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Priority review Notice Added Final

OFAC Notice: Persons Added to SDN List

Favicon for www.regulations.gov Regs.gov: Office of Foreign Assets Control
Published November 12th, 2025
Detected March 14th, 2026
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Summary

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has added individuals to the Specially Designated Nationals (SDN) List. These designations block all property and interests in property subject to U.S. jurisdiction and prohibit U.S. persons from transacting with them.

What changed

The Office of Foreign Assets Control (OFAC) has issued a notice adding two individuals, Saw San Aung and Sai Kyaw Hla, to the Specially Designated Nationals (SDN) List. These designations are based on their alleged involvement with the Democratic Karen Benevolent Army and malicious cyber-enabled activities, as well as actions threatening the peace, security, or stability of Burma. Their property and interests in property subject to U.S. jurisdiction are now blocked.

U.S. persons are generally prohibited from engaging in transactions with these designated individuals. Compliance officers should review the updated SDN List and ensure that any dealings with these individuals or entities linked to them are ceased immediately. Failure to comply with sanctions regulations can result in significant penalties.

What to do next

  1. Review updated SDN List for Saw San Aung and Sai Kyaw Hla.
  2. Ensure no transactions are conducted with designated individuals or their linked entities.
  3. Update internal compliance systems to reflect these sanctions.

Penalties

All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. Penalties for non-compliance with OFAC sanctions can be severe.

Source document (simplified)

Content

ACTION:

Notice.

SUMMARY:

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons
that have been placed on OFAC's Specially Designated Nationals and Blocked Persons List (SDN List) based on OFAC's determination
that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction
of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.

DATES:

This action was issued on November 12, 2025. See Supplementary Information for relevant dates.

FOR FURTHER INFORMATION CONTACT:

OFAC: Associate Director for Global Targeting, 202-622-2420; Assistant Director for Sanctions Compliance, 202-622-2490 or https://ofac.treasury.gov/contact-ofac.

SUPPLEMENTARY INFORMATION:

Electronic Availability

The SDN List and additional information concerning OFAC sanctions programs are available on OFAC's website: https://ofac.treasury.gov.

Notice of OFAC Action

On November 12, 2025, OFAC determined that the property and interests in property subject to U.S. jurisdiction of the following
persons are blocked under the relevant sanctions authorities listed below.

Individuals

  1. AUNG, Saw San (a.k.a. AUNG, Saw Sang; a.k.a. “AUNG, San”), Burma; DOB 28 Jul 1968; nationality Burma; Gender Male (individual) [BURMA-EO14014] CYBER4.

Designated pursuant to section 1(a)(iii)(D) of Executive Order 14014 of February 10, 2021, “Blocking Property With Respect
to the Situation in Burma,” 86 FR 9429, 3 CFR, 2021 Comp. p. 514 (E.O. 14014), for being or having been a leader or official
of DEMOCRATIC KAREN BENEVOLENT ARMY, an entity whose property and interests in property are blocked pursuant to E.O. 14014
as a result of activities related to the leader's or official's tenure.

Designated pursuant to section 1(a)(iii)(F) of Executive Order 13694 of April 1, 2015, “Blocking the Property of Certain Persons
Engaging in Significant Malicious Cyber-Enabled Activities,” 80 FR 18077, 3 CFR, 2015 Comp., p. 297, as amended by Executive
Order 13757 of December 28, 2016, “Taking Additional Steps to Address the National Emergency With Respect to Significant Malicious
Cyber-Enabled Activities,” 82 FR 1, 3 CFR, 2016 Comp., p. 659, and as further amended by Executive Order 14144 of January
16, 2025, “Strengthening and Promoting Innovation in the Nation's Cybersecurity,” 90 FR 6755, and Executive Order 14306 of
June 6, 2025, “Sustaining Select Efforts To Strengthen the Nation's Cybersecurity and Amending Executive Order 13694 and Executive
Order 14144,” 90 FR 24723 (E.O. 13694, as further amended), for being or having been a leader, official, senior executive
officer, or member of the board of directors of DEMOCRATIC KAREN BENEVOLENT ARMY, a person whose property and interests in
property are blocked pursuant to E.O. 13694, as further amended.

  1. HLA, Sai Kyaw (a.k.a. SAI, Ko), Burma; DOB 06 Sep 1971; nationality Burma; Gender Male; Passport MB941865 (Burma); National ID No. 13MasakaN024010 (Burma) (individual) [BURMA-EO14014] CYBER4.

Designated pursuant to section 1(a)(ii)(B) of E.O. 14014 for being responsible or complicit in, or having directly or indirectly
engaged or attempted to engage in, actions or policies that threaten the peace, security, or stability of Burma.

Designated pursuant to section 1(a)(iii)(C) of E.O. 13694, as further amended, for having materially assisted, sponsored,
or provided financial, material, or technological support for, or goods and services to or in support of, cyber-enabled activities
originating from, or directed by persons located, in whole or in substantial part, outside the United States that is reasonably
likely to result in, or has materially contributed to, a threat to the national security, foreign policy, or economic health
or financial stability of the United States, and that has the purpose of or involves causing a misappropriation of funds or
economic resources, intellectual property, proprietary or business confidential information, personal identifiers, or financial
information for commercial or competitive advantage or private financial gain.

  1. SAWANG, Chamu (a.k.a. MOOSAWAN, Naija; a.k.a. SAVANG, Cha Mu; a.k.a. YU, Jianjun), Thailand; DOB 01 Jan 1964 to 17 Feb 1964; nationality Thailand; Gender Male; Passport Z992106 (Thailand) expires 26 Feb 2017 (individual) [BURMA-EO14014] CYBER4.

Designated pursuant to section 1(a)(iii)(D) of Executive Order 14014 for being or having been a leader or official of TRANS
ASIA INTERNATIONAL HOLDING GROUP THAILAND COMPANY LIMITED, an entity whose property and interests in property are blocked
pursuant to E.O. 14014 as a result of activities related to the leader's or official's tenure.

Designated pursuant to section 1(a)(iii)(F) of E.O. 13694, as further amended, for being or having been a leader, official,
senior executive officer, or member of the board of directors of TRANS ASIA INTERNATIONAL HOLDING GROUP THAILAND COMPANY LIMITED,
a person whose property and interest in property are blocked pursuant to E.O. 13694, as further amended.

  1. STEEL, Saw, Burma; DOB 27 Mar 1961; nationality Burma; Gender Male (individual) [BURMA-EO14014] CYBER4.

Designated pursuant to section 1(a)(iii)(D) of Executive Order 14014 for being or having been a leader or official of DEMOCRATIC
KAREN BENEVOLENT ARMY, an entity whose property and interests in property are blocked pursuant to E.O. 14014 as a result of
activities related to the leader's or official's tenure.

Designated pursuant to section 1(a)(iii)(F) of E.O. 13694, as further amended, for being or having been a leader, official,
senior executive officer, or member of the board of directors of DEMOCRATIC KAREN BENEVOLENT ARMY, a person whose property
and interest in property are blocked pursuant to E.O. 13694, as further amended.

  1. WIN, Saw Sein (a.k.a. “WIN, Sein”), Burma; DOB 15 Aug 1965; nationality Burma; Gender Male (individual) [BURMA-EO14014] CYBER4.

Designated pursuant to section 1(a)(iii)(D) of Executive Order 14014 for being or having been a leader or official of DEMOCRATIC
KAREN BENEVOLENT ARMY, an entity whose property and interests in property are blocked pursuant to E.O. 14014 as a result of
activities related to the leader's or official's tenure.

Designated pursuant to section 1(a)(iii)(F) of E.O. 13694, as further amended, for being or having been a leader, official,
senior executive officer, or member of the board of directors of DEMOCRATIC KAREN BENEVOLENT ARMY, a person whose property
and interest in property are blocked pursuant to E.O. 13694, as further amended.

Entities

  1. DEMOCRATIC KAREN BENEVOLENT ARMY (a.k.a. DEMOCRATIC KAREN BUDDHIST ARMY; a.k.a. DEMOCRATIC KAREN BUDDHIST ARMY BRIGADE 5; a.k.a. KALOH HTOO BAW ARMED GROUP; a.k.a. KAREN KLO HTOO BAW ORGANIZATION; a.k.a. KLO HTOO BAW BATTALION; a.k.a. “DKBA”; a.k.a. “DKBA 5”; a.k.a. “KKO”), Sone See Myaing Village, Myawaddy, Karen State, Burma; Organization Established Date 08 Nov 2010; Target Type Armed Group [BURMA-EO14014] [CYBER4].

Designated pursuant to section 1(a)(ii)(B) of E.O. 14014 for being responsible or complicit in, or having directly or indirectly
engaged or attempted to engage in, actions or policies that threaten the peace, security, or stability of Burma.

Designated pursuant to section 1(a)(iii)(C) of E.O. 13694, as further amended, for having materially assisted, sponsored,
or provided financial, material, or technological support for, or goods and services to or in support of, cyber-enabled activities
originating from, or directed by persons located, in whole or in substantial part, outside the United States that is reasonably
likely to result in, or has materially contributed to, a threat to the national security, foreign policy, or economic health
or financial stability of the United States, and that has the purpose of or involves

  causing a misappropriation of funds or economic resources, intellectual property, proprietary or business confidential information,
  personal identifiers, or financial information for commercial or competitive advantage or private financial gain.
  1. TRANS ASIA INTERNATIONAL HOLDING GROUP THAILAND COMPANY LIMITED (a.k.a. HUANYA INTERNATIONAL HOLDING GROUP), 100/20 Prasat Withee Road, Mae Sot, Tak 63110, Thailand; Organization Established Date 24 Feb 2020; Organization Type: Non-specialized wholesale trade; Registration Number 0635563000201 (Thailand) [BURMA-EO14014] [CYBER4]. Designated pursuant to section 1(a)(ii)(B) of E.O. 14014 for being responsible or complicit in, or having directly or indirectly engaged or attempted to engage in, actions or policies that threaten the peace, security, or stability of Burma.

Designated pursuant to section 1(a)(iii)(C) of E.O. 13694, as further amended, for having materially assisted, sponsored,
or provided financial, material, or technological support for, or goods and services to or in support of, cyber-enabled activities
originating from, or directed by persons located, in whole or in substantial part, outside the United States that is reasonably
likely to result in, or has materially contributed to, a threat to the national security, foreign policy, or economic health
or financial stability of the United States, and that has the purpose of or involves causing a misappropriation of funds or
economic resources, intellectual property, proprietary or business confidential information, personal identifiers, or financial
information for commercial or competitive advantage or private financial gain.

  1. TROTH STAR COMPANY LIMITED (a.k.a. “TRUST STAR COMPANY LIMITED”), No. 19, Ward No. 2, Pai Kyone, Hlaingbwe, Burma; Organization Established Date 2022; Organization Type: Construction of buildings; Registration Number 132583269 (Burma) [BURMA-EO14014] [CYBER4].

Designated pursuant to section 1(a)(ii)(B) of E.O. 14014 for being responsible or complicit in, or having directly or indirectly
engaged or attempted to engage in, actions or policies that threaten the peace, security, or stability of Burma.

Designated pursuant to section 1(a)(iii)(C) of E.O. 13694, as further amended, for having materially assisted, sponsored,
or provided financial, material, or technological support for, or goods and services to or in support of, cyber-enabled activities
originating from, or directed by persons located, in whole or in substantial part, outside the United States that is reasonably
likely to result in, or has materially contributed to, a threat to the national security, foreign policy, or economic health
or financial stability of the United States, and that has the purpose of or involves causing a misappropriation of funds or
economic resources, intellectual property, proprietary or business confidential information, personal identifiers, or financial
information for commercial or competitive advantage or private financial gain.

Bradley T. Smith, Director, Office of Foreign Assets Control. [FR Doc. 2026-04652 Filed 3-9-26; 8:45 am] BILLING CODE 4810-AL-P

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Classification

Agency
Various Federal Agencies
Published
November 12th, 2025
Instrument
Notice
Legal weight
Binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Importers and exporters Financial advisers Investors Public companies Manufacturers
Geographic scope
US

Taxonomy

Primary area
Sanctions
Operational domain
Compliance
Topics
Burma Cybersecurity

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