James Swe
In July 2025, Myanmar’s resistance movement witnessed two headline developments from Washington. On July 22, the U.S. Congress advanced three of the most robust bills ever proposed to tighten sanctions on the junta and support those struggling for democracy. Yet only two days later, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced the delisting of several Myanmar-linked companies and individuals, including those publicly associated with the regime’s key arms and fuel procurement operations.
Such mixed signals have caused confusion and concern. To understand what’s truly at play, it’s important to separate direct legislative action from the legal and administrative machinery of U.S. sanctions policy—a distinction recently highlighted by experts handling these delisting cases in real time.
Legal Experts Confirm: It’s a Routine Global Review
In a public LinkedIn post on July 24, Erich Ferrari—one of America’s foremost OFAC sanctions attorneys—shared firsthand insight following the “triple removal action” that same day. Ferrari’s comment confirms that the delistings affected clients in matters involving not only Myanmar, but also North Korea and non-proliferation sanctions. He emphasized his pride in achieving these removals and noted that such simultaneous actions are “unprecedented” for his career.
This direct testimony makes clear: the recent removals are NOT unique to Myanmar, nor do they represent a change in U.S. Burma policy. Instead, they are the outcome of technical, evidence-based petitions handled by specialized legal teams.
How Delistings Happen (and Why Only Big Players Can Afford It)
OFAC delistings require a stringent process:
• Heavy Legal Burden: Petitioners must show fundamental changes in company structure, operations, or end of prohibited activity.
• Long, Expensive Process: As Ferrari and others note, such outcomes are rare, typically requiring months (or years) of work by expert U.S. legal counsel and supporting teams—at a cost only major players can bear.
• Administrative, Not Political: Each removal depends on documentation, compliance, and legal due process—not on White House, State Department, or Congressional policy shifts.
Delistings in Myanmar… and Beyond
On the same day as the Myanmar delistings, OFAC also removed entities and individuals linked to North Korea, Syria (in a major programmatic action weeks prior), Russia, China, Iraq, and non-proliferation cases. As Ferrari’s post and OFAC’s own records confirm, these removals happen periodically across countries, always based on legal reviews—not geopolitics.
What Does This Mean for Myanmar’s Revolution?
• Pressure Works: The only reason junta-linked companies spend hundreds of thousands of dollars on high-powered U.S. attorneys is because international financial isolation IS hurting them.
• No Policy Shift: Congress remains more committed than ever—advancing new bills and tightening sanctions with bipartisan urgency.
• Delistings ? Exoneration: These companies remain under the microscope. OFAC watches for any resumption of prohibited activity and can reinstate sanctions at any time.
• The Fight Continues: The resistance and civil society must continue monitoring, documenting ongoing military-business links, and advocating for rigorous enforcement and oversight.
The Real Story: Sanctions Advocacy Remains Vital
Rather than weakening, global pressure on the regime is working: it’s driving major players to expend huge resources simply to get a technical delisting—while Congressional and international partners push forward. The real work is ensuring that any changes claimed by these companies are real—not superficial—and that continued evidence collection and public reporting bring true accountability, both at OFAC and in world opinion.
In Summary
The July 24 OFAC delistings are not a softening of U.S. resolve on Myanmar. They are legal events, documented in public by leading U.S. sanctions counsel, and part of global, routine administrative reviews.
It is only the deeply pressured, well-resourced regime cronies who even attempt such petitions—which underscores the effectiveness of ongoing international pressure. The resistance should take these removals as evidence of impact, remain vigilant, and deepen efforts to document, report, and advocate for relentless sanctions enforcement side by side with Congressional allies.
The views expressed here do not necessarily reflect the views of Myanmar Media.
