Clifford Chance

US Government Issues Advisory On Heightened Risks Associated With Doing Business In Burma

2 February 2022

The Biden Administration has put US and international companies and financial institutions on notice regarding the wide-ranging legal risks of doing business with and in Burma, including under the Foreign Corrupt Practices Act, Treasury Department Office of Foreign Assets Control sanctions, Commerce Department Bureau of Industry and Security export controls, US anti-money laundering laws and regulations, and US human rights laws.  Given the strong focus by the US Department of Justice and other enforcement agencies on adequate risk assessments and compliance frameworks, all companies are well advised to consider their exposure to the delineated risks in their business, and ensure that their compliance framework adequately mitigates those risks within the company's risk tolerance set by senior management or the Board.

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