On July 11, 2012, the U.S. Government announced a partial waiver of the ban on new investments in Myanmar. Instead of being prohibited, Americans are allowed to invest in Myanmar but will be required to provide annual reports on their policies and procedures for human rights, environmental management, labor standards, land acquisition, and anti-corruption. These reports are meant to be mostly available for public consumption. ERI submitted this Comment as part of the Paperwork Review Act approval process for the Reporting Requirements. In it, ERI recommends 1) that the Reporting Requirements should clearly apply to the operations of investors’ business partners and related entities over which they have significant influence, and 2) that the Reporting Requirements should not allow investors to self-designate information as confidential business information that can be withheld from the public.

ERI also recommends reporting according to widely accepted international standards and frameworks and provides detailed Guidance in this respect in the Annexes to the Comment. These Annexes are presented here in separate form as well and can be used as a stand-alone resource.