FROM A
DIFFERENT ANGLE by Kenneth Rijock
Financial Crime Consultant, for World-Check
Alert on OFAC language on Burma
8 May 2008

Whilst the General License issued this week permits financial institutions to assist in humanitarian aid to cyclone-ravaged Burma, in order to avoidf the pitfalls we want our readers to carefully review the specific explanatory language that appeared in an official OFAC statement. Please read the direct quotes from the statement, which are contained in the main article and pay particular attention to the sections I have emphasised through the use of boldface type.

  • Existing general licenses already authorize the exportation or reexportation of financial services ordinarily incident to the exportation of goods or services, other than financial services, to Burma. This action will allow US individuals and entities to send and US financial institutions to transfer, funds to Burma to be used to support the humanitarian-denominated funds through the United states to be used to provide humanitarian assistance by NGOs in Buirma. This general license does not authorize the provision of financial services directly or indirectly to the Government of Burma or to persons blocked under the Burma sanctions and such services remain prohibited.

  • All transfers authorized by this general license may be made utilizing the services of blocked financial institutions in Burma, provided the transfers are made through third-country banks (no debits or credits may be made to any blocked account on the books of a US financial institution).

Additionally, for those readers who are unaware of our warnings on the possibility that opportunistic money laundering may occur, due to the extraordinary circumstances of the situation in Burma, you are urged to read: Watch OFAC Burma Licensees Carefully, World-Check 7 May, 2008. It can be accessed through the search function on this page, or go directly to:
http://www.world-check.com/articles/2008/05/07/watch-ofac-burma-financial-licensees-carefully/  

The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.

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