Remaining Sanctions Targeting Burma As a result of the May 17, 2016 actions, the remaining sanctions targeting Burma have been significantly reduced. Generally, unless authorized or exempt, US persons remain prohibited from dealing with blocked persons, including persons on the SDN List, as well as any entity owned in the aggregate, directly or indirectly, 50 percent or more by one or more blocked parties. Despite the May 17 actions, a number of Burmese parties remain on the SDN List. The BSR continue to prohibit the importation into the United States of any jadeite or rubies mined or extracted from Burma and any articles of jewelry containing jadeite or rubies mined or extracted from Burma. Limited OFAC restrictions remain on dealings with the designated Burmese financial institutions covered by the partial authorization described above. First, transactions with such financial institutions still may not involve other blocked parties not included in the general license. US persons also remain prohibited from engaging in new investment with or in such designated financial institutions.

Finally, a prohibition remains on the exportation or reexportation of financial services in connection with the provision of security services, directly or indirectly, to the Burmese Ministry of Defense, any state or non-state armed group or any entity 50 percent or greater owned by such parties. The reporting requirement also remains in effect for US persons engaging in investment in Burma, which currently applies to new investment exceeding US$500,000. The Department of State is proposing to change the reporting threshold from US$500,000 to US$5,000,000. The proposed change is currently undergoing administrative review.

In addition, US persons undertaking any new investment pursuant to an agreement, or pursuant to the exercise of rights under such an agreement, that is entered into with Myanma Oil and Gas Enterprise (MOGE) will continue to have an obligation to notify the Department of State of such investment. With certain sanctions targeting Burma still in place, companies doing business in Burma should monitor closely the remaining measures, and any further developments, to ensure compliance. Penalties for noncompliance can be severe. White & Case LLP 701 Thirteenth Street, NW Washington, District of Columbia 20005-3807 United States White & Case LLP Wetstraat 62 rue de la Loi 1040 Brussels Belgium T T +1 202 626 3600 USsanctions@whitecase.com +32 2 219 16 20 EUsanctions@whitecase.com In this publication, White & Case means the international legal practice comprising White & Case LLP, a New York State registered limited liability partnership, White & Case LLP, a limited liability partnership incorporated under English law and all other affiliated partnerships, companies and entities. This publication is prepared for the general information of our clients and other interested persons. It is not, and does not attempt to be, comprehensive in nature.

Due to the general nature of its content, it should not be regarded as legal advice. Client Alert White & Case 3 .