Financial Integrity Monitor

Myanmar MM

Domains (D1–D6)
2
Sources
11
Role actions
8
Horizon <90d
1
Jurisdiction profile
Black-ListTier BRisk: IncreasingPermissive

Myanmar remains on FATF's Call for Action (black) list since October 2022; military junta controls AML/CFT institutions post-coup.

MoreNo functioning public beneficial ownership register; jade/gemstone licensing frozen since 2020 but informally exploited. Junta-run FIU capacity degraded by conflict, state capture, and sanctions isolation. Border-region armed groups (BGF/KNA/DKBA) run parallel scam-compound economies with alleged military complicity.

Key deficiencies
  • No public beneficial ownership register; DICA company registry lacks BO disclosure requirements
  • Weak/absent AML supervision of TCSPs, real estate, and DNFBPs amid civil conflict
  • Alleged Border Guard Force/military complicity in protecting cyber-scam compounds (KK Park, Shwe Kokko, Tai Chang, Huanya)
  • Extensive fraud and cyber-scam activity persists despite FATF-cited partial improvements
  • Opaque jade/gemstone extraction sector funding military and armed groups with no chain-of-custody transparency
Recent developments (18m)
  • FATF June 2026 Plenary retained Myanmar on Call for Action list, warning of countermeasures if no further progress by October 2026
  • OFAC designated Karen National Army (May 2025) and Democratic Karen Benevolent Army (Nov 2025) as transnational criminal organizations tied to scam compounds
  • Myanmar military conducted mass raids/demolitions at KK Park and Shwe Kokko, detaining over 70,000 foreign nationals since 2024 per junta claims
  • EU Council extended Myanmar restrictive measures to 30 April 2027, covering 105 individuals and 22 entities
  • UK closed OFSI Consolidated List (28 Jan 2026), consolidating Myanmar designations into the single UK Sanctions List
Brief

Lead signal

Lead Signal

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Lead Signal

Myanmar enacted a new Anti-Money Laundering Law (Law No. 16/2026) on 11 March 2026, replacing the 2014 AML Law and restructuring reporting-organisation obligations across banks, financial institutions, and designated non-financial businesses and professions. The new law introduces strengthened customer due diligence and enhanced due diligence requirements for politically exposed persons and high-risk-jurisdiction counterparties, a five-year record-retention standard, and asset-seizure powers directed at ethnic armed organisations tolerating illicit operations within territory they control. This is architecture, not incident: a wholesale institutional restructuring of Myanmar's AML framework rather than a single enforcement action, and it lands while Myanmar remains on the FATF list of high-risk jurisdictions subject to a call for action, unchanged at the 17-19 June 2026 Plenary. FATF's own posture calls for enhanced due diligence proportionate to risk rather than the fuller countermeasures applied to Iran and the Democratic People's Republic of Korea, a distinction obliged entities should not collapse into a single undifferentiated grey- or black-list treatment.

The practical effect for reporting organisations dealing with Myanmar counterparties is a widened compliance perimeter at the exact moment that unilateral sanctions activity against Myanmar-linked armed-group scam economies is accelerating from Washington, without a corresponding EU or UK listing identified this cycle. The combination of a newly architected domestic AML regime and unresolved implementing rules creates a period in which the letter of the law has moved further than verified practice can yet confirm.

Other Developments

OFAC's escalating sanctions posture against Karen State armed-group scam infrastructure is the clearest sanctions-architecture signal this cycle. Treasury designated the Democratic Karen Benevolent Army, four of its senior leaders, the Thailand-incorporated Trans Asia International Holding Group, Troth Star Co., and an individual named Chamu Sawang for operating or enabling cyber-scam compounds in Myawaddy, Karen State, tied to human trafficking and fraud against United States persons. This November 2025 action follows a May 2025 designation of the Karen National Army, formerly the Karen Border Guard Force, for leasing land to scam syndicates and providing security at compounds including the notorious KK Park. Read together, the two actions describe a pattern rather than an isolated event: armed groups monetising control of border territory by hosting scam-compound economies, with correspondent-banking and trade-finance exposure as the transmission channel into the formal financial system. No equivalent European Union or United Kingdom listing has been identified this cycle, leaving the sanctions response to this specific typology asymmetric across jurisdictions.

The Central Bank of Myanmar's remittance-sector licensing tightening sits adjacent to, but distinct from, the AML Law restructuring. New Offshore Remittance Business Regulations issued 18 May 2026 repeal 2019-era rules and expand licensing and reporting obligations for remittance agents and branch offices, a change with plain implications for the money-service-business channel through which scam-compound proceeds are frequently understood to move.

Myanmar's standing cryptocurrency prohibition was reiterated, not newly created, in a 16 November 2025 Central Bank warning citing money-laundering, scam, and volatility risk, continuing a posture dating to a 2020 notification. This is enablement-by-absence in reverse: rather than a permissive gap enforcement declines to fill, it is a maintained prohibition whose persistence itself signals the authorities' assessment of the money-laundering risk digital assets pose in this specific operating environment.

Cross-Monitor Connections

The scam-compound economy sanctioned by OFAC this cycle sits squarely at the intersection of financial-crime typology and the conflict-finance and state-capture themes tracked elsewhere in this fleet: armed groups exercising territorial control are monetising that control through cyber-fraud infrastructure rather than through the extractive-industry or natural-resource channels more commonly associated with conflict finance, a variant worth flagging for any conflict-finance-focused reader tracking non-traditional revenue streams for non-state armed actors. The correspondent-banking and trade-finance customer typologies named in the OFAC designations also warrant attention from any payments-focused reader tracking cross-border settlement exposure to Southeast Asian scam-corridor jurisdictions.

Outlook

The determinative question for the next assessment period is whether implementing regulations under the 2026 AML Law specify DNFBP scope, particularly whether casinos and other gambling-adjacent or high-cash businesses are brought within designated-reporting-entity status; this was not independently verified this cycle and remains a genuine gap rather than a settled negative. Watch also for whether the European Union or United Kingdom moves to align sanctions coverage with OFAC's Karen State designations, and whether Myanmar's FATF status shifts at a subsequent Plenary now that a wholesale legislative restructuring has occurred, even though implementation and effectiveness remain unverified.

weekly_brief_draft · JID MM
Domain intelligence (D1–D6)

D1 Sanctions Architecture and Evasion

Sanctions

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OFAC's designation activity against Myanmar's Karen State scam-compound economy has escalated over the past year into a recognisable architecture rather than a series of isolated actions. In November 2025, Treasury designated the Democratic Karen Benevolent Army, four senior DKBA leaders, the Thailand-incorporated Trans Asia International Holding Group, Troth Star Co., and an individual, Chamu Sawang, for operating or enabling cyber-scam compounds in Myawaddy, Karen State, tied to human trafficking and fraud against United States persons. This followed a May 2025 designation of the Karen National Army, formerly the Karen Border Guard Force, for leasing land to scam syndicates and providing security services at compounds including KK Park. The structural read is that armed groups exercising de facto territorial control along the Thai border have found a durable revenue model in hosting and protecting scam-compound infrastructure, and that Thailand-incorporated entities are functioning as the front-company layer connecting that infrastructure to formal commerce and banking relationships. Correspondent-banking and trade-finance channels are the customer typologies named in the underlying designations, meaning the exposure for global financial institutions runs through standard cross-border settlement relationships rather than through anything exotic.

What is analytically most significant is the divergence in sanctions coverage: no European Union or United Kingdom listing equivalent to these OFAC designations has been identified this cycle. For institutions operating a sanctions programme calibrated to the union of major sanctioning-authority lists, this divergence matters operationally, not just academically, because screening built only to EU or UK lists would miss designations that a US nexus institution must observe, and vice versa in other typologies. The pattern of unilateral US action against a specific typology, absent multilateral alignment, is itself worth tracking as a recurring feature of the Myanmar sanctions landscape rather than a one-off.

Outlook

The open question is whether the European Union or United Kingdom moves toward parallel designations targeting the same armed groups and front companies, which would close the current coverage gap, or whether the typology remains a US-only sanctions concern for the foreseeable future. Continued OFAC designation activity against additional Karen State-linked entities would be consistent with the pattern already established across the May and November 2025 actions and should be read as architecture-reinforcing rather than as a new departure.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions

Not covered

Enabler Jurisdictions is not yet covered for this jurisdiction in this report.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto / Digital Assets / Financial Innovation

Not covered

Crypto / Digital Assets / Financial Innovation is not yet covered for this jurisdiction in this report.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

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Myanmar's AML/CTF regime underwent a wholesale legislative restructuring this cycle with the enactment of the Anti-Money Laundering Law 2026 (Law No. 16/2026) on 11 March 2026, which repeals and replaces the previous 2014 law. The new law restructures reporting-organisation obligations across banks, financial institutions, and designated non-financial businesses and professions, introduces strengthened customer due diligence and enhanced due diligence requirements specifically for politically exposed persons and high-risk-jurisdiction counterparties, sets a five-year record-retention standard, and grants asset-seizure powers aimed at ethnic armed organisations that tolerate illicit operations within territory under their control. Myanmar's Financial Intelligence Unit has been conducting training and clarification sessions on the new law, consistent with an active, if early-stage, implementation effort. Separately, the Central Bank of Myanmar issued new Offshore Remittance Business Regulations on 18 May 2026, repealing 2019 rules and expanding licensing and AML/CFT compliance obligations for remittance agents and branch offices, a sector-specific tightening that complements the broader statutory restructuring.

This architectural overhaul occurs while Myanmar remains on the FATF list of high-risk jurisdictions subject to a call for action, a status unchanged at the 17-19 June 2026 Plenary. FATF's assessment calls for enhanced due diligence proportionate to risk, a materially lighter designation than the full countermeasures FATF applies to Iran and the Democratic People's Republic of Korea, and that distinction should be preserved in any institutional risk-rating methodology rather than collapsed into a single blacklist treatment. The juxtaposition of a newly rewritten AML statute against an unchanged FATF blacklist status is itself the analytically interesting fact: legislative architecture has moved, but FATF has evidently not yet seen sufficient implementation evidence to alter Myanmar's list position, and the DNFBP scope of the new law, including whether casinos or other cash-intensive businesses are captured, has not been independently verified this cycle.

Outlook

The key indicator to watch is whether implementing regulations under the 2026 AML Law clarify DNFBP scope and CDD thresholds, and whether that implementation, once verified, is sufficient to move Myanmar's status at a subsequent FATF Plenary. Absent verified implementation evidence, the gap between statutory architecture and demonstrated effectiveness should be treated as the operative risk factor for any institution assessing Myanmar counterparty exposure.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon
In Force2026-Q3 · ±half_year

AML Law 2026 implementing regulations

16-chapter restructuring of AML institutional framework, reporting obligations, and cross-border transaction provisions.
1 dated · 3 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLRO

Myanmar enacted a new AML Law (16/2026) in March 2026 while remaining on the FATF call-for-action list as of June 2026.

SAR/STR triggers involving Myanmar counterparties should now be assessed against the restructured CDD/EDD obligations in the 2026 AML Law, particularly for PEP and correspondent-banking typologies, while FATF-driven enhanced due diligence remains proportionate-risk rather than full countermeasures.

2 evidence refs
Compliance

OFAC designated the DKBA and Thai front companies in November 2025 over Myanmar scam-compound infrastructure, following a May 2025 KNA designation.

Sanctions screening lists should be checked for the newly designated entities and individuals; the absence of equivalent EU/UK listings means a US-only screening programme captures this exposure while an EU/UK-only programme would not.

2 evidence refs
Legal

Myanmar's new AML Law grants asset-seizure powers targeting ethnic armed organisations tolerating illicit operations in their territory.

Legal exposure assessments for any Myanmar-linked counterparty or transaction chain should account for the expanded statutory basis for asset seizure and the unresolved DNFBP scope question, which has not been independently verified this cycle.

1 evidence refs
Board

Myanmar's AML architecture was wholesale restructured in March 2026 against an unchanged FATF blacklist status in June 2026.

The gap between new statutory architecture and unverified implementation is a material governance consideration for any board-level risk appetite decision touching Myanmar exposure.

2 evidence refs
CTO

The Central Bank of Myanmar reiterated its comprehensive cryptocurrency prohibition in a November 2025 warning.

Any technical architecture supporting Myanmar-linked payment or settlement flows should account for the maintained, comprehensive ban on cryptocurrency transactions as a fixed constraint rather than an evolving one.

1 evidence refs
Risk

OFAC's escalating unilateral designation activity against Karen State scam-compound infrastructure signals a growing correspondent-banking exposure typology.

Exposure-concentration models should flag correspondent-banking and trade-finance relationships with Thailand-incorporated entities connected to the Myanmar-Thailand border region as an emerging risk cluster, given the pattern established across the May and November 2025 designations.

2 evidence refs
Operations

The Central Bank of Myanmar tightened offshore remittance licensing requirements in May 2026.

Transaction-monitoring and screening workflows touching Myanmar remittance-agent relationships should be updated to reflect the expanded licensing and reporting obligations introduced by the 2026 regulations.

1 evidence refs
Audit

No material change this cycle.

No material change for this persona this cycle

Decision lens
MLRO

Myanmar enacted a new AML Law (16/2026) in March 2026 while remaining on the FATF call-for-action list as of June 2026.

Compliance

OFAC designated the DKBA and Thai front companies in November 2025 over Myanmar scam-compound infrastructure, following a May 2025 KNA designation.

Legal

Myanmar's new AML Law grants asset-seizure powers targeting ethnic armed organisations tolerating illicit operations in their territory.

Board

Myanmar's AML architecture was wholesale restructured in March 2026 against an unchanged FATF blacklist status in June 2026.

CTO

The Central Bank of Myanmar reiterated its comprehensive cryptocurrency prohibition in a November 2025 warning.

Risk

OFAC's escalating unilateral designation activity against Karen State scam-compound infrastructure signals a growing correspondent-banking exposure typology.

Operations

The Central Bank of Myanmar tightened offshore remittance licensing requirements in May 2026.

Audit

No material change this cycle.

Shared evidence: 4 refs
Scenario sketches

AMLA transition and cross-border obliged-entity supervision

Illustrative orientation only: as the EU AML Package moves obliged-entity supervision from purely national authorities toward a hybrid regime under the AMLA Regulation (Reg (EU) 2024/1620), alongside the directly-applicable AMLR (Reg 2024/1624) and per-state 6AMLD transposition, cross-border obliged entities with exposure to non-EEA high-risk jurisdictions such as Myanmar could see EU-level supervisory attention converge on correspondent-banking relationships tied to sanctioned armed-group scam-compound networks. This is a structural illustration of how a shifting EU supervisory perimeter could interact with an unrelated non-EEA sanctions typology, not a prediction of either.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_changeNo material MM-linked Russian sanctions-evasion signal found this cycle.
T2 · EU AML Package / AMLAno_changeNot applicable to MM (autonomous, non-EEA jurisdiction).
T3 · FATF Grey Listno_changeMyanmar remains on the FATF blacklist unchanged at the 17-19 June 2026 Plenary.
T4 · Beneficial-Ownership Register Statusno_changeNo BO-registry development identified for MM this cycle.
T5 · Crypto / VASP Regulatory FrameworkwatchCBM reiterated its comprehensive crypto prohibition via a 16 Nov 2025 public warning.
T6 · Sanctions Regime Divergencematerial_changeOFAC unilaterally designated DKBA, KNA-linked entities and Thai front companies over Myanmar scam-compound operations; no equivalent EU/UK listing identified this cycle.
Registers

Enforcement actions

  • OFAC designated Karen State warlord and militia figures, including Saw Chit and Eh Moo, under the Burma-EO14014 and Transnational Criminal Organization authorities for ties to cyber-scam operations in Karen State. 5 May 2025
  • OFAC designated the Yatai New City/Shwe Kokko Special Economic Zone network and affiliated Chit Linn Myaing companies under Global Magnitsky and Transnational Criminal Organization authorities for enabling scam-compound infrastructure in Karen State. 8 Sep 2025
  • As part of the launch of the DOJ Scam Center Strike Force, OFAC designated the DKBA, four senior leaders, a Thai national and two Thai companies tied to compounds in Karen State (Tai Chang, Huanya, KK Park) where trafficked workers are forced into online fraud. 12 Nov 2025
  • Myanmar military conducted a large-scale raid on the KK Park cyberscam compound on the Thai border, arresting 2,198 workers and seizing 30 Starlink satellite internet receivers allegedly used to sustain scam operations. 21 Oct 2025
  • The EU Council approved new restrictive measures against three persons and one entity associated with the Myanmar military junta and responsible for scam operations, including figures linked to the KK Park, Shwe Kokko and Huanya compound network. 25 Apr 2025

Sanctions changes

  • EU Council prolonged Myanmar restrictive measures for a further twelve months, until 30 April 2027, following the annual review; removed one deceased individual from the list. EU measures currently apply to 105 individuals and 22 entities. 27 Apr 2026
  • The OFSI Consolidated List of Asset Freeze Targets closed on 28 January 2026; the UK Sanctions List became the sole authoritative source for Myanmar (and all other regime) designations, with a correction made to one Myanmar designation shortly after. 28 Jan 2026
  • OFAC added new Burma-related SDN listings for the Yatai New City/Shwe Kokko network, Chit Linn Myaing group companies, and associated individuals under Transnational Criminal Organization and Global Magnitsky authorities. 8 Sep 2025
  • OFAC designated the Democratic Karen Benevolent Army and senior leaders as a transnational criminal organization, coinciding with the DOJ's launch of the interagency Scam Center Strike Force targeting Myanmar and Cambodia scam-compound networks. 12 Nov 2025

Regulatory horizon (register)

  • FATF October 2026 Plenary review of Myanmar countermeasures threshold
  • EU Council next annual review of Myanmar restrictive measures
  • UK MLR high-risk third country list update following FATF October 2026 plenary

Active schemes

  • [CRITICAL] Karen State scam-compound crypto laundering pipeline
  • [HIGH] Junta military-procurement banking evasion network
  • [HIGH] Jade and gemstone conflict-finance extraction racket
  • [HIGH] Military-conglomerate beneficial ownership opacity (MEC/MEHL)
  • Rebel-government blockchain currency (DMMK/nUSDT) conflict-finance instrument
Sources
  1. Financial Action Task Force
  2. Financial Action Task Force
  3. Financial Action Task Force
  4. US Department of the Treasury, OFAC
  5. US Department of the Treasury, OFAC
  6. US Department of the Treasury, OFAC
  7. Council of the European Union
  8. UK Foreign, Commonwealth & Development Office / OFSI
  9. United Nations / UN Special Rapporteur on Myanmar
  10. OCCRP
  11. Global Witness
Coverage gaps
UN reporting identified 16 banks across seven countries proc…
UN reporting identified 16 banks across seven countries processing junta military-procurement transactions and 25 banks providing correspondent services to junta-controlled state banks, despite years of targeted sanctions, indicating persistent correspondent-banking leakage around the sanctions perimeter.
Myanmar's company registry (DICA) does not require disclosur…
Myanmar's company registry (DICA) does not require disclosure of beneficial ownership, and the jade/gemstone licensing regime lacks any chain-of-custody or shareholder transparency requirement, despite years of civil-society advocacy for reform.
Global Witness/EarthRights International documented that the…
Global Witness/EarthRights International documented that the US and UK failed to coordinate timing with the EU's 2022 sanctioning of Myanma Oil and Gas Enterprise (MOGE), the junta's largest foreign-currency revenue source, weakening collective diplomatic leverage even after later US action via the MOGE Financial Services Directive.
Myanmar's own AML/CFT supervisory data, FIU statistics, and …
Myanmar's own AML/CFT supervisory data, FIU statistics, and enforcement reporting are not independently verifiable in the open-source English-language environment due to junta information control, limiting this baseline to third-party (FATF, OFAC, EU, UN, NGO, vendor) sourcing rather than a national regulatory primary reporting original compliance data.

Evidence

Confidence-tiered claims

Anti-Money Laundering Law 2026 (Law No. 16/2026) enacted 11 March 2026 by the National Defense and Security Council, repealing the 2014 AML Law; sets CDD triggers and designates MFIU as reporting-receiving authority. SRC-fim-MM-002
Probable · 1 source
Anti-Online Scam Law (2026 Pyidaungsu Hluttaw Law No. 3) enacted 31 July 2026; defines Mule Account offences and mandates bank/telecom/government information-sharing; penalties up to life/death for coerced-labour deaths. SRC-fim-MM-007
Probable · 1 source
No new OFAC/EU Council/UK OFSI designation specific to Myanmar was located within the 28 Sep-4 Oct 2026 window; targeted sectoral sanctions under EO 14014 remain unchanged. SRC-fim-MM-006
Uncertain · 1 source
CBM issued new offshore remittance business regulations on 18 May 2026, repealing Notification No. 21/2019; requires written AML/CFT policy, documented risk assessment, quarterly reporting, UN/CBM sanctions screening, five-year record retention, two-account-per-country limit. SRC-fim-MM-010
Probable · 1 source
Residents report scam and illegal-gambling networks relocating from demolished KK Park and Shwe Kokko compounds into Myawaddy town itself, with alleged Border Guard Force facilitation in exchange for payment. SRC-fim-MM-009
Uncertain · 1 source
Myanmar remains on the FATF 'High-Risk Jurisdictions Subject to a Call for Action' list, unchanged at the June 2026 Plenary. SRC-fim-MM-003
Probable · 1 source