BIS Entity List: Four Burma-Based Entities Supporting SAC Military Coup

Mechanism

BIS exercised its authority under EAR Part 744.11(b) to designate entities acting contrary to U.S. foreign policy and national security interests. The listings are Burma-destination entries under Supplement No. 4 to Part 744.

King Royal Technologies Co., Ltd. (a.k.a. KRT): Listed for providing satellite communication services to Burma's military. Satellite links are operationally critical for the SAC's command-and-control, surveillance, and battlefield communications following the February 1, 2021 coup.

Myanmar Wanbao Mining Copper, Ltd.; Myanmar Yang Tse Copper, Ltd.; Wanbao Mining, Ltd.: These three entities operate the Letpadaung copper mine project in the Sagaing Region — a joint venture between Chinese state-linked Wanbao Mining and MEHL (Myanmar Economic Holdings Limited). MEHL, the SAC's principal commercial arm, channels a share of mining revenues to Burma's Ministry of Defence. BIS treats MEHL-linked revenue sharing as indirect material support for the coup government.

Correction: The rule also corrected the address for Myanmar Economic Corporation (MEC), which had been listed on March 8, 2021, updating its geographic designation to "Burma."

License controls

Context: SAC commercial network

The SAC military junta relies on two principal commercial conglomerates — MEHL and Myanmar Economic Corporation (MEC) — to fund military operations and circumvent financial pressure. BIS's approach of targeting entities in revenue-sharing arrangements with MEHL extended export-control pressure to the junta's copper royalty stream, complementing contemporaneous Treasury/OFAC sanctions on MEHL and MEC issued under Executive Order 14014 (February 10, 2021, "Blocking Property With Respect to the Situation in Burma").

The Letpadaung mine is the largest copper mine in Myanmar and one of MEHL's most significant commercial assets. Its Chinese operator (Wanbao, a subsidiary of CITIC Group) had been a source of domestic controversy in Myanmar due to land confiscations and a 2012 crackdown on protesters; post-coup, it became a focal point for U.S. economic-pressure measures.

Downstream implications

• Cuts U.S. dual-use technology pathways (electronics, satellite ground equipment, mining

machinery subject to EAR) to Wanbao's Myanmar operations.

• MEHL revenue-sharing theory of liability previews BIS's later broader use of Entity List

designations to target revenue streams for sanctioned militaries (cf. similar logic in Russia energy-sector entity additions post-February 2022).

• KRT listing signals that satellite-communications providers for coup/authoritarian

governments are within BIS's Entity List theory of harm, a precedent invoked in later designations under the Burma and Russia programs.

Open questions

• Whether Wanbao Mining's parent (CITIC Group) faces secondary pressure given U.S. person

supply links to the Letpadaung project.

• Status of POSCO International's adjacent gas joint venture with MOGE — not listed here

but under growing pressure from civil society (addressed in the OFAC Directive 1 track, 2023-2024).