Changeflow GovPing Trade & Export Myanmar Humanitarian Activity General Licence
Priority review Guidance Added Final

Myanmar Humanitarian Activity General Licence

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Detected March 6th, 2026
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Summary

The UK has issued a General Licence (INT/2025/8257372) under the Myanmar (Sanctions) Regulations 2021 and the Global Human Rights Regulations 2020. This licence exempts certain 'Relevant Persons' from prohibitions when carrying out activities necessary for humanitarian assistance and supporting basic human needs in Myanmar.

What changed

This General Licence (INT/2025/8257372) provides an exemption from sanctions prohibitions under the Myanmar (Sanctions) Regulations 2021 and the Global Human Rights Regulations 2020. It permits 'Relevant Persons', including UK-funded organisations, UN entities, humanitarian organisations, and their implementing partners, to conduct activities necessary for humanitarian assistance and supporting basic human needs in Myanmar. This includes the provision of funds, economic resources, goods, and services, provided the Relevant Person believes these actions are necessary and has no reasonable cause to suspect otherwise.

Compliance officers should review the definitions of 'Designated Person', 'Relevant Person', and 'Relevant Activities' to determine applicability. While this licence facilitates essential humanitarian work, it is crucial to ensure all activities strictly relate to Myanmar and adhere to the conditions outlined. The licence does not specify a compliance deadline, but regulated entities must ensure their actions align with the licence's permissions and conditions to avoid breaching sanctions. No specific penalties are detailed within the licence itself, but non-compliance with underlying sanctions regulations would carry significant consequences.

What to do next

  1. Review definitions of 'Designated Person', 'Relevant Person', and 'Relevant Activities'.
  2. Ensure all humanitarian activities and support for basic human needs strictly relate to Myanmar.
  3. Verify that any funds, economic resources, goods, or services provided are necessary for timely delivery of assistance and comply with licence conditions.

Source document (simplified)

GENERAL LICENCE: MYA NMAR HUMA NITARIAN ACTIVITY INT/2025/ 8257372 1. This licence is granted under regulation 4 4 of Th e Myanmar (Sanctio ns) Regulation s 2 021 (the “Myanmar Re gulations”) and under regulat ion 20 of T he Glob al Human Rights (Sanctions) Regul ations 2020 (“ the Global Human Rights Regulations ”). 2. Any act which would otherwis e breach the proh ibitions in r egulations 11-15 of the Myanmar Regulations and regulations 11 - 15 of th e Global Human Rights Regulations is exempt from tho se prohibition s as set out below. 3. In this licence: “Designated Person ” means Any person design ated under the M yanmar Regulations and/or th e Global Human Rights Regulations. “Relevant Person” means Any UK Funded Person; The United Na tions, including its p rogrammes, fun ds and other entiti es and bodies, and its specialised agencies and r elated organisations; Humanitarian o rganisations having o bserver status with the United Nations General A ssembly and members of tho se humanitarian or ganisations; Bilaterally or mult ilaterally funded non-gov ernmental organisations p articipating in th e United Nation s Humanitarian Re sponse Plans, Refugee Response Plans, other Unit ed Nations appeals, o r humanitarian clusters coordinate d by the United Nations Office for the Coordination of Humanitarian Af fairs; International organis ations carr ying out humanitari an assistance and o ther activities that suppo rt basic human needs in Myanmar; The Disasters E mergency Committee; Any employee, g rantee, subsidiary, or implementin g partner of any or ganisation fallin g within the above list while and to th e extent that they are acting in those capaciti es. Any persons provi ding goods or services to any of the persons listed above including but not li mited to the provision, proces sing and payment of funds or economic resou rces and makin g available digital technologies. “UK Funded Person ” means Any organisation that receives, or ha s received in t he last 5 years, fund ing from any part of the Government of th e United Kingdo m for the purpose of providing hu manitarian assis tance or supporting basic human ne eds.

“Relevant Activities” mea ns Activities necess ary to provide hu manitarian assistance, oth er activities that su pport basic human needs and facilit ate the timely provi sion of those activities in Myanma r. This includes th e provision, proces sing and payme nt of funds, or econo mic resou rces, and the provision of goods and servi ces necessary to ensure the timely delivery of such assistance or to suppor t such activities which must solely relate to Myanmar. “Relevant Institution ” means A person that has permission under P art 4A of the Financial Services and Markets Act 2000 (permission to carry on regul ated activity). A person that is authorised or regis tered under Pa rt 2 of the Payment Services Regula tions (SI 2017/7 52). A person that is authorised or regis tered under Pa rt 2 of the Electron ic Money Regula tions (SI 2011/9 9). A person that is a “recogn ised clearing hous e”, “third country central counterparty”, “r ecognised CSD” or “third country CSD” for the pu rposes of s.285 of th e Financial Services and Markets Act 2000. A person that is an operator of a recognised pay ment sy stem (or tha t is a service provi der in relation to recognised pay ment systems) fo r the purposes of Part 5 of the Bankin g Act 2009. Permissions 4. U nder this licence, sub ject to the condit ions in paragra ph 5 and 6, a R elevant Person may perform th e Relevant Activities provid ed that the Relevant Person believ es that carrying out th e Relevant Activiti es is necessary to p rovide humanitarian a ssistance, other activities that suppo rt basic human needs and facilit ate the timely provis ion of that assistance or those acti vities in Myanmar and there i s no reasonable caus e for the Relevant Person to suspect othe rwise. 5. An y funds used to effe ct the permissions s et out in paragraph 4 must not b e from funds or economic resou rces that are owned, held or con trolled by a Designated Person. 6. The permission set out in paragraph 4 does not p ermit the use of econo mic resources owned, held or controlled by a D esignated Person except where a Designated P erson has received fu nds, goods or servic es in exchange fo r those econo mic resources from a Relevant Person to perform Relev ant Activities. 7. Any Relevant In stitution may carry out any activity n ecessary to effect the permi ssions listed in paragraph 4, subject to para graph 5 and 6. Notification Re quirement 8. A Relev ant Person condu cting Relevant Act ivities in Myanmar in acco rdance with paragraphs 4, 5 and 6 above must provi de written notice to HM Treasury within 30 days of commencing the activity. Notification may be pro vided by email to ofsi@hmtreasu ry.gov.uk and should inclu de the required deta ils about the R elevant Person (i.e. the o rganisation name, a ddress, and con tact information).

  1. Notifi cation provided in accordance with pa ragraph 8 above doe s not constitute verification by HM Treasury that act ivity purporting to be permitted under this licence is permitted. General 10. The pe rmissions in this lic ence are without pr ejudice to the pe rmissions provi ded by any other licence, whether general or in respect of par ticular acts, that h ave been or may be issued by HM T reasury from tim e to time. 11. The pe rmissions in this lic ence do not authoris e any act which the person carrying ou t the act knows, or has reasonable grou nds for suspe cting, will result in a breach of th e Myanmar Regulation s or the Global Human R ights Regulation s, save as permitted un der licences grant ed under th os e Regulation s. 12. Information pro vided to HM Tre asury in connection with this licence shall be disclosed to third parties onl y in compliance with the UK G eneral Data Prote ction Regulation and the Data Prot ection Act 2018. 13. This licence tak es effect from 19 D ecember 2025. 14. HM Treasury may vary, revo ke or suspend this licence at any ti me. Signed: Office of Financial Sanctio ns Implementation HM Treasury 19 Decembe r 202 5.

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
Various
Instrument
Guidance
Legal weight
Binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Government agencies Nonprofits Insurers
Geographic scope
Myanmar

Taxonomy

Primary area
Sanctions
Operational domain
Compliance
Topics
Humanitarian Aid International Law

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