Myanmar – European Sanctions Enforcement

September 15, 2026September 15, 2026 by Mark Handley

Norway – investigation into possible breaches of Myanmar sanctions

The Norwegian company Telenor ASA has issued a press release confirming that it is the subject of an ongoing investigation by Norwegian authorities into suspected breaches of sanctions against Myanmar.

The press release notes a police search took place earlier today at the company’s premises and that there has been an ongoing dialogue with the authorities “for a long time”.

The press release also quotes the company’s Media Relations Director as saying:

“Our employees risked imprisonment, torture or the death penalty if the military authorities’ orders were not complied with. This was a very demanding situation in which we found that we had no real choice and that we could not put our employees’ lives at risk”.

A press release from Norway’s National Criminal Investigation Service confirms that the company has been charged both with sanctions offences and human rights related offences.

The investigation relates to the period before the sale of Telenor’s operating subsidiary in Myanmar in 2022 and relates to both the transfer of “historical traffic data on customers” and “sanctioned surveillance equipment”.

September 10, 2024 by Mark Handley

Germany – CJEU rules on appeal against conviction and interpretation of Myanmar sanctions

Further to our earlier post, in 2022 a German individual was convicted of importing timber from Myanmar in breach of EU sanctions and was sentenced to 19 months in jail and a substantial confiscation order of over €3m was also issued.

The case then went on appeal through the German system, and ultimately a referral was made to the Court of Justice of the European Union (“CJEU”).

The argument on the appeals, and for consideration by the CJEU, was that the timber in question underwent sufficient processing in Taiwan, such that it should no longer be considered timber of Myanmarese origin.

The CJEU has ruled that the timber which only underwent “debranching and debarking” was not processed to a level as to amount to a change of origin. The CJEU also held that the timber which was sawn into “wooden cuboids” also did not undergo sufficient processing as to amount to a change of origin.

By contrast the timber which was sawn into finished boards of lumber was held to have undergone sufficient processing to properly be considered of Taiwan origin.

On the referred question of whether the prohibition against goods “exported from Burma/Myanmar” in article 2(2)(a)(ii) of the EU Regulation prohibits imports via third countries, the CJEU held the prohibition “must be interpreted as meaning that that provision covers only goods that have been imported into the European Union directly from Burma/Myanmar“.

It should be noted that this last ruling was in the context of a separate prohibition against the importation of goods which “originate in Burma/Myanmar”, with the court ruling that this other provision was the one which caught imports via third countries.

The German courts will now need to apply these findings to the existing conviction.

November 17, 2022September 10, 2024 by Mark Handley

Germany – conviction for importing timber from Myanmar referred to CJEU

A referral to the Court of Justice of the European Union has revealed a conviction in Germany arising from the importation of timber from Myanmar in breach of the EU’s sanctions.

The defendant was convicted and given a sentence of 19 months in prison and a confiscation order of €3,310,902.98 was imposed as well.

The case has been referred to the CJEU because the defendant argues that the timber in question should properly be seen as having been imported from Taiwan, and not Myanmar, because the timber had been processed in Taiwan.

Update: The CJEU case was registered on 8 February 2023.