Yes.  The prohibitions in the MOGE Financial Services Directive apply to MOGE “or its property or interests in property,” including any entity, such as a subsidiary or joint venture, that is 50 percent or more owned, directly or indirectly, by MOGE, except to the extent otherwise provided by law or unless authorized by OFAC.

Pursuant to the MOGE Financial Services Directive, the following activities by a U.S. person are prohibited on or after December 15, 2023:  the provision, exportation, or rexportation, directly or indirectly, of financial services to or for the benefit of Myanma Oil and Gas Enterprise (MOGE).

Further, except to the extent otherwise provided by law or unless authorized by OFAC, the following are also prohibited pursuant to the MOGE Financial Services Directive:  (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the MOGE Financial Services Directive; and (2) any conspiracy formed to violate any of the prohibitions of the MOGE Financial Services Directive.

OFAC considers the term “financial services” for purposes of the MOGE Financial Services Directive to include loans, transfers, accounts, insurance, investments, securities, guarantees, foreign exchange, letters of credit, and commodity futures or options.