Max Myanmar and its subsidiaries were only removed from the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list in October 2016 – three years after Accor started doing business with Max Myanmar’s Max Hotels Group. In its report to the 42nd Session of the UN Human Rights Council on September 9-27, 2019, the Independent International Fact-Finding Mission on Myanmar concludes that: “… the Mission now has reasonable grounds to also conclude that officials from KBZ Group and Max Myanmar should be criminally investigated and, if appropriate, prosecuted for making a substantial and direct contribution to the commission of the crime against humanity of ‘other inhumane acts’ and persecution as outlined above in the applicable legal…