind that such
asset freeze measures may also extend to the
clauses may not provide for a “general relief”, but
provision of labour or services to a designated person
require a close case-by-case examination.
(or an entity that is “owned” or “controlled” by a
designated person), if the provision of such services When negotiating contracts related to Myanmar,
may enable the designated person to obtain funds, overseas investors should consider incorporating
goods or services. The circumstances in which relevant warranties and sanction clauses, addressing
investors are allowed to provide labour or services to the impact of (sanction) scenarios and a smooth exit.
designated persons are subject to a strict case-by-
case interpretation. Investors subject to EU/UK 7. Statutory Penalties
sanctions should carefully consider whether and to
Violating sanctions may result in severe fines or
what extent their portfolio of services could enable a
imprisonment as stipulated in the relevant national
designated person to obtain funds, goods or services.
laws.
The US sanctions go further and extend to a broader
For the EU, article 8, section 1 of Council Regulation
prohibition on any transactions or dealings involving a
(EU) No. 401/2013 provides that the member states
designated person (or an entity “owned” by such
shall lay down the rules on penalties applicable to
person), including assets and services of any kind.
infringements of the provisions of Council Regulation
This may also affect the winding up of business
(EU) No. 401/2013. Germany, for example, has
relations with designated persons, which may require
codified this in sections 17 et seq. of the Foreign
express authorisation by the US government.
Trade Act (Außenwirtschaftsgesetz). Section 18 (1)
(c) provides for the possibility of imprisonment of three
5. Risk-based vs. strict liability months to five years for willful violations of a
approach prohibition on asset-freeze as stated by an EU Council
regulation. Section 19 (1) further imposes fines of up
The EU and UK accept a risk-based approach in
to EUR 500,000 for negligent violations.
ensuring compliance with sanctions and allow for a
due diligence defence. Accordingly, EU/UK investors In the USA, §1705 (b) of U.S. Code Title 50 provides
may not be held liable if they had appropriate risk- that civil penalties may be imposed in an amount not
management controls in place, but did not know or exceeding the greater of USD 250,000, or an amount
had no reasonable cause to suspect that their actions that is twice the amount of the transaction that is the
violate sanction laws. basis of the violation with respect to which the penalty
is imposed. Further, § 1705 (c) of U.S. Code Title 50
In contrast, US sanctions apply on a strict liability
stipulates a criminal penalty of a fine of not more than
basis, meaning that investors subject to US sanction
USD 1,000,000 or, if a natural person, imprisonment
obligations may be liable even if they did not know or
for not more than 20 years, or both.
had no reason to suspect that they were in breach.

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In the UK, penalties for offences are stipulated in the Section 2 further clarifies that prohibitions in section 1
Global Human Rights Sanctions Regulations 2020 of this order include (a) “the making of any contribution
and the Myanmar (Sanctions) Regulations 2021. A or provision of funds, goods, or services by, to, or for
summary conviction will usually not exceed 12 months the benefit of any person whose property and interests
imprisonment or a fine (or both). A conviction on in property are blocked pursuant to this order; and (b)
indictment may result in imprisonment not exceeding the receipt of any contribution or provision of funds,
10 years or a fine (or both). The specific penalty goods, or services from any such person”.
depends on various criteria, particularly whether the
In the UK, the State Secretary shall assess whether
offence is made against financial or trade provisions.
an individual / entity is involved in an “action, policy or
activity which threatens the peace, stability or security
8. Risk of being sanctioned of Myanmar” which includes “providing financial
In addition to the risk of punishment for sanctions services, or making available funds or economic
violations, investors operating in or with business resources, that could contribute to such an activity;”
partners from Myanmar should also consider the risk and “profiting financially, or obtaining any other
of being sanctioned themselves. benefit, from such an activity.”

Sanctions may be imposed on anyone found to be in

9. Reputational Risk
violation of the Myanmar sanctions, even if such
person or entity is not subject to the respective Finally, in addition to the legal risks presented in this
sanctions regime. article, international investors should also consider
potential reputational risks resulting from any
The EU may impose sanctions on a case-by-case
transactions with sanctioned individuals or entities.
basis in accordance with EU principles as further set
out in Article 21 of the Treaty of the EU. Guidance is
provided in the “Basic Principles on the Use of
Restrictive Measures (Sanctions)” dated 7 June 2004,
the “Guidelines on the implementation and evaluation
of restrictive measures (Sanctions)” dated 4 May 2018
and the “Best practices for the effective
implementation of restrictive measures” dated 27
June 2022.
The USA may impose sanctions in accordance with
the EO 14014 of the Secretary of the Treasury.
Pursuant to section 1 (a) (vi) of EO 14014, an asset-
freeze shall be imposed on any foreign person
determined to “have materially assisted, sponsored,
or provided financial, material, or technological
support for, or goods or services to or in support of
any person whose property and interests in property
are blocked pursuant to this order”.

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III. List of sanctioned individuals

No. Individual Occupation/ Affiliation EU USA UK Remarks
(103) (122) (42)
1. Aung Aung Lieutenant General Yes Yes Yes Sanctioned by the USA, EU and UK
before Feb 2021
2. Aung Hla Affiliated with Tet Kham Construction Co., Ltd, No Yes No Sanctioned by the USA before Feb 2021
Tet Kham Gems Co., Ltd, Yangon Airways
Co., Ltd
3. Aung Hlaing Oo Managing Director of Myanmar Chemical and Yes Yes Yes
Machinery Co. Ltd
4. Aung Kyaw Min Former Member of SAC Yes No No
(in office until 1 Aug 2023)
5. Aung Kyaw Zaw Lieutenant General Yes Yes Yes Sanctioned by the USA, EU and UK
before Feb 2021
6. Aung Lin Dwe General, Secretary of SAC Yes Yes Yes
(a.k.a. Dwe Aung Lin)
7. Aung Lin Tun Major General Yes No No
8. Aung Lwin Oo Member of the Union Election Commission Yes No No
(a.k.a. U Aung Lwin OO)
9. Aung Mar Myint Wife of General Maung Maung Kyaw No Yes No
10. Aung Min Managing Director of Myanma Oil and Gas No Yes No
Enterprise
11. Aung Moe Myint Director of Dynasty International Company Yes Yes Yes
Limited
12. Aung Moe Myint Member of the Union Election Commission Yes No No
(a.k.a. U Aung Moe Myint)
13. Aung Myo Thu Field Unit Commander of the 33rd Light Yes No Yes Sanctioned by the EU and UK before
Infantry Division Feb 2021
Myanmar Sanctions 3 August 2024

No. Individual Occupation/ Affiliation EU USA UK Remarks

(103) (122) (42)
14. Aung Naing Oo Former Union Minister for Investment and Yes Yes No
Foreign Economic Relations
(in office until Aug 2022)
15. Aung Pyae Sone Son of Min Aung Hlaing No Yes No
16. Aung Saw Win Member of the Union Election Commission Yes No No
(a.k.a. U Aung Saw Win)
17. Aung Soe General Yes Yes No
18. Aung Zaw Aye Lieutenant General Yes No No
19. Aye Nu Sein Member of SAC’s Central Advisory Body Yes Yes No
(Former Member of SAC until 1 Feb 2023)
20. Ba Kyaw Staff Sargeant Yes No Yes Sanctioned by the EU and UK before
Feb 2021
21. Ba Maung Former Member of the Union Election Yes No No
Commission
(in office until 1 Feb 2023)
22. Banyar Aung Moe Member of SAC’s Central Advisory Body Yes Yes No
(Former Member of SAC until 1 Feb 2023)
23. Bran Shaung Member of the Union Election Commission Yes No No
24. Charlie Than Union Minister of Industry Yes Yes No
25. Chaturong Taiyai No Yes No Sanctioned by the USA before Feb 2021
(a.k.a. Cha Ta Fa, a.k.a. Chin (Non-Burmese)
Shun Lu)
26. Cheng Yu Li No Yes No Sanctioned by the USA before Feb 2021
(a.k.a. San Jang Bunthawee, (Non-Burmese)
a.k.a. Ah Li Ko)
27. Cheng Yun No Yes No Sanctioned by the USA before Feb 2021
(Non-Burmese)

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No. Individual Occupation/ Affiliation EU USA UK Remarks

(103) (122) (42)
28. Chin Sung Chang No Yes No Sanctioned by the USA before Feb 2021
(Non-Burmese)
29. Chit Naing Union Minister of the Union Government Yes Yes No
(a.k.a. Sate Pyin Nyar) Office 2
(Former Union Minister of Information until
1 Aug 2023)
30. Chun Ting Ho Affiliated with Hong Pang Group of No Yes No Sanctioned by the USA before Feb 2021
Companies (Non-Burmese)
31. Hein Htet Son of General Maung Maung Kyaw No Yes No
32. Hla Moe Major General Yes No No
33. Hla Swe Pro-regime activist No Yes No
34. Hlaing Bwar Aung Son of Lieutenant General Aung Lin Dwe No Yes No
35. Hlaing Moe Myint Director of Dynasty International Company No Yes No
Limited
36. Hmu Than Member of SAC Yes No No
(a.k.a. Hmuh Thang)
37. Hsueh Lung Wei No Yes No Sanctioned by the USA before Feb 2021
(a.k.a. Aik Hsam Hkim, a.k.a. (Non-Burmese)
Cheewinprapasi Aphichart, a.k.a.
Cheewinprapasri Soonthron,
a.k.a. Chiwinpraphasi Sunthorn)
38. Hsueh Yuan Wei No Yes No Sanctioned by the USA before Feb 2021
(a.k.a. Wei Hsueh Yuan) (Non-Burmese)
39. Htein Win Major General Yes No No
40. Htin Latt Oo Major General Yes No No
41. Htoo Htet Tay Za Son of Tay Za No Yes Yes
42. Htoo Htwe Tay Za Daughter of Tay Za No Yes No

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No. Individual Occupation/ Affiliation EU USA UK Remarks

(103) (122) (42)
43. Htun Aung Commander-in-Chief of Myanmar’s Air Force Yes Yes Yes
(a.k.a. Tun Aung)
44. Hua Chiang Pao No Yes No Sanctioned by the USA before Feb 2021
(a.k.a. Ta Kat) (Non-Burmese)
45. Jeng Phang Naw Htaung Former Member of SAC Yes No No
(in office until 1 Feb 2023)
46. Jonathan Myo Kyaw Thaung CEO of KT Group No Yes No
47. Kai Shou Li No Yes No Sanctioned by the USA before Feb 2021
(Non-Burmese)
48. Kan Zaw Union Minister of Investment and Foreign Yes Yes No
Economic Relations
49. Kaung Htet Son of General Maung Maung Kyaw No Yes No
50. Khaing Moe Myint Daughter of Lieutenant General Moe Myint No Yes No
Tun
51. Khaing Pa Pa Chit Wife of Lieutenant General Moe Myint Tun No Yes No
52. Khet Htein Nan Chief Minister of Kachin State Government No Yes No
53. Khin Hlaing Lieutenant General Yes Yes Yes Sanctioned by the USA, EU and UK
before Feb 2021
54. Khin Maung Oo Member of the Union Election Commission Yes No No
55. Khin Maung Soe Major General Yes Yes Yes Sanctioned by the USA, EU and UK
(a.k.a. Soe Khin Maung) before Feb 2021
56. Khin Maung Swe Member of SAC’s Central Advisory Body Yes Yes No
(Former Member of SAC until 1 Feb 2023)
57. Khin Maung Yi Union Minister of Natural Resources and Yes Yes No
(a.k.a. Khin Maung Yee; a.k.a. U Environmental Conservation
Khin Maung Yi)
58. Khin Phyu Win Businessman associated with the Asia Sun No Yes Yes
Group
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No. Individual Occupation/ Affiliation EU USA UK Remarks

(103) (122) (42)
59. Khin Thiri Thet Mon Daughter of Min Aung Hlaing No Yes No
60. Ko Ko Hlaing Union Minister of International Cooperation No Yes No
61. Ko Ko Lwin Member of the Union Election Commission Yes No No
62. Ko Ko Maung Major General Yes No No
63. Ko Ko Oo Brigadier General No Yes No
64. Kuo Neng Shih No Yes No Sanctioned by the USA before Feb 2021
(a.k.a. Ah San, a.k.a. Shi Kwan (Non-Burmese)
Neink, a.k.a. Shih Kuo Neng)
65. Kwang Hyok Kim Korean Mining Development Trading No Yes No Sanctioned by the USA before Feb 2021
Corporation Representative in Burma (Non-Burmese)
66. Kyaw Chay Corporal in the Border Guard Police Yes No Yes Sanctioned by the EU and UK before
Feb 2021
67. Kyaw Min Oo Director of Sky Aviator Company Limited Yes Yes Yes
68. Kyaw Swar Lin Lieutenant General Yes No No
69. Kyu Kyu Hla Wife of General Min Aung Hlaing No Yes No
70. La Bo Kya No Yes No Sanctioned by the USA before Feb 2021
(Non-Burmese)
71. Li Myint Affiliated with Hong Pang Group No Yes No Sanctioned by the USA before Feb 2021
(Non-Burmese)
72. Mahn Nyein Maung Member of the SAC Yes Yes No
73. Maung Ha Member of SAC’s Central Advisory Body Yes No No
(Former Member of SAC until 1 Feb 2023)
74. Maung Ko Former Chief Minister of the Mandalay Region No Yes No
Government
(in office until 1 Feb 2023)
75. Maung Maung Aye Chief of General Staff for the Burmese Army, Yes Yes No
Navy and Air Force

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Myanmar Sanctions 3 August 2024

No. Individual Occupation/ Affiliation EU USA UK Remarks

(103) (122) (42)
76. Maung Maung Kyaw General Yes Yes Yes
77. Maung Maung Ohn Union Minister of Information Yes No No
(a.k.a. U Maung Maung Ohn)
78. Maung Maung Soe Major General Yes Yes Yes Sanctioned by the USA, EU and UK
before Feb 2021
79. Min Aung Hlaing Commander-in-Chief Yes Yes Yes Sanctioned by the USA, EU and UK
before Feb 2021
80. Min Min Oo Member of the Union Election Commission Yes No No
81. Moe Aung Commander-in-Chief of the Myanmar Navy Yes No No
82. Moe Htet Htet Tun Daughter of Lieutenant General Moe Myint No Yes No
Tun
83. Moe Myint Tun Lieutenant General Yes Yes Yes
84. Mya Tun Oo General, Deputy Prime Minister of Myanmar, Yes Yes Yes
Union Minister of Transport and
Telecommunications, Member of SAC
85. Myint Kyaing Union Minister of Immigration, and Population Yes Yes No
86. Myint Oo Member of the Union Election Commission Yes No No
87. Myint Swe General Yes Yes No
88. Myint Thein Member of the Union Election Commission Yes No No
89. Myo Myint Aung Lieutenant Colonel Yes No No
90. Myo Myint Oo Former Union Minister of Energy Yes Yes No
(in office until 1 August 2023)
91. Myo Swe Win Chief Minister of the Bago Region No Yes No
Government
92. Myo Thitsar Director of Dynasty International Company No Yes Yes
Limited

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Myanmar Sanctions 3 August 2024

No. Individual Occupation/ Affiliation EU USA UK Remarks

(103) (122) (42)
93. Naing Htut Aung Managing Director of International Gateways Yes Yes No
Group of Company Limited
94. Naing Win Thet Affiliated with Tet Kham Construction No Yes No
Company Limited
95. Ni Lin Aung Brigadier General Yes No No
96. Nilar Wife of Lieutenant General Ye Win Oo No Yes No
97. Nu Mya Zan Member of the Union Election Commission Yes No No
98. Nyi Nyi Swe Major General Yes No Yes Sanctioned by the EU and UK before
Feb 2021
99. Nyo Saw Lieutenant General, Member of SAC Yes No No
100. Nyunt Win Swe Major General Yes No No
101. Ohn Mar Myint Wife of Lieutenant General Aung Lin Dwe No Yes No
102. Oo Oo Khine Affiliated with Tet Kham Group and Yangon No Yes No
Airways Co., Ltd
103. Phone Myat Lieutenant General Yes No No
104. Phyo Arkar Aung Son of Lieutenant General Aung Lin Dwe No Yes No
105. Porel Aung Thein Member of SAC Yes No No
106. Pwint San Former Minister of Commerce Yes Yes No
(in office until 19 Aug 2022)
107. Pyae Phyo Tay Za Son of Tay Za No Yes Yes
108. Sai Lone Saing Member of SAC’s Central Advisory Body Yes Yes No
(a.k.a. Sai Long Hseng) (Former Member of SAC until 1 Feb 2023)
109. Saw Ba Hline Former Member of the Union Election Yes No No
Commission
(in office until 1 Feb 2023)
110. Saw Chit Thu Leader of the Border Guard Force (BGF) No No Yes GB Global Human Rights Sanctions
(a.k.a. Thu Saw Chit) Colonel Regulations 2020

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Myanmar Sanctions 3 August 2024

No. Individual Occupation/ Affiliation EU USA UK Remarks

(103) (122) (42)
111. Saw Daniel Member of SAC’s Central Advisory Body Yes Yes No
(Former Member of SAC until 1 Feb 2023)
112. Saw Min Min Oo Managing Director of the Chit Lin Myaing Co No No Yes GB Global Human Rights Sanctions
(Oo Saw Min Min) Colonel Regulations 2020
113. Saw Myint Oo Chief Minister of Kayin State Government No Yes No
114. Saw Tun Aung Myint Former Minister of Ethnic Affairs No Yes No
(in office until 1 Feb 2023)
115. Sein Win General Yes Yes No
116. Shao Kuei Tuan No Yes No Sanctioned by the USA before Feb 2021
(Non-Burmese)
117. Shwe Kyein Member of SAC Yes No No
(a.k.a. U Shwe Kyein)
118. Shwe Ye Phu Aung Daughter of Lieutenant General Aung Lin Dwe No Yes No
119. Sit Taing Aung Managing Director of Yatanarpon Aviation Yes Yes Yes
(a.k.a. Sit / Sitt Taing Asung) Support cooperating with Mottama Holdings
120. Soe Htut Former Minister of the Union Government Yes Yes Yes Currently Imprisoned by the Military
Office 1 Court for 5 Years due to Corruption
(in office until 25 Sep 2023)
121. Soe Oo Member of the Union Election Commission Yes No No
122. Soe Win Deputy Commander-in-Chief of the Myanmar Yes Yes Yes GB Global Human Rights Sanctions
(a.k.a. Win Soe) Armed Forces, Deputy Prime Minister of Regulations 2020
Myanmar
123. Sok Chol Kim DPRK national deployed in Uganda between No Yes No Sanctioned by the USA before Feb 2021
2015 and 2016 as an instructor for (Non-Burmese)
police/military training.
124. Ssu Lao No Yes No Sanctioned by the USA before Feb 2021
(Non-Burmese)

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Myanmar Sanctions 3 August 2024

No. Individual Occupation/ Affiliation EU USA UK Remarks

(103) (122) (42)
125. Swe Swe Aung Director General of the Prosecution of No Yes No
Department, Ministry of Legal Affairs
126. Tay Za Business Owner and Chairman of Htoo Group Yes Yes Yes
of Companies
127. Tayza Kyaw Member of the Myanmar Armed Forces Yes No No
128. Than Hlaing General, Chief of the Myanmar Police Forces Yes Yes Yes
129. Than Htike Brigadier General Yes No No
130. Than Nyein Former Governor of the Central Bank of No Yes No
Burma
(in office until 19 Aug 2022)

131. Than Oo Brigadier General Yes Yes Yes Sanctioned by the USA, EU and UK
before Feb 2021
132. Than Soe Member of the Union Election Commission Yes No No
133. Than Swe Chairmen of the Anti-Corruption Commission Yes No No
134. Than Than Aye Wife of Admiral Tin Aung San No Yes No
135. Than Than Nwe Wife of General Soe Win No Yes No
136. Than Tun Member of the Union Election Commission Yes No No
(a.k.a. U Than Tun)
137. Than Win Member of the Union Election Commission Yes No No
138. Thant Zaw Win Major of the 564th Light Infantry Battalion of Yes No Yes Sanctioned by the EU and UK before
the Myanmar Armed Forces Feb 2021
139. Thant Zin Oo Commander of the 8th Security Police Yes No Yes Sanctioned by the EU and UK before
Battalion Feb 2021
140. Thein Nyunt Member of SAC, Chairman of the New Yes Yes No
National Democracy Party (NNDP)
141. Thein Soe Chairman of the Union Election Commission Yes Yes Yes

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Myanmar Sanctions 3 August 2024

No. Individual Occupation/ Affiliation EU USA UK Remarks

(103) (122) (42)
142. Thein Win Zaw Owner of Shwe Byain Phyu Group of No Yes No
Companies
143. Theint Win Htet Owner of Shwe Bayain Phyu Group of No Yes No
Companies
144. Thet Khaing Win Union Minister of Health Yes Yes No
145. Thet Pon Lieutenant General Yes No No
146. Thet Thet Aung Wife of General Mya Tun Oo No Yes No
147. Thet Thet Khine Union Minister of Hotels and Tourism (former Yes Yes No
Union Minister of Social Welfare, Relief and
Resettlement until 3 Aug 2023)
148. Thida Oo Union Minister of Legal Affairs and Union Yes Yes Yes
(a.k.a. Daw Thida Oo) Attorney General
149. Thinzar Ye Daughter of Lieutenant General Ye Win Oo No Yes No
150. Thit Akiraphokin Businessman of Dehong Thailong Hotel Co., No Yes No Sanctioned by the USA before Feb 2021
Ltd (Non-Burmese)
151. Thura San Lwin Brigadier General Yes Yes Yes Sanctioned by the USA, EU and UK
before Feb 2021
152. Tin Aung San Deputy Prime Minister of Myanmar, Union Yes Yes Yes
Minister of Defence, Member of SAC
153. Tin Latt Min Wife of Thein Win Zaw No Yes No
154. Tin Oo Chairman of the Anti-Corruption Commission No Yes Yes
155. Toe Yi Deputy Minister of Home Affairs Yes No No
156. Tun Min Latt Director of Star Sapphire Trading and Arms- No Yes Yes
dealer
157. Tun Naing Commanding Officer of the Border Guard Yes No Yes Sanctioned by the EU and UK before
Police Feb 2021

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Myanmar Sanctions 3 August 2024

No. Individual Occupation/ Affiliation EU USA UK Remarks

(103) (122) (42)
158. Tun Tun Naung Union Minister of Border Affairs Yes Yes No
(a.k.a. Tun Tun Naing; a.k.a.
Htun Htun Naung)
159. Tun Tun Oo Chief Justice of Burma’s Supreme Court Yes Yes No
(a.k.a. Htun Htun Oo)
160. Win Kyaw Kyaw Aung Former Director and shareholder of Asia Sun No No Yes
Trading
161. Win Min Soe Wife of Tun Min Latt No Yes No
(a.k.a. Winthura Min Soe)
162. Win Paing Kyaw Owner of Shwe Byain Phyu Group of No Yes No
Companies
163. Win Shein Minister of Planning, Finance and Industry Yes Yes No
164. Wunna Maung Lwin Member of SAC Yes No No
165. Yadanar Moe Myint Daughter of Lieutenant General Moe Myint No Yes No
Tun
166. Ye Aung General No Yes No
167. Ye Win Oo Lieutenant General, Joint Secretary of SAC Yes Yes Yes
168. Yin Min Thu Daughter of Admiral Tin Aung San No Yes No
169. Yu Liang Pao No Yes No Sanctioned by the USA before Feb 2021
(a.k.a. Ta Kyet) (Non-Burmese)

170. Yu Yi Pao No Yes No Sanctioned by the USA before Feb 2021

(a.k.a. Ta Rang) (Non-Burmese)

171. Zaw Hein Major General No Yes No

172. Zaw Lin Aung Deputy Director of the Prison Department, Yes No No
Ministry of Home Affairs

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Myanmar Sanctions 3 August 2024

No. Individual Occupation/ Affiliation EU USA UK Remarks

(103) (122) (42)
173. Zaw Min Director General of the Prison Department, Yes Yes No
Ministry of Home Affairs
174. Zaw Min Tun Director of Asia Sun Group companies No Yes Yes
175. Zaw Min Tun Brigadier-General Yes Yes No
176. Zin Min Htet Major General Yes No No

19 | Luther Law Firm Limited | Luther Corporate Services Limited

Myanmar Sanctions 3 August 2024

IV. List of sanctioned entities / organizations

No. Entities / Organizations EU USA UK Remarks
(21) (63) (34)
1. A & M Mahar Co., Ltd No Yes No
2. Asia Green Development Bank Ltd No Yes No Currently registered as Asia Green
(a.k.a. AGD Bank) Development Bank Public Company
Limited
3. Asia Sun Group Co., Ltd Yes Yes No
4. Asia Sun Trading Co., Ltd No Yes Yes
5. Cancri Gems & Jewellery Co., Ltd No Yes No Currently registered as Cancri (Gems &
Jewellery) Co., Ltd
6. Cargo Link Petroleum Logistics Co., Ltd No Yes Yes
(a.k.a. Cargo Link Pongrawe Logistics Co., Ltd)
7. Directorate of Defence Industries Yes Yes Yes
(a.k.a. Ka Pa Sa)
8. Directorate of Procurement of the Commander-In-Chief of Defence Services Yes Yes Yes
9. Dynasty Group Of Companies Yes Yes Yes
(a.k.a. Dynasty International Company Limited)
10. Everfit Company Limited No Yes No
11. Forest Products Joint Venture Corporation Limited Yes No No Currently registered as The Republic Of
The Union Of Myanmar Forest Products
Joint Venture Corporation Public
Company Limited
12. Hong Pang Electronic Industry Co., Ltd No Yes No Sanctioned by the USA before Feb 2021
(a.k.a. Gold Mount Industrial Co., Ltd)
13. Hong Pang Gems & Jewellery (HK) Co., Ltd No Yes No Sanctioned by the USA before Feb 2021
14. Hong Pang Gems & Jewellery Co., Ltd No Yes No Sanctioned by the USA be-fore Feb 2021
15. Hong Pang General Trading Co., Ltd No Yes No Sanctioned by the USA before Feb 2021
Myanmar Sanctions 3 August 2024

No. Entities / Organizations EU USA UK Remarks

(21) (63) (34)
16. Hong Pang Livestock Development Co., Ltd No Yes No Sanctioned by the USA before Feb 2021
17. Hong Pang Mining Co., Ltd No Yes No Sanctioned by the USA before Feb 2021
18. Hong Pang Textile Co., Ltd No Yes No Sanctioned by the USA before Feb 2021
19. Htoo Group of Companies Yes Yes Yes
20. International Gateways Group of Company Limited Yes Yes Yes
(a.k.a. IGGC, a.k.a. IGG)
21. International Group of Entrepreneurs Company Limited Yes No Yes
(a.k.a. IGE)
22. JSC Gorizont No No Yes
23. King Royal Technologies Co., Ltd No Yes No
24. KT Services & Logistics Company Limited No Yes No Currently registered as KT Services &
Logistics (KTSL) Company Limited
25. Mining Enterprise No. 1 Yes Yes Yes
26. Mining Enterprise No. 2 Yes Yes Yes
27. Ministry of Defence No Yes No
28. Miya Win International Ltd No No Yes
29. Myanma Economic Holdings Public Company Ltd Yes Yes Yes GB Global Human Rights Sanctions
Regulations 2020
30. Myanma Five Star Line Company Limited No Yes No
(a.k.a. Myanma five Star Shipping Company)
31. Myanma Oil and Gas Enterprise Yes No No Non-SDN List (USA)
32. Myanmar Chemical & Machinery Company Limited No Yes Yes
33. (a.k.a. MCM Group)
34. Myanmar Economic Corporation Ltd Yes Yes Yes GB Global Human Rights Sanctions
Regulations 2020
35. Myanmar Foreign Trade Bank No Yes No
(a.k.a. MFTB)
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Myanmar Sanctions 3 August 2024

No. Entities / Organizations EU USA UK Remarks

(21) (63) (34)
36. Myanmar Gems Enterprise Yes Yes Yes
(a.k.a. Myanmar Gems Corporation, also spelled as Myanma Gems Enterprise)
37. Myanmar Imperial Jade Co., Ltd No Yes No Currently registered as Myanmar Imperial
Jade (Gems & Jewellery) Co., Ltd
38. Myanmar Investment and Commercial Bank No Yes No
(a.k.a. MICB)
39. Myanmar New Era Trading Company Ltd No No Yes
40. Myanmar Pearl Enterprise No Yes Yes
41. Myanmar Ruby Enterprise Co., Ltd No Yes Yes GB includes under Myanma Economic
Holdings Public Company Ltd
42. Myanmar Timber Enterprise Yes Yes Yes
(a.k.a. Myanma Timber Enterprise)
43. Myanmar War Veterans Organization Yes Yes Yes
44. Office of the Chief of Military Security Affairs No No Yes
45. P.E.I Energy Pte. Ltd. No Yes No Linked to Khin Phyu Win
46. PEIA Pte. Ltd. No Yes No Linked to Khin Phyu Win
47. Quartermaster General Office Yes Yes Yes
(a.k.a. Myanmar Office of the Quarter Master General)
48. Royal Shune Lei Company Limited Yes No No
49. Shoon Energy Pte., Ltd No Yes Yes
50. Shwe Byain Phyu Group of Companies No Yes No
(a.k.a. SBPG)
51. Sky Aviator Company Limited Yes Yes Yes
52. Sky One Construction Co., Ltd No Yes Yes
53. Sky Royal Hero Company Limited No Yes No
54. SS Techniques Company Limited No No Yes
(a.k.a. Synpex Shwe Company Ltd.)
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Myanmar Sanctions 3 August 2024

No. Entities / Organizations EU USA UK Remarks

(21) (63) (34)
55. Star Sapphire Group of Companies Yes Yes Yes
(a.k.a. Kyei Nilar Company)
56. Star Sapphire Group Pte. Ltd No Yes No
57. Star Sapphire Trading Company Limited No Yes No
58. State Administrative Council (SAC) Yes Yes Yes
59. Suntac Group No Yes No
(a.k.a. Suntac Technologies Company Limited)
60. Suntac International Trading Company Limited No Yes No
61. Tet Kham Construction Co., Ltd No Yes No Sanctioned by the USA before Feb 2021
62. Tet Kham Gems Co., Ltd No Yes No Sanctioned by the USA before Feb 2021
63. The Yangon Gallery No Yes No
64. The Yangon Restaurant No Yes No
65. Union Election Commission No Yes No
66. URAL AVIA LLC No No Yes
67. Wanbao Mining Ltd No Yes No
68. Yangon Airways Co., Ltd No Yes No Sanctioned by the USA before Feb 2021
69. Zhao Wei Narcotics Trafficking Group No Yes No
(a.k.a. Kings Romans Casino; a.k.a. Kings Romans Group)
70. 7th (Seventh) Sense Co. Ltd No Yes No
(a.k.a. 7th Sense Creation)
71. 33rd Light Infantry Division No Yes Yes
72. 66th Light Infantry Division No Yes No
73. 77th Light Infantry Division No Yes Yes
74. 99th Light Infantry Division No Yes Yes
75. 101st Light Infantry Division No No Yes

23 | Luther Law Firm Limited | Luther Corporate Services Limited

Luther in Myanmar
Active in Myanmar since 2013, Luther is one of the largest law firms and corporate services providers in Yangon. Our international
team of more than 50 professionals consist of lawyers, tax consultants, corporate secretaries and accountants from Germany,
France, Italy and Myanmar.

With our “one-stop” service solution, Luther Law Firm Limited and Luther Corporate Services Limited provide a comprehensive
range of services to assist and advise clients in all stages of the business lifecycle, namely, from the establishment of a Myanmar
business, through on-going legal and tax advice, bookkeeping, accounting, payroll and payment administration up to the dissolution
of enterprises.

We devise and help our clients to implement legal, tax and corporate compliance structures that work and let them focus on being
successful in Asia’s last frontier market. Myanmar’s legal framework is governed by both old and new laws and regulations, as well
as internal policies and practices of the Myanmar authorities. Many laws dating back to the colonial and post-independence periods
are, with more or less changes, still in force. Since its political and economic opening in 2011, Myanmar has embarked on a
comprehensive reform process and is currently overhauling its legal framework.

Our local and international colleagues have the necessary knowledge, experience and commercial expertise to serve our more
than 600 clients in this rapidly developing country, including multinational investors, MNCs and SMEs, development organisations,
embassies, NGOs and local conglomerates.

To advise each client in the best possible way, our lawyers and tax advisors – in addition to their specialised legal and tax expertise
have expert knowledge of specific industries.

Further, our team members are well connected and actively participating and holding positions in various chambers to stay abreast
of the latest developments, such as the European Chamber of Commerce in Myanmar, the German Myanmar Business Chamber,
the British Chamber of Commerce and French Myanmar Chamber of Commerce and Industry.

We offer pragmatic solutions and recommendations based on best practice guidelines. We never compromise on quality and we
always put our clients first. Our lawyers are trained to deliver work products that comply with the highest standards and we will not
settle for less.

In 2024, both Luther Myanmar and Alexander

“The Legal 500 Asia-Pacific 2024“ ranked Luther
Bohusch individually were ranked in Band 3 by
Myanmar in Band 3.
Chambers Asia Pacific.

CHAMBERS
THE LEGAL 500 ASIA-PACIFIC
2024
2024

24 | Luther Law Firm Limited | Luther Corporate Services Limited

Legal advisory services

Our international and Myanmar lawyers provide

comprehensive legal and tax advice in all areas of corporate
and commercial law, including:

Foreign direct investment and market entry Non-profit sector

■ Support and advice on the choice of location ■ Advice on the appropriate legal structures for NGOs,
■ Advice with regard to the appropriate market entry and development organisations, foundations, social enterprises
restrictions under the Myanmar Investment Law and charities
■ Representation vis-à-vis regulatory authorities ■ Registration of companies limited by guarantee,
■ Application for Permits and Endorsements under the associations and NGOs
■ Myanmar Investment Law 2016 and the Special Economic ■ Application of tax exemptions
Zone Law 2014
Compliance
Establishment of a Myanmar business ■ Anti-corruption compliance
■ Advising on the type of entity to be established and the ■ Corporate governance and corporate compliance
optimal corporate & tax structure ■ Labour law compliance
■ Incorporation of limited companies and registration of ■ Regulatory compliance
foreign corporations (“Branch or Representative Offices“) ■ Tax compliance

Corporate law, investment structuring and jointventures Employment and labour law
■ National and international joint ventures, PPP projects ■ Employment and secondment contracts, employment policies
■ Capital measures (increase and reduction in capital, cash ■ Registration of employment contracts with Myanmar labour
and in kind) authorities
■ Advice to members of executive and supervisory boards ■ Corporate restructuring, redundancy and compensation plans
■ Shareholders agreements, constitutions and rules of
procedure Immigration law
■ Disputes among shareholders ■ Visa, long-term stay permits and foreigner registration
cards
M&A advisory ■ Labour Cards
■ Support in M&A, domestic and cross-border acquisitions ■ Form C (Occupation of Residential Premises)
by asset or share deal
■ Due diligence Contract law
■ Corporate restructuring measures ■ Negotiation and drafting of commercial agreements
■ Post-merger / closing integration ■ Registration of deeds and contracts with the authorities
■ Advice and assistance on stamp duty payments
Finance advisory
■ Banking, finance and insurance law International trade and distribution law
■ Corporate finance ■ Registration of foreign trading companies
■ Loan and security agreements ■ Review of general terms and conditions
■ Registrations with the Central Bank and FRD ■ Supply and procurement agreements
■ Legal opinions ■ Distributorship and sales agency agreements

Real estate law Intellectual property law

■ Sale and purchase agreements and leases ■ Development and implementation of IP protection
■ Financing structures strategies
■ Registration of trademarks, designs and patents
■ License agreements, research and development
agreements

25 | Luther Law Firm Limited | Luther Corporate Services Limited

 Tax advisory and business process outsourcing services

Our tax advisors, company secretaries and accountants support

clients with a complete range of BPO services, including:

Corporate secretarial services Accounting and financial reporting

■ Provision of personnel to assume statutory positions ■ Bookkeeping
– Company secretary – Setting up the chart of accounts
– Nominee director / officer – Recording of all payments and funds received
■ General statutory compliance services – Preparation of monthly bank reconciliation statements
– Advice on best practice, corporate governance and – Recording of all sales, purchase and trade debtors
compliance with Myanmar law – Recording of prepayments and accruals
– Setting up, custody and maintenance of statutory books – Recording of assets and related depreciation
and registers – Recording of all commercial tax (CT) on taxable
– Filings with the Directorate of Investment and Company purchases/ supplies
Administration (DICA) and the Myanmar Investment – Extraction of monthly trial balances and general ledger
Commission (MIC) ■ Management reports
– Preparation of notices, minutes, and other documents – Compiling of profit and loss account and balance sheet
pertaining to directors’ and shareholders’ meetings – Generating aged financial analysis of debtors and
– Provision of registered office address creditors
■ Managing changes: – Business advisory services such as accounting reports
– Change of name – Budget preparation, comparison and analysis of key
– Change in constitutional documents components of financial performance
– Change in capital structure (transfer of shares, issuance – Statutory accounting
of shares) – Preparation of financial statements and notes to
– Change of shareholders, directors, representatives, the financial statements
auditors and company secretaries
– Change of registered office address Human resources and payroll administration
■ Cessation of a business ■ Processing and payment of employee expense claims
– Liquidation of companies ■ Computation of salaries, social security contributions
– De-Registration of overseas corporations (Branch / and personal income taxes
Representative Office) ■ Provision of payroll reports and financial journals
■ Payment of salaries net of personal income tax and
Tax advice and tax structuring social security contributions
■ International tax (inbound and outbound) ■ Filing and payment of personal income tax and social
■ Direct and indirect taxes security contributions
■ Tax structuring of M&A transactions ■ Ensuring compliance with tax and social security
■ Transfer pricing reporting requirements

Tax compliance Payment administration

■ Commercial tax and special goods tax ■ Administration of cash funds deposited with us or in
■ Corporate income tax and withholding tax client’s own bank accounts
■ Personal income tax ■ Account signatory services to enable settlement
■ Applications for relief under Double Tax Agreements of company payment obligations and observance of
■ Liaison with the Internal Revenue Department “four eyes principle”
■ Payment of stamp duty ■ Cash flow forecasting and processing of accounts
receivables
■ Issuance of payment vouchers and arrangement
of payments

26 | Luther Law Firm Limited | Luther Corporate Services Limited

Luther in Asia
Expertise Singapore

Our Myanmar office works closely together with the other Singapore is a leading international trade and financial hub. As
Luther offices in Asia and Europe. We take a holistic approach, such, it serves as Asian headquarters for many international
dealing with Asia-wide compliance issues, assisting with the companies operating within the Asia-Pacific region.
creation of international holding structures and ensuring tax-
efficient repatriation of profits. With a staff strength of more than 100, Luther is by far the
largest continental European law firm in Singapore. More than
We provide the complete range of legal and tax advice to 25 lawyers from Singapore, Germany, France and other
clients doing business in and from Asia. To offer a seamless jurisdictions cover the full range of corporate and commercial
service, we have teams in Europe as well as in Asia, led by legal work as well as the structuring of investments within
partners with many years of experience on both continents. South and South East Asia.
That way, we can immediately answer questions concerning
investment decisions and provide our clients with an accurate Our team is supported by excellent local Singaporean lawyers,
assessment of the particularities of their projects, no matter notary publics, tax advisors, accountants, corporate
where they are located. secretaries and other professionals.

Our lawyers unite substantial practical knowledge in important Region

legal areas and cover the entire spectrum of law in Asia and
beyond. We support foreign investors in the assessment of Our principal office in Singapore is complemented by offices
location and investment criteria, the structuring of investment and teams in Yangon (Myanmar), Bangkok (Thailand), Delhi-
projects, acquisitions and joint ventures. Finding and Gurugram (India), Ho Chi Minh City (Vietnam), Kuala Lumpur
implementing solutions for sensitive areas like technology (Malaysia) and Jakarta (Indonesia).
transfer and know-how protection also form part of our work.
Alongside our clients we negotiate with future partners and This network of Luther offices is further strengthened by the
local authorities and ensure the enforcement of their rights, in long-established business relationships that we have
and out of court as well as in arbitration proceedings. successfully developed both locally and with our regional
partners in Australia, China, Hong Kong, Japan, New Zealand,
The services of our lawyers are complemented by our tax the Philippines, South Korea and Vietnam.
advisors, company secretaries, liquidators accountants, HR
professionals and other professionals offering all the services
one would necessarily associate with a “one- stop shop”
concept, from outsourced administration to accounting, payroll
and tax compliance. Additionally, we provide corporate
secretarial services, especially in Asian “common law”
countries.

Collectively, our lawyers, tax consultants and professionals

combine the competence and experience necessary to
comprehensively assist comprehensively on all business
matters in Asia. Our tax experts advise on individual and
corporate tax compliance as well as on withholding tax issues,
on Double Taxation Agreements and on complex international
tax structures. Our accountants and professionals carry out the
time-consuming administrative tasks of accounting and payroll
functions a business must undertake, allowing our clients to
concentrate on growing their business.

27 | Luther Law Firm Limited | Luther Corporate Services Limited

Hits the mark. Luther.
Luther Rechtsanwaltsgesellschaft mbH is one of the leading corporate law firms in Germany. With some 420 lawyers and tax
advisors, we can advise you in all fields of German and international corporate law. In addition to having offices in every economic
centre throughout Germany, we are also present in ten locations abroad: in Brussels, London and Luxembourg in Europe, and in
Bangkok, Delhi-Gurugram, Ho Chi Minh City, Jakarta, Kuala Lumpur, Singapore and Yangon in Asia.

Our advisory services are tailored to our clients’ corporate goals. We take a creative, dedicated approach to achieving the best
possible economic outcome for each of our clients. The name “Luther” stands for expertise and commitment. With a passion for
our profession, we dedicate all our efforts to solving your issues, always providing the best possible solution for our clients. Not too
much and not too little – we always hit the mark.

We know how crucial it is to use resources efficiently and to plan ahead. We always have an eye on the economic impact of our
advice. This is true in the case of strategic consulting as well as in legal disputes. We have complex projects on our agenda every
day. At Luther, experienced and highly specialised advisors cooperate closely in order to offer our clients the best possible service.
Thanks to our fast and efficient communication, permanent availability and flexibility, we are there for you whenever you need us.

Luther Myanmar is ranked in the Asia Pacific Guides 2024 of Chambers and Legal 500.

Lawyers and Locations Long-Standing Connec- Offices in International

Tax Advisors tions to Commercial Law Financial Centres and
Firms Worldwide Investment Locations

420 20
About unyer
locationsunyer is a global organisation of leading international professional services firms. Besides law firms, unyer is also open to
other related professional services, especially from the legal tech sector. unyer is based in Zurich as a Swiss Verein. unyer is
globally connected but has strong local roots in their respective markets.

unyer has an exclusive approach and only accepts one member firm from each market. unyer members offer its clients full services
across all jurisdictions with a compelling industry focus. The organisation has an annual turnover of more than EUR 650 million
and includes over 2,550 lawyers and advisors in more than 14 countries in Europe and Asia.

www.unyer.com

28 | Luther Law Firm Limited | Luther Corporate Services Limited

Our locations
Our and our local partners’ offices in important European and Asian markets

London
Brussels Bangkok
Luxembourg

Ho Chi Minh City

10 Offices
in Germany
Berlin
Cologne
Dusseldorf
Delhi-Gurugram
Essen
Frankfurt a.M.
Yangon
Hamburg
Hanover Jakarta
Leipzig
Munich Kuala Lumpur
Singapore
Stuttgart

The shown locations are either Luther legal or corporate

services offices and/or offices of our local cooperation partners.

29 | Luther Law Firm Limited | Luther Corporate Services Limited

Contact

Bagaya St Bagaya St Bagaya St

Koe Htat Gyi Pagoda

Ba
ho
Lower Kyeemyindaing Rd

Rd
Pann Hlaing St Asia World
Hospital

in
Sh aw

Ba
ho
S u

Rd
P

Kanner Rd.
Myindaing
Thida St
U Lu Ni St

Description in detail

Our office in Myanmar Your contact

Luther Law Firm Limited // Alexander Bohusch

Luther Corporate Services Limited Rechtsanwalt/Attorney-at-law
Uniteam Marine Office Building, Level 8, Unit #1 (Germany)
84 Pan Hlaing Street, Sanchaung Accredited Tax Practitioner
Township 11111 Yangon, Myanmar (Income Tax) (Singapore)
Phone +95 1 7500 021, Fax +95 1 7502 852
Myanmar@Luther-Lawfirm.com

Imprint Disclaimer
Luther Rechtsanwaltsgesellschaft mbH, Anna-Schneider-Steig 22, Although every effort has been made to offer current and correct
50678 Cologne, Germany, Phone +49 221 9937 0, Fax +49 221 9937 information, this publication has been prepared to provide information on
110, contact@luther-lawfirm.com recent regulatory and legal developments in Myanmar only. It is not
exhaustive and thus does not cover all topics with which it deals. It will
Editor: Alexander Bohusch, Rechtsanwalt/Attorney-at-law (Germany), not be updated and cannot substitute individual legal and/or tax advice.
Luther Law Firm Limited, Luther Corporate Services Limited, This publication is distributed with the understanding that Luther, the
Uniteam Marine Office Building, Level 8, Unit #1, 84 Pan Hlaing Street, editors and authors cannot be held responsible for the results of any
Sanchaung Township 11111 Yangon, Myanmar, Phone +95 1 500 021, actions taken on the basis of information contained herein or omitted,
Fax +95 1 502 852, HP (MM): +95 9 425 0136 00, nor for any errors or omissions in this regard.
HP (SG): +65 9 829 1829, alexander.bohusch@luther-lawfirm.com

Copyright: These texts are protected by copyright. You may make use of
the information contained herein with our written consent, if you do so
accurately and cite us as the source. Please contact the editors in this
regard contact@luther-lawfirm.com

30 | Luther Law Firm Limited | Luther Corporate Services Limited

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Frankfurt a.M., Hamburg, Hanover, Kuala Lumpur, Jakarta, Leipzig, London,
Luxembourg, Munich, Singapore, Stuttgart, Yangon

You can find further information at:

www.luther-lawfirm.com
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