U.S. Removes Theint Win Htet From Myanmar-Related Sanctions List

Theint Win Htet was originally designated on January 31, 2024, under the U.S. Burma-related sanctions program and was removed recently.

Why was the family originally sanctioned?

In January 2024, the U.S. Treasury designated Thein Win Zaw, his company Shwe Byain Phyu Group of Companies, and several family members.

The Treasury said Thein Win Zaw’s business activities included importing and distributing petroleum for Myanmar’s military-linked economic network. His daughter, Theint Win Htet, was designated because she was an adult child of a person already subject to sanctions.

The October 2026 update confirms her removal from the SDN List. However, OFAC’s list update does not provide a detailed explanation for the decision.

Importantly, her removal does not mean that all related individuals or companies have been delisted. Compliance teams must check the current status of each person and entity separately.

Implications for Compliance Teams

This development highlights several practical sanctions-compliance priorities:

• Keep screening data current: Update screening systems promptly when OFAC publishes additions or removals.
• Reassess potential matches: Review alerts against the latest official list to avoid treating a removed person as currently designated solely because of outdated data.
• Check related parties separately: A family member’s removal does not automatically remove sanctions on associated individuals, businesses or entities that remain listed.
• Maintain audit trails: Record list updates, screening decisions and the rationale for closing or reopening alerts.
• Continue risk-based due diligence: Delisting alone does not eliminate every potential financial-crime or reputational risk.

The case demonstrates that sanctions compliance requires ongoing monitoring, not just screening customers when relationships begin. Financial institutions need accurate, regularly updated data and clear procedures for handling both new designations and removals.