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A new joint report by EarthRights International and Global Witness finds that U.S., U.K., and EU sanctions policy has been undermined by poor coordination and a lack of high-impact targets.

February 1, 2023, Washington, D.C.–The U.S., U.K., and EU have relied on targeted economic sanctions as a key part of their response to the 2021 coup that saw Myanmar’s military attempt to seize power from the democratically elected government. Targeted sanctions have the potential to cut the junta’s access to money while making it more difficult for the junta to acquire weapons, ammunition, and jet fuel – the items it needs to maintain the war machine that it has turned on the people of Myanmar. U.S., U.K., and EU policymakers have highlighted the need to go after high-impact sanctions targets and the importance of coordination in order to maximize the effects of their sanctions.

However, a new report, Missed Opportunities: The Need for a Better Approach to Sanctions in Response to Myanmar’s Military Coup, shows clearly that U.S., U.K., and EU authorities have fallen short on both counts with their post-coup sanctions policies.

While they tout the importance of close coordination, the report finds that two-thirds of the 165 distinct sanctions since the coup have been unilateral, meaning they have only been imposed by one of the U.S., U.K., or EU. Only 22 (13 percent) of targets have been sanctioned by all three.

“Coordination failures create gaps in sanctions programs that allow the Myanmar military to evade international pressure,” said Keel Dietz, Myanmar Policy Consultant for Global Witness. “The international community has not responded to the pro-democracy movement’s repeated calls for more impactful, strategic use of sanctions.”

Failures of coordination are compounded by the fact that the U.S., U.K., and EU have largely left the most potentially impactful targets unsanctioned. For example, the EU has placed sanctions on the Myanma Oil and Gas Enterprise (MOGE), which collects revenues from offshore gas projects and is now under the control of the junta. The U.S. and U.K., however, have not sanctioned MOGE, which has undermined the successes of EU sanctions and left the junta with access to its largest source of foreign currency. On Jan 31, 2023, the U.S. did sanction the Managing and Deputy Managing Directors of MOGE, a move unlikely to meaningfully impact junta revenues. This underlines the lack of strategic vision in U.S. policy, which clearly recognizes the importance of MOGE but remains unwilling to do more than half-measures to address it.

All three have also failed to pursue other high-impact targets in a coordinated manner. Aviation fuel, which a recent report by Amnesty International linked to the junta’s bombing campaigns and called to be suspended, has not yet been targeted. A clear model already exists for how this would be done – the U.S., U.K., and EU should ban the provision of financial and other services to companies and ships moving fuel to Myanmar. This would mirror actions in response to Russia’s invasion of Ukraine and Western attempts to stop Russia from profiting from the sale of oil transported by ship.

“The U.S., U.K., and EU are self-inflicting damage on their own Myanmar sanctions regimes,” said Kirk Herbertson, Senior Policy Advisor for EarthRights. “How can governments expect to have an effective sanctions program when they can’t coordinate and refuse to sanction the highest-impact targets? They have set themselves up for failure.”

The report contains further findings about the lack of coordination and avoidance of high-impact targets, including:

  • Approximately half of U.S. and EU post-coup sanctions have been imposed unilaterally.
  • The U.S. and EU have been relatively comprehensive in sanctioning the 20 members of the junta’s ruling State Administration Council (SAC), but the U.K. has only sanctioned.
  • Eleven (39 percent) of the junta’s 28 cabinet-level ministers have not been sanctioned, while a further nine (29 percent) have been sanctioned by only one of the U.S., U.K., and EU.
  • In spite of an identified interest in targeting arms networks, the U.S., U.K., and EU have barely touched the junta’s arms dealers and have been inconsistent in the scope of their sanctions even when targeting the same networks.
  • The U.S., U.K., and EU have all sanctioned the SAC itself, but a lack of clarity around the scope of these sanctions has given space for international organizations and companies to engage with SAC representatives and do business with SAC-controlled entities. 

The failures of their sanctions strategies have also undermined broader U.S., U.K., and EU policies toward Myanmar since the coup. Leaders of the pro-democracy movement and members of Myanmar civil society have consistently called on all three to use sanctions more strategically, and the refusal of the U.S., U.K., and E.U. to follow these requests undercuts the authority of the movement. 

It also hurts efforts to get ASEAN members and other regional partners like India and Japan to take a harder line toward Myanmar. The U.S., U.K., and EU are asking these countries to make difficult political decisions in rejecting the junta and opposing its purported plans to hold sham elections this summer. Yet as this report shows, the U.S., U.K., and EU have been unwilling or unable to take meaningful actions that would actually reduce the junta’s ability to operate.

“If the U.S., U.K., and EU – the pro-democracy movement’s most vocal supporters – are too cautious to implement a serious sanctions strategy, how can Myanmar’s neighbors, who have much more at stake in the conflict, be expected to take bold policy actions?” added Dietz.

Read the report here.


Kate Fried, EarthRights International
(202) 257.0057 

Maxine Sackey, Global Witness