EU Must Expand Burma/Myanmar Oil and Gas Sector Sanctions

Joint Statement by European Advocacy Organisations

EU Must Expand Burma/Myanmar Oil and Gas Sector Sanctions

On the eve of European Foreign Ministers’ expected annual rollover of European Union targeted sanctions on the Burmese military, we the undersigned European civil society organisations call on the European Union to expand sanctions targeting oil and gas revenue reaching the Burmese military.

The European Union (EU) must extend its sanctions framework on Burma to cover the entire oil and gas extraction supply chain, including service companies, financial intermediaries, insurers, accreditation providers and engineering contractors.

The EU has already recognised the central role of the oil and gas sector in sustaining the Burmese military. In February 2022, the Council sanctioned the Myanma Oil and Gas Enterprise (MOGE), noting that:

“MOGE is thus controlled by and generates revenue for the Tatmadaw, therefore contributing to its capabilities to carry out activities undermining democracy and the rule of law in Myanmar/Burma.” The EU further emphasised that MOGE acts as the operator, service provider and regulator of the oil and gas sector, overseeing exploration, production and gas transmission while collecting taxes and profits from private partners.

This reasoning clearly demonstrates that the oil and gas sector is a major source of revenue for the Burmese military and that participation by private companies enables this revenue stream. Oil and gas revenues not only bolster a ruthless dictatorship but directly fund war crimes and human rights abuses against civilians in Burma.

However, the current sanctions regime leaves significant loopholes. While MOGE itself is sanctioned, European companies may still provide technical, engineering, certification, insurance and financial services. These services allow gas projects to continue operating and generating revenue for the Burmese military.

For example, the Cyprus-registered company Energy Holdings Limited (https://www.energyholdings.cy/) illustrates the type of EU-linked corporate structures that may participate in or facilitate activities connected to Burma’s gas industry. It is currently working on the Zawtika gas field in Burma, under a contract with the Thai company, PTT Exploration and Production Public Company Limited (PTTEP). This clearly shows even where companies are not directly managing fields, or directly working with MOGE, their services support infrastructure, operations and provide investment that MOGE and the Burmese military benefit from.

The EU’s own reasoning for sanctioning MOGE should logically apply to such companies. If an entity generates or facilitates revenue for the Burmese military through the oil and gas sector, then it contributes to the regime’s ability to sustain its campaign of repression. Service companies and intermediaries are an integral part of the same value chain.

Another concern is the lack of transparency surrounding service provision in the sector. Insurance, certification, auditing and accreditation services are particularly opaque. In many cases it is unclear which firms are underwriting projects, providing risk coverage, certifying operations or supporting compliance functions. Without targeted sanctions covering these services, the EU cannot know the full extent of possible European involvement in sustaining the Burmese military’s gas revenue.

To ensure that EU sanctions achieve their intended effect, the EU must:

Expand sanctions to cover the entire Burma oil and gas extraction supply chain, including service providers and intermediaries.

Introduce restrictions on insurance, reinsurance, certification, engineering and financial services linked to the sector.

Improve transparency and due-diligence requirements to identify EU-based companies facilitating oil and gas sector operations.

Investigate EU-registered entities that may be directly or indirectly involved in supporting Burma’s oil and gas industry.

Without such measures, the sanctions on MOGE risk being undermined by the continued involvement of international service providers that prop up the oil and gas sector and bankroll the Burmese military.

The people of Burma face unrelenting human rights abuses and violations of international law committed by the Burmese military. The European Union can and must do more to cut the flow of arms and revenue to the Burmese military, and ensure no European companies are involved in the gas sector in Burma.

Signed by the following organisations:

Burma Action Ireland

Burma Campaign UK

Burmese Rohingya Organisation UK

Doh Atu – Ensemble pour le Myanmar

German Solidarity with Myanmar e.V.

Info Birmanie

Italia-Birmania.Insieme

Myanmar (CRPH) Support Group, Norway

Netherlands-Myanmar Solidarity Platform

Swedish Burma Committee