Saw Chit Thu, as the leader of the KNA, has entrusted different aspects of the operations to trusted subordinates, such as Tin Win and Saw Min Min Oo. Tin Win and Saw Min Min Oo control property that hosts the scam centers, provide security for those facilitating illicit money flows, and personally run entities that control and support scam compounds in Karen State. Saw Min Min Oo is a KNA official, and former Colonel in the KNA, who runs and manages various KNA affiliated companies. He is on the board of Chit Linn Mying Co., Ltd (CLM Co.), Chit Linn Myaing Toyota Company Limited, Chit Linn Myaing Mining & Industry Company Limited, and Myanmar Yatai International Holding Group Co., Ltd. OFAC is designating Tin Win, Saw Min Min Oo, and Chit Linn Myaing Co., pursuant to E.O. 13581, as amended, 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.
On February 10, 2021, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701–1706) (IEEPA), issued Executive Order (E.O.) 14014 of February 10, 2021, “Blocking Property With Respect to the Situation in Burma” (86 FR 9429, February 12, 2021).
In E.O. 14014, the President determined that the situation in and in relation to Burma, and in particular the February 1, 2021 coup, in which the military overthrew the democratically elected civilian government of Burma and unjustly arrested and detained government leaders, politicians, human rights defenders, journalists, and religious leaders, thereby rejecting the will of the people of Burma as expressed in elections held in November 2020 and undermining the country's democratic transition and rule of law, constitutes an unusual and extraordinary threat to the national security and foreign policy of the United States and declared a national emergency to deal with that threat.
OFAC is issuing the Burma Sanctions Regulations, 31 CFR part 525 (the “Regulations”), to implement E.O. 14014, pursuant to authorities delegated to the Secretary of the Treasury in E.O. 14014. A copy of E.O. 14014 appears in appendix A to this part.
The Regulations are being published in abbreviated form at this time for the purpose of providing immediate guidance to the public. OFAC intends to supplement this part 525 with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licenses, and other regulatory provisions. The appendix to the Regulations will be removed when OFAC supplements this part with a more comprehensive set of regulations.
