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. 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. OFAC is designating Saw Chit Thu and his two sons, Saw Htoo Eh Moo and Saw Chit Chit, pursuant to E.O. 13581, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, the Karen National Army, and pursuant to E.O. 14014 for having acted or purported to act for or on behalf of, directly or indirectly, the Karen National Army. Saw Htoo Eh Moo and Saw Chit Chit are also being designated pursuant to E.O. 14014 for being the adult children of Saw Chit Thu.
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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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.
