Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Karen National Army (KNA), a militia group in Burma, as a transnational criminal organization, along with the group’s leader Saw Chit Thu, and his two sons, Saw Htoo Eh Moo and Saw Chit Chit, for their role in facilitating cyber scams that harm U.S. citizens, human trafficking, and cross-border smuggling. The KNA-controlled region, located on the Thai-Burmese border, is home to multiple cyber scam syndicates, and the KNA has benefitted from its connection to Burma’s military in its criminal operations. Although statistics vary, American victims of cyber scams like the ones emanating from Burma have collectively lost billions of dollars over the last three years. The KNA is headquartered in Shwe Kokko, Myawaddy Township in Burma’s southeast Karen State along the border with Thailand. The KNA has leveraged its former role as a Border Guard Force (BGF) with Burma’s military to facilitate a transborder criminal empire; the majority of cyber scam syndicates in Karen State operate in the KNA-controlled border region. While the KNA (formerly known as the Karen Border Guard Force) changed its name in March 2024 in an effort to distance itself from Burma’s military regime, it has continued its cooperation with the Burmese military as recently as September 2024. The KNA profits from cyber scam schemes on an industrial scale by leasing land it controls to other organized crime groups, and providing support for human trafficking, smuggling, and the sale of utilities used to provide energy to scam operations. The KNA also provides security at scam compounds in Karen State. Survivors from KK Park—an infamous scam site—who were coerced into forced criminality to commit cyber scams have reported that the uniforms of soldiers guarding the compound bore the insignia of the KNA. As the leader of the KNA, Saw Chit Thu has emerged as one of the central figures in Burma’s scam economy, facilitating transnational crimes in a KNA-controlled zone along the border with Thailand. Under Saw Chit Thu’s leadership, the KNA has become a key enabler of scam operations in the region, providing security at compounds and leasing land to criminal organizations while profiting handsomely at the expense of scam victims and of the otherwise innocent people forced to carry out these crimes. Saw Chit Thu was sanctioned by the United Kingdom in 2023 and the European Union in 2024 for his involvement in scam compounds and with Burma’s military regime. Saw Chit Thu appointed his two sons, Saw Htoo Eh Moo and Saw Chit Chit, as officers in the KNA. Both have served in key roles in the KNA criminal enterprise. Saw Htoo Eh Moo has an interest in KNA-affiliated business ventures, including cyber scam centers. Saw Chit Chit is active in military operations alongside the military regime and has commanded KNA battalions fighting against anti-regime rebel groups. He also holds shares and directorships in several KNA-linked businesses.
Transnational Criminal Organizations Sanctions Regulations, 31 C.F.R. part 590;
Executive Order 13581 of July 24, 2011 Blocking Property of Transnational Criminal Organizations
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Official Information
On January 12, 2012, OFAC issued the Transnational Criminal Organizations Sanctions Regulations, 31 CFR part 590 (77 FR 1864, January 12, 2012) (the “Regulations”), to implement Executive Order (E.O.) 13581 of July 24, 2011, “Blocking Property of Transnational Criminal Organizations” (76 FR 44757, July 27, 2011), pursuant to authorities delegated to the Secretary of the Treasury in E.O. 13581. The Regulations were initially issued in abbreviated form for the purpose of providing immediate guidance to the public. OFAC amended the Regulations on July 23, 2019 (84 FR 35307, July 23, 2019) to implement E.O. 13863 of March 15, 2019, “Taking Additional Steps to Address the National Emergency With Respect to Significant Transnational Criminal Organizations” (84 FR 10255, March 19, 2019), which amended E.O. 13581. OFAC is amending and reissuing the Regulations as a more comprehensive set of regulations that includes additional interpretive guidance and definitions, general licenses, and other regulatory provisions that will provide further guidance to the public. Due to the number of regulatory sections being updated or added, OFAC is reissuing the Regulations in their entirety.
E.O. 13581 On July 24, 2011, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), issued E.O. 13581. In E.O. 13581, the President found that the activities of significant transnational criminal organizations, such as those listed in the Annex to E.O. 13581, have reached such scope and gravity that they threaten the stability of international political and economic systems. The President further found that such organizations are becoming increasingly sophisticated and dangerous to the United States; they are increasingly entrenched in the operations of foreign governments and the international financial system, thereby weakening democratic institutions, degrading the rule of law, and undermining economic markets. The President stated these organizations facilitate and aggravate violent civil conflicts and increasingly facilitate the activities of other dangerous persons. The President determined that the activities of significant transnational criminal organizations constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States and declared a national emergency to deal with that threat.
