Sanctions Busting: Myanmar Teak

This Month's Focus

NU Borders, LLC operates the Border Intelligence for Trade Enforcement (BITE) platform which aggregates large-scale international manifest data for advanced analytics. Our enforcement SMEs continuously query BITE to identify suspicious transactions in the trade data, particularly for 2nd and 3rd tier entities that may not appear in court documents or Watch Lists but are involved in the illicit movement of controlled or protected commodities. These entities, not captured on any other Watch lists, play critical roles in sanctions evasion and their identifiers significantly enhance risk management programs. The intermediary/transshipment companies are provided via our BITE List which is available at a very low subscription fee (https://nuborders.com/contact).

This month's BITE List entries focus on the international movement of Myanmar teak wood which is highly prized in yacht manufacturing, high-end furniture and other luxury products that require superior water and pest-resistant wood. In April 2021, the U.S. Treasury Department* designated Burmese state-owned enterprise Myanmar Timber Enterprise (MTE) in response to the military junta's coup in February of that year. The European Union implemented similar sanctions in June 2021.** MTE is the state-owned enterprise responsible for Myanmar's timber and teak trade (conflict wood).

Despite the sanctions, large amounts of teak shipments are exported from Myanmar to other countries, including the U.S.,*** which help finance the military regime's human rights abuses. In addition to the U.S., India - which has no ban on Myanmar teak - imports and processes significant quantities. BITE queries also reveal several companies in Vietnam receiving Myanmar teak after the U.S. and EU implemented sanctions.

Although these shipments may not violate Vietnamese law, responsible companies should be aware of their connections to MTE and exercise greater due diligence when trading with the Vietnam companies listed below. NU Borders will continue to research these 2nd and 3rd tier intermediaries and document the entities on our BITE List to provide risk management and compliance officials greater insight into their trade activities.

• *https://home.treasury.gov/news/press-releases/jy0138
• **https://assets.gov.ie/153115/9ef90328-d535-4842-9680-dd96987ce650.pdf
• ***https://www.justiceformyanmar.org/stories/us-companies-imported-nearly-1-600-tonnes-of-myanmar-teak-circumventing-sanctions

Accessing the BITE List

BITE and the BITE List are priced competitively so all users can apply efficient, seamless risk-management solutions at negligible costs.

To access the BITE List register here or email us at bite@nuborders.com

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