26 October 2023

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We are writing to you because your institution has reportedly held correspondent accounts in one or more Myanmar financial institutions now under the control of the military junta: the Myanma Foreign Trade Bank (MFTB), Myanma Investment and Commercial Bank (MICB), Innwa Bank Limited, Myawaddy Bank Limited, and/or Asia Green Development (AGD) Bank.

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We request that your institution responds to the following questions. We will post this letter, along with your response, on the website of the Business and Human Rights Resource Centre, www.business-humanrights.org.

• What steps has your institution taken to prevent sanctioned members of the junta and sanctioned entities under the de facto control of the junta from accessing accounts held at your institution?
• What is your institution’s policy with respect to accounts for any unsanctioned individuals or entities known or suspected by your institution to have assisted the junta in sanctions evasion?
• Has your institution implemented safeguards to avoid participating in or facilitating the junta’s efforts to circumvent sanctions? Please note that common junta sanctions evasion tactics include channeling funds through non-sanctioned individuals and entities and converting funds to different currencies?
• What measures has your institution taken to implement the United States’ August 2023 determination that allows for sanctions to be imposed on any foreign individual or entity determined to operate in the jet fuel sector of the Burmese economy?
• How has your institution integrated the United States’ January 2022 business advisory on Burma into its due diligence procedures?
• What measures are being implemented to ensure that humanitarian aid and access is being received in Myanmar and that civilians are able to access banking services and to safeguard against de-risking?

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