481. If there is an active and ongoing investigation against an individual or entity for apparent violations of the Burmese Sanctions Regulations (“BSR”), would that investigation cease now that the President has ended economic and financial sanctions on Burma and the prohibitions in the BSR are no longer in effect?

Pending OFAC enforcement matters will proceed irrespective of the termination of OFAC-administered sanctions on Burma, and OFAC will continue to review app​arent violations of the BSR, whether they came to the agency’s attention before or after the Burma sanctions program was terminated. Under longstanding practice, apparent sanctions violations are analyzed in light of the laws and regulations that were in place at the time of the underlying activities, and civil and criminal enforcement authorities are applied accordingly. Current or future investigations regarding apparent violations of the BSR will not be impacted by its termination and may result in OFAC enforcement actions after the termination of the BSR.