--- title: "Myanmar (MM) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/myanmar/ source_html: /jurisdictions/myanmar/index.html description: "Financial integrity intelligence for Myanmar (MM): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: edc4afe9abbf904833d8fbd89be5c521aa8c69570b0bfc86c1e575aebffb21e1 generator: "fe-fleet/md-twin@1.0" --- # Myanmar (MM) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Myanmar MM Domains covered 8 of 8 Sources 122 Role actions 8 Horizon <90d 1 Jurisdiction profile FATF status: Black-List Tier: B Risk direction: Increasing Enablement vs enforcement: Permissive Myanmar remains on FATF's Call for Action (black) list since October 2022; military junta controls AML/CFT institutions post-coup. More No 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 The Financial Action Task Force's 30 October 2026 Plenary left Myanmar on its call-for-action list but attached a new, dated escalation point: countermeasures will be considered absent further progress by February 2027. FinCEN's relay of the FATF statement is explicit that Myanmar remains a high-risk jurisdiction subject to a call for action, and FATF continues to tie the underlying deficiencies directly to fraud and cyber-scam risk. This is a transition on the standing architecture record, not a change of list position: Myanmar does not move categories this cycle, but the review now carries a clock, converting what has been a static designation into a time-bound decision point for correspondent banks and payment companies maintaining Myanmar-linked relationships. Read full brief #### Lead Signal The Financial Action Task Force's 30 October 2026 Plenary left Myanmar on its call-for-action list but attached a new, dated escalation point: countermeasures will be considered absent further progress by February 2027. FinCEN's relay of the FATF statement is explicit that Myanmar remains a high-risk jurisdiction subject to a call for action, and FATF continues to tie the underlying deficiencies directly to fraud and cyber-scam risk. This is a transition on the standing architecture record, not a change of list position: Myanmar does not move categories this cycle, but the review now carries a clock, converting what has been a static designation into a time-bound decision point for correspondent banks and payment companies maintaining Myanmar-linked relationships. #### Other Developments Cross-border enforcement against the scam-compound economy intensified in two jurisdictions during October. A Chinese court sentenced members of a Kokang-network criminal gang to death on 13 October 2026 for operating scam compounds tied to Myanmar's border region, a sanction corroborated across independent outlets. Eight days later, on 21 October 2026, Myanmar's military raided a suspected Chinese-run scam and gambling compound at Mong Hsat near the Thai border; this account is drawn from a single regional press outlet describing the broader campaign as targeting illegal call centres and online gambling rings, and it has not been corroborated by any Myanmar government notice. Read together, these are two different states exercising criminal and military authority against the same underlying compound infrastructure, consistent with Myanmar's continuing function as an enabler jurisdiction for cross-border scam-compound finance despite periodic high-profile enforcement. A routine sanctions-list adjustment also occurred this period. The US Office of Foreign Assets Control removed Theint Win Htet, a Burma national designated under Executive Order 14014, from the Specially Designated Nationals list effective 9 October 2026, as published in the Federal Register. No corresponding European Union or United Kingdom action has been located, and the delisting reads as ordinary single-designee list maintenance rather than a shift in US sanctions policy toward Myanmar. #### Cross-Monitor Connections The scam-compound enforcement activity described above sits adjacent to conflict-finance concerns in the same border territory: revenue from compound operations in Border Guard Force and ethnic armed organisation territory is a documented adjacent stream to armed-actor finance, though it has not been independently quantified this period. The same compound infrastructure that draws Chinese and Myanmar military enforcement attention is also the subject of a separate cross-border connectivity question, with the US Congress investigating whether satellite connectivity services supplied the compounds in question — a thread that bears on the technology and infrastructure dimension of the same illicit-finance architecture rather than on its financial dimension directly. The FATF countermeasures deadline interacts with both threads: a move to countermeasures in February 2027 would tighten correspondent-banking access across the board, affecting legitimate cross-border flows as well as any financial activity connected to the compound economy. #### Outlook February 2027 is the date to watch. Industry practice already applies enhanced due diligence to Myanmar counterparties, so the practical effect of an escalation to full countermeasures would be to push most correspondent banks toward a near-blanket de-risking posture on Myanmar-linked flows, placing Myanmar alongside the jurisdictions subject to FATF's most severe measures. Short of that date, the pattern of enforcement against the compound economy — now including a capital sanction imposed by a neighbouring state's courts and a military raid by Myanmar's own forces — indicates an underlying illicit-finance architecture that remains active despite periodic crackdowns, reflecting a capacity deficit in Myanmar's border territories rather than a change in political will on either side. Earlier periodic briefs (7) 4 Nov 2026 · fim-2026-11-04 #### Lead Signal The Financial Action Task Force's 30 October 2026 Plenary left Myanmar on its call-for-action list but attached a new, dated escalation point: countermeasures will be considered absent further progress by February 2027. FinCEN's relay of the FATF statement is explicit that Myanmar remains a high-risk jurisdiction subject to a call for action, and FATF continues to tie the underlying deficiencies directly to fraud and cyber-scam risk. This is a transition on the standing architecture record, not a change of list position: Myanmar does not move categories, but the review now carries a clock, converting what has been a static designation into a time-bound decision point for correspondent banks and payment companies maintaining Myanmar-linked relationships. #### Other Developments Cross-border enforcement against the scam-compound economy intensified in two jurisdictions during October. A Chinese court sentenced members of a Kokang-network criminal gang to death on 13 October 2026 for operating scam compounds tied to Myanmar's border region, a sanction corroborated across independent outlets. Eight days later, on 21 October 2026, Myanmar's military raided a suspected Chinese-run scam and gambling compound at Mong Hsat near the Thai border; this account is drawn from a single regional press outlet describing the broader campaign as targeting illegal call centres and online gambling rings, and it has not been corroborated by any Myanmar government notice. Read together, these are two different states exercising criminal and military authority against the same underlying compound infrastructure, consistent with Myanmar's continuing function as an enabler jurisdiction for cross-border scam-compound finance despite periodic high-profile enforcement. A routine sanctions-list adjustment also occurred this period. The US Office of Foreign Assets Control removed Theint Win Htet, a Burma national designated under Executive Order 14014, from the Specially Designated Nationals list effective 9 October 2026, as published in the Federal Register. No corresponding European Union or United Kingdom action has been located, and the delisting reads as ordinary single-designee list maintenance rather than a shift in US sanctions policy toward Myanmar. #### Cross-Monitor Connections The scam-compound enforcement activity described above sits adjacent to conflict-finance concerns in the same border territory: revenue from compound operations in Border Guard Force and ethnic armed organisation territory is a documented adjacent stream to armed-actor finance, though it has not been independently quantified this period. The same compound infrastructure that draws Chinese and Myanmar military enforcement attention is also the subject of a separate cross-border connectivity question, with the US Congress investigating whether satellite connectivity services supplied the compounds in question — a thread that bears on the technology and infrastructure dimension of the same illicit-finance architecture rather than on its financial dimension directly. The FATF countermeasures deadline interacts with both threads: a move to countermeasures in February 2027 would tighten correspondent-banking access across the board, affecting legitimate cross-border flows as well as any financial activity connected to the compound economy. #### Outlook February 2027 is the date to watch. Industry practice already applies enhanced due diligence to Myanmar counterparties, so the practical effect of an escalation to full countermeasures would be to push most correspondent banks toward a near-blanket de-risking posture on Myanmar-linked flows, placing Myanmar alongside the jurisdictions subject to FATF's most severe measures. Short of that date, the pattern of enforcement against the compound economy — now including a capital sanction imposed by a neighbouring state's courts and a military raid by Myanmar's own forces — indicates an underlying illicit-finance architecture that remains active despite periodic crackdowns, reflecting a capacity deficit in Myanmar's border territories rather than a change in political will on either side. 3 Nov 2026 · fim-2026-11-03 #### Lead Signal The Financial Action Task Force's 30 October 2026 Plenary left Myanmar formally where it has stood for several cycles, on the list of jurisdictions subject to a call for action, yet the substance of that outcome has sharpened considerably. For the first time the Plenary attached an explicit deadline, stating that countermeasures will be considered absent further progress by February 2027. That date converts what has functioned as a standing enhanced-due-diligence designation into a near-term binary risk event for correspondent banks and other obliged institutions with Myanmar-linked exposure. The designation itself is Confirmed on a Tier 1 source, a United States government notice relaying the Task Force's own statement, and it sits within the Enhanced due diligence register of FATF instruments rather than any broader embargo. The practical consequence is that institutions already applying enhanced due diligence to Myanmar counterparties are now operating against a visible clock. Should the Task Force conclude in the first quarter of 2027 that progress has been insufficient, Myanmar would move from the enhanced-due-diligence tier into the Countermeasures tier alongside the handful of jurisdictions that presently occupy it. That shift, if it occurs, would require most correspondent banks to move toward a near-blanket de-risking posture on Myanmar-linked flows, a materially different operating environment from the current regime of heightened scrutiny. #### Other Developments A routine sanctions-list adjustment with no broader signal. The Office of Foreign Assets Control removed a single individual, a Burma national designated under Executive Order 14014, from the Specially Designated Nationals List, effective 9 October 2026. The underlying Federal Register notice is Confirmed and Tier 1. The interpreter's own characterisation treats this as ordinary list maintenance rather than evidence of a policy shift toward Myanmar, and no corresponding removal by the European Union or the United Kingdom has been located, which the record treats as unremarkable asynchrony between sanctions regimes rather than a point of divergence worth flagging on its own. Cross-border enforcement against scam and gambling compounds continues. A Chinese court sentenced members of a criminal network to death for operating scam compounds based in Myanmar's Kokang region, reported by CBS News citing AFP and assessed Probable. Separately, the Myanmar military is reported to have raided a suspected Chinese-run scam and gambling compound near Mong Hsat on 21 October 2026, a development resting on a single regional press account and assessed at the Uncertain tier. Read together, these are enforcement actions taken against the compounds rather than evidence that the underlying enabling conditions inside Myanmar have been resolved. The pattern sustains, rather than closes, the profile that sits behind the Task Force's own framing of Myanmar's deficiencies as tied specifically to fraud and cyber-scam risk. #### Cross-Monitor Connections The scam-compound enforcement pattern sits at the intersection of financial-integrity and conflict-adjacent monitoring: the compounds operate in contested border territory, are frequently described as protected by or operating alongside armed actors, and generate proceeds that move through the same regional financial channels that other monitors track for state-capture and cross-border illicit-flow purposes. The Task Force's explicit linkage of Myanmar's deficiencies to fraud and cyber-scam risk, rather than to money laundering or terrorist financing in the conventional sense, is itself a signal worth carrying into any monitor tracking information-operations or platform-enabled fraud infrastructure, since the compounds' output increasingly depends on cross-border digital platforms rather than purely physical smuggling routes. #### Outlook The February 2027 deadline is the dominant forward marker to track. As scheduled, the Task Force's first-quarter 2027 review will determine whether Myanmar is escalated to the countermeasures tier, a change that the record characterises as requiring a substantial shift in correspondent-banking posture rather than an incremental tightening. Industry practice already reflects enhanced due diligence; the open question is whether that practice will need to become near-blanket de-risking. Continued scam-compound enforcement activity, whatever its episodic enforcement value, has not to date been treated by the Task Force as sufficient progress, and the record gives no indication that structural conditions inside Myanmar have shifted enough to alter the trajectory before the deadline arrives. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Myanmar's border region continues to function as a permissive enabler environment for cross-border scam-casino syndicates, with the enforcement signal running through Chinese courts rather than through Myanmar's own authorities. On 13 October 2026, courts in Quanzhou and Nan'an sentenced three leaders of a Wei-clan Kokang syndicate, Wei Huairen, Chen Dawei and Liao Jingfang, to death for operating a network of scam centres and illegal casinos inside Myanmar, the third such round of Chinese capital prosecutions against Kokang-region syndicate leadership during 2026. Separately, reporting indicates that operations displaced by earlier crackdowns at sites such as KK Park and Shwe Kokko have relocated into Myawaddy town on the Thai border, and that Myanmar's military raided a new base near Mong Hsat on 21 October 2026, arresting 99 Chinese nationals. Read together, this is a pattern of sustained external and domestic pressure that has not yet produced confirmed reduction in underlying throughput, only relocation. #### Other Developments A new governing AML instrument. Myanmar's Anti-Money Laundering Law 2026 (Law No. 16/2026) was enacted on 11 March 2026, repealing the 2014 AML Law. The new law extends customer due diligence and reporting obligations, requires a minimum five-year retention period for CDD and transaction records, and explicitly extends coverage to digital-currency transactions and to foreign residents. Because this is a newly scoped baseline record for this tracker, confidence is held at Probable despite the underlying source being a Tier 1 government announcement. FATF review point unresolved. Myanmar remains on FATF's high-risk call-for-action list, a status it has held since October 2022. The Financial Action Task Force's 19 June 2026 statement set October 2026 as the point at which it will consider applying countermeasures absent further progress. No plenary outcome has yet been located, leaving this review point open as this cycle closes. No crypto-proceeds finding. Myanmar's AML Central Body reiterated, on 31 July 2026, that no evidence has been found of crypto-scam proceeds entering the regulated financial system, a position consistent with the Central Bank of Myanmar's standing prohibition on cryptocurrency. #### Cross-Monitor Connections The Kokang-region enabler pattern documented here connects directly to conflict-finance and state-capture questions elsewhere in this corpus: a border region operating largely outside the junta's effective administrative control, generating illicit proceeds that both fund and are tolerated by armed actors with their own financing needs. The extension of Myanmar's new AML law to digital-currency transactions also intersects with crypto-infrastructure questions, since scam-centre proceeds are a recognised vector for crypto-enabled layering even where, as here, no direct evidence of such flows into the regulated system has yet surfaced. The persistence of the FATF call-for-action status continues to constrain correspondent-banking access for Myanmar more broadly, a theme that recurs across payment-infrastructure analysis of the jurisdiction. #### Outlook The clearest near-term marker remains the FATF countermeasures-review point, set for October 2026, with no outcome yet located; a move to countermeasures would be a material escalation for the jurisdiction's financial-crime exposure. Beyond that, the displacement pattern into Myawaddy town suggests further raids alone are unlikely to resolve the underlying cross-border scam economy, and additional Chinese prosecutions of syndicate leadership are a plausible continuation of a pattern now observed three times in 2026. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal The most consequential development touching Myanmar this cycle is not a change to the architecture governing it but a single, narrow adjustment at the margin. On 9 October 2026, the US Treasury's Office of Foreign Assets Control unblocked and removed Theint Win Htet, daughter of military-linked businessman Thein Win Zaw, from the Burma-related Specially Designated Nationals List under Executive Order 14014, with the Federal Register notice published 15 October 2026. OFAC's own notice gives no rationale, though press reporting has framed the move against a backdrop of possible US-Myanmar diplomatic recalibration. Read against the otherwise intact EO 14014 sanctions program and against the unchanged UK, EU, Canadian and Australian Myanmar sanctions lists this cycle, this is an isolated episodic easing, not a structural shift in how the Burma sanctions architecture treats military-linked wealth. #### Other Developments Kokang death sentences. Chinese courts delivered the most significant enforcement signal of the cycle, even though it falls outside any Myanmar instrument. The Quanzhou Intermediate People's Court and the Nan'an People's Court sentenced three leaders of the Wei-clan syndicate to death, three to life imprisonment, and 55 others to terms of three to 24 years, for operating illegal casinos, telecoms fraud, drug trafficking and forced labour from compounds in Myanmar's Kokang region. The judgment found that the syndicate had processed funds exceeding RMB 12.2 billion since 2019, a scale of laundering throughput that places Myanmar's borderlands among the more significant enabling environments documented this cycle anywhere in the tracker. The prosecuting authority is Chinese, not Myanmar's, and that asymmetry is itself the finding: enforcement against conduct located inside Myanmar continues to originate from the jurisdiction receiving the harm rather than from Myanmar's own courts or financial intelligence apparatus. Thai cross-border infrastructure disruption. A second, related development corroborates the same pattern. Thai authorities raided a border village and severed a 48-core fibre-optic cable that had been illegally run 350 metres across the border, supplying an illegal casino and suspected scam centre on the Myanmar side. This is a physical-infrastructure enforcement action by a neighbouring state against the connectivity sustaining Myanmar-based illicit finance operations, not a Myanmar regulatory or law-enforcement initiative. FATF countermeasures deadline approaches. Myanmar remains on the FATF black list under the Call for Action designation, unchanged since October 2022. FATF's June 2026 statement set October 2026 as the point by which it will consider escalating Myanmar from enhanced due diligence to full countermeasures, a designation currently reserved for Iran and North Korea. The next FATF Plenary is scheduled for 26 to 30 October 2026, falling just after this research window closes, so no outcome exists yet to report. #### Cross-Monitor Connections The Kokang enforcement action and the Thai infrastructure disruption both sit at the intersection of financial-crime typology and gambling-sector exposure: the underlying conduct is casino and scam-centre operation, which the companion gambling-regulatory monitor is independently tracking as a borderlands enforcement-gap story, and the payment-corridor implications of a jurisdiction where correspondent access is shaped by sanctions architecture and FX controls are a world-payments concern. The RMB 12.2 billion in funds processed through the Kokang network is a conflict-finance-adjacent and professional-facilitator-adjacent signal: funds of that scale moving through a militia-controlled enabling environment typically imply correspondent-banking or trade-finance-adjacent layering mechanisms, even though no such mechanism was independently evidenced this cycle. The OFAC delisting, by contrast, is a narrowly sanctions-architecture development with no cross-monitor payment-corridor implication beyond the individual concerned. #### Outlook The single event most likely to reshape Myanmar's financial-integrity profile in the near term is the FATF Plenary of 26-30 October 2026, at which FATF will decide whether to escalate Myanmar to full countermeasures. A move to countermeasures would be a structural escalation well beyond this cycle's individual-level sanctions easing, and would materially tighten correspondent-banking and payment-corridor access for the jurisdiction generally. Absent that decision, the enabling-environment pattern evidenced by the Kokang and Thai-border developments is likely to persist: enforcement against Myanmar-located illicit finance infrastructure continues to be supplied by neighbouring and interested states rather than by Myanmar's own authorities. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Myanmar's anti-money-laundering architecture registered a structural change this cycle with the enactment of AML Law No. 16/2026 by the National Defence and Security Council on 11 March 2026, repealing the 2014 AML Law and introducing a sixteen-chapter framework covering customer due diligence, enhanced due diligence, reporting obligations, cross-border transaction rules and penalties. The law is stated to have been drafted with reference to FATF recommendations. Implementation remains incomplete: the Myanmar Financial Intelligence Unit continues to roll out sector-specific notifications and training for designated non-financial businesses and professions, real estate and gold entrepreneurs, and Myanmar remains on the FATF blacklist (the list of jurisdictions subject to a call for action) unchanged since the 19 June 2026 Plenary. The juxtaposition is the signal worth foregrounding: a confirmed, enacted primary instrument sits alongside unchanged international designation, meaning the structural reform has not yet translated into any change to Myanmar's external risk classification. #### Other Developments Divergent sanctions-regime movement. The United States Treasury's Office of Foreign Assets Control deleted one individual, Theint Win Htet, linked to Zaw Thein Win, from the Specially Designated Nationals List under the Burma-EO14014 programme on 9 October 2026, with no accompanying new Myanmar designations. In parallel, the Council of the European Union prolonged its Myanmar restrictive measures for a further twelve months to 30 April 2027, a regime covering 105 individuals and 22 entities. The narrow scope of the OFAC action set against the breadth and duration of the EU renewal illustrates continuing divergence in designation pace and scope between the two sanctions regimes rather than a substantive policy shift by either. Financial-sector technology partnerships. Trade press reported, around 5 January 2026, a partnership between Temenos and Myanmar Citizens Bank for digital-core banking technology, and a separate partnership between FinbotsAI and KBZ Bank for AI-based credit scoring. Neither partnership carries a disclosed deal value, and reporting rests on a single trade-press source with no corroborating primary-source confirmation located this cycle. These are commercial technology deployments in the banking sector rather than AML-specific compliance-technology developments, though digital-core and credit-scoring infrastructure of this kind typically carries downstream implications for how customer data and transaction monitoring are structured at the institutions concerned. #### Cross-Monitor Connections The divergence between the EU's broad, long-duration Myanmar sanctions regime and OFAC's narrow single-entity action is a pattern with relevance beyond Myanmar alone, bearing on how multinational obliged entities reconcile screening lists across jurisdictions with materially different designation scope for the same country risk. The enactment of AML Law No. 16/2026 against a backdrop of continued FATF blacklisting also illustrates a structural pattern seen elsewhere: a formally reformed legal framework whose practical effect is constrained while implementing notifications and institutional capacity remain in build-out, a dynamic relevant to state-capture and conflict-finance monitoring wherever legal reform outpaces institutional delivery. #### Outlook The period ahead should be read against the Myanmar Financial Intelligence Unit's continued rollout of sector notifications under AML Law No. 16/2026, expected to extend into 2027 as the primary law's obligations are progressively extended to designated non-financial businesses and professions and other sectors. Whether this structural reform affects Myanmar's FATF blacklist status will depend on assessed implementation rather than enactment alone, and no change to that status was evident as at this cycle. The sanctions picture remains one to watch for continued divergence between the US and EU tracks through the EU regime's current expiry point of 30 April 2027. 28 Sep 2026 · fim-2026-09-28 #### 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. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal Myanmar's financial-integrity picture this cycle centers on a wholesale AML statutory replacement running in parallel with an intensifying, multi-jurisdictional enforcement campaign against scam-gambling compounds. The Anti-Money Laundering Law 2026 (Law No. 16/2026), enacted by the National Defense and Security Council on 11 March 2026, repeals the prior 2014 AML Law and layers new five-year CDD and beneficial-ownership record-retention duties, plus a senior compliance-officer mandate, onto Myanmar reporting organizations. This formal-compliance uplift is not, however, running in place of an escalating sanctions and enforcement track — it is running alongside it, and the two tracks are not substitutable. The Office of Foreign Assets Control has issued three sequenced 2025-2026 designation rounds against Myanmar-based scam-gambling entities and their facilitators: nineteen entities designated in September 2025, nine of them located in the Shwe Kokko compound zone; a coordinated multi-agency Scam Center Strike Force action on 23 April 2026 that, for the first time, targeted the full scam-operation lifecycle rather than individual compound entities alone; and a further designation on 16 June 2026 of a Myanmar-based armed group, a Thai national, and a Mae Sot-registered company. Myanmar remains on the FATF Call-for-Action blacklist alongside Iran and North Korea, confirmed at the 19 June 2026 Plenary, an unchanged status that sustains a global enhanced-due-diligence posture toward the jurisdiction regardless of the domestic legislative uplift. Both W1a-style licensing developments and the correspondent-facing sanctions track carry High confidence this cycle. Myanmar's overall jurisdiction-risk trajectory is assessed as increasing, driven jointly by the new AML statute's parallel-track compliance uplift and the sustained multi-jurisdictional enforcement pressure bearing down on the scam-gambling economy. The widening gap between a hardening domestic compliance architecture and an unrelenting external enforcement and sanctions track is this cycle's central financial-integrity read for Myanmar. #### Other Developments Armed-group revenue capture from the scam-gambling economy is now directly evidenced: individuals linked to the Karen National Army, including Tin Win and Saw Min Min Oo, are assessed to have provided security and managed entities supporting scam-gambling operations in the Myanmar border zone. This is a conflict-finance channel independent of, and durable against, Myanmar's formal AML reform trajectory, and it was named specifically in the same 16 June 2026 OFAC designation action that targeted the Myanmar-based armed group and its Thai and Mae Sot-registered facilitators. Crypto-laundering infrastructure at the Shwe Kokko and KK Park scam-gambling compounds — casino servers and crypto-transaction gateways — was directly targeted by OFAC's 23 April 2026 coordinated strike, the first action explicitly aimed at the crypto-laundering layer of the scam-compound economy rather than at the compounds' physical or corporate footprint alone. Beneficial-ownership architecture in Myanmar remains layered rather than unified: the AML Law 2026's new five-year CDD and beneficial-ownership retention mandate sits atop the pre-existing DICA beneficial-ownership disclosure regime under Directive No. 17/2019, with no unified public beneficial-ownership register in place. The retention mandate is an uplift in duration and specificity of obligation, not a structural overhaul of how beneficial ownership is disclosed in the first instance. #### Cross-Monitor Connections The extra-parliamentary enactment of the AML Law 2026 by the NDSC, ahead of parliament convening, is a state-capture-adjacent signal warranting continued WDM cross-reference: a financial-integrity statute reformed through executive rather than legislative process sits naturally alongside state-capture-focused monitoring of Myanmar's governance trajectory. The Karen National Army's revenue capture from scam-gambling compounds is a conflict-finance signal warranting SCEM cross-reference, given the direct evidence of security provision and entity management by named individuals tied to an armed group operating in a contested border zone. The crypto-transaction-gateway infrastructure at Shwe Kokko and KK Park connects directly to digital-asset tracking of Southeast Asian scam-compound infrastructure more broadly, and the compound economy's blend of telecom fraud, forced-labor-adjacent conditions, and gambling carries an FCW-relevant information-operations dimension insofar as diplomatic messaging from China and enforcement narratives from Myanmar authorities shape public perception of the crackdown's underlying motivations. #### Outlook The near-term horizon is dominated by Myanmar's AML Law 2026 implementing directives, expected in the fourth quarter of 2026 but not yet published, which will determine whether the new compliance-officer and audit obligations translate into practice matching the DNFBP outreach and training the Myanmar Financial Intelligence Unit is currently conducting. The FATF's next Plenary review is a second horizon marker: no change to Myanmar's Call-for-Action blacklist status was recorded this cycle, and continuation of that status would sustain the current correspondent-banking de-risking pressure compounding on top of the stacked OFAC designations. Absent a Tier-1 primary gazette text of the AML Law itself, confidence in the durability of the domestic reform track continues to rest on secondary legal and policy-analyst reporting rather than official publication. Domain intelligence (D1–D8) #### Sanctions The sanctions picture for Myanmar this cycle is narrow and procedural rather than structural. The Office of Foreign Assets Control removed Theint Win Htet, a Burma national designated under Executive Order 14014, from the Specially Designated Nationals List, with the removal effective 9 October 2026. The underlying Federal Register notice is a Tier 1 primary source and the claim is assessed Confirmed. The interpreter's own framing treats this as routine list maintenance: a single delisting of this kind does not, on its own, indicate any change in the United States' overall sanctions posture toward Myanmar, and no broader designation or removal pattern accompanies it. Continue reading The absence of a matching move by the European Union or the United Kingdom is worth recording precisely because sanctions-list divergence between major issuing jurisdictions is a standing structural feature worth tracking over time, even where, as here, a single delisting is most plausibly explained by ordinary asynchrony in review cycles rather than by any substantive disagreement over the underlying designee. Myanmar's sanctions architecture more broadly sits under Executive Order 14014 and parallel instruments, and nothing in the current record suggests that architecture is under near-term revision. The designation regime applicable to Myanmar remains distinct from the Comprehensive sanctions category used for embargo-type regimes; EO 14014 and its associated designations function as targeted measures against named individuals and entities connected to the February 2021 coup and subsequent repression, not as a jurisdiction-wide embargo. What gives this otherwise minor development its salience is proximity: it lands in the same cycle as the Financial Action Task Force's decision to attach an explicit February 2027 deadline to Myanmar's call-for-action status, discussed in the regime-level record. The two tracks, sanctions designations on one hand and the Task Force's anti-money-laundering and counter-terrorist-financing assessment on the other, operate on different legal bases and different institutional logic, but both bear on the same underlying question for compliance functions: how much residual risk does a Myanmar nexus carry, and is that risk trending up or down. On the sanctions track specifically, the answer this cycle is: unchanged in substance, with one technical removal that does not alter the overall designation landscape. #### Outlook No further sanctions-list action specific to Myanmar is signalled in the current record. The more consequential forward marker sits on the anti-money-laundering track, where the Financial Action Task Force's first-quarter 2027 review will determine whether Myanmar is escalated from enhanced due diligence to countermeasures. Should that escalation occur, institutions should expect it to be accompanied, in the normal course, by renewed attention to designation lists as enforcement bodies recalibrate exposure; absent escalation, the sanctions picture is likely to remain one of incremental, individual-level adjustments of the kind seen this cycle rather than structural change. Judgment: OFAC's routine single-designee delisting under EO 14014 is ordinary maintenance churn, not a policy shift; no corresponding EU/UK action located. Probable #### Beneficial Ownership and Corporate Transparency Myanmar sits outside the European Economic Area, and its corporate-transparency exposure is therefore best read first through its own domestic registry framework rather than through the EU AML Package. The directly relevant development this cycle is the persistent absence of any beneficial-ownership disclosure requirement at Myanmar's DICA company registry, a structural deficiency identified since at least 2023 and unchanged in this baseline window. That gap is not abstract: Myanma Economic Holdings Ltd and Myanma Economic Corporation, the two military conglomerates at the center of this cycle's findings, hold cross-sectoral shareholdings in banking, mining, telecoms and jade without any public UBO trail, using layered nominee and subsidiary structures that obscure military ownership from sanctions screening and financial-institution due diligence alike. The effect is that Myanmar's most consequential corporate-transparency problem is not a gap in international standards being applied to it, but the absence of any domestic legal requirement to disclose ownership at all. Continue reading Globally, the EU AML Package sets the structural direction for corporate-transparency reform, and it remains the relevant contextual backdrop even for a non-EEA jurisdiction like Myanmar. The package now comprises three distinct instruments: the AML Regulation (Regulation (EU) 2024/1624), which is directly applicable across Member States without national transposition; the sixth AML Directive, transposed individually by each Member State; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority and is progressively shifting supervision of certain cross-border obliged entities from purely national competent authorities toward a hybrid EU-level regime through AMLA's direct and indirect supervision perimeter. Myanmar itself is not directly supervised under either the AMLR or the AMLA Regulation; its EU relevance runs instead through high-risk third-country listing rather than through direct transposition or AMLA supervisory reach. Myanmar's historical status under EU Delegated Regulation 2016/1675 requires re-verification against the December 2025 consolidated Delegated Regulations (EU) 2026/46 and (EU) 2026/83, and the downstream enhanced due-diligence obligations that EU obliged entities owe toward Myanmar-nexus relationships depend on the confirmed text of that updated list. Myanmar also appears on HM Treasury's June 2026 high-risk third-country advisory list, a UK-specific track running in parallel to, but not identical with, the EU mechanism. The practical consequence of the DICA registry gap and the pending list re-verification, taken together, is that beneficial-ownership opacity around MEHL and MEC is currently insulated from two directions at once: no domestic disclosure obligation compels transparency at source, and the international high-risk-jurisdiction mechanisms that would otherwise compensate for that gap through enhanced due diligence remain in a state of unresolved status re-confirmation this cycle. Global Witness has continued to call for reinstatement of shareholder disclosure and UBO publication requirements, particularly for jade and gemstone licensees, but no legislative reform has been identified within the eighteen-month baseline window. #### Outlook No near-term legislative remediation of the DICA registry gap is indicated by this cycle's findings, and the structural fusion of state and private military-commercial interest in Myanmar makes voluntary domestic reform unlikely absent external pressure. The more immediate development to track is the resolution of Myanmar's EU high-risk third-country status following the December 2025 consolidated Delegated Regulations, alongside the parallel UK HRTC advisory-list reconfirmation expected after the FATF's October 2026 plenary; both will determine the practical enhanced due-diligence burden facing EU and UK obliged entities with Myanmar-nexus corporate relationships, independent of any change to Myanmar's own registry framework. Judgment: No beneficial-ownership development was located this cycle. Uncertain #### Enabler Jurisdictions Myanmar's border territories continue to host the physical infrastructure of a cross-border scam-and-gambling compound economy, and this period's developments illustrate the enabler-jurisdiction dynamic with unusual clarity: enforcement comes from outside and above, while the underlying territorial capacity to prevent the activity from recurring remains limited. A Chinese court sentenced members of a Kokang-network criminal gang to death on 13 October 2026 for operating scam compounds tied to Myanmar's border region, an action corroborated across independent reporting and notable for its severity — a capital sanction imposed by a neighbouring state's judiciary against operators located, at least in part, within Myanmar's territory. Eight days later, on 21 October 2026, Myanmar's own military raided a suspected Chinese-run scam and gambling compound at Mong Hsat near the Thai border, with regional press describing a broader campaign against illegal call centres and online gambling rings. That account rests on a single regional outlet and has not been corroborated by any Myanmar government notice, a caveat worth preserving given the pattern of episodic, campaign-style enforcement that characterises this border territory rather than sustained administrative control. Continue reading The analytical significance of these two actions, taken together, is structural rather than incident-specific. Myanmar continues to function as an enabler jurisdiction for cross-border scam-compound finance not because its authorities decline to act — both a neighbouring state's courts and Myanmar's own military acted within an eight-day window — but because the underlying capacity deficit in fragmented, contested border territory means that periodic raids and prosecutions do not translate into durable suppression of the infrastructure itself. This is a capacity problem more than a political-will problem: enforcement action occurred on both sides of the border, yet the compound economy is described as continuing. For institutions assessing counterparty or correspondent exposure touching Myanmar's border regions, the relevant signal is not the occurrence of enforcement action alone but its episodic character, set against a territorial environment that structurally limits what any single enforcement action can achieve. A further dimension of enabler-jurisdiction exposure touches the technology layer rather than the financial layer directly: a separate inquiry opened this period into the connectivity infrastructure that may sustain these compounds, examining whether a satellite connectivity provider supplied service to Myanmar-based scam and gambling operations. That inquiry sits at the edge of this domain's remit — it is an infrastructure and technology question rather than a financial-flow question — but it underscores that the compound economy's enabling conditions are not limited to weak territorial control; they may also include commercially available connectivity services that are not contingent on any particular jurisdiction's AML/CFT posture. #### Outlook No further Myanmar-specific judicial or military action against the compound economy is scheduled or announced. The pattern observed this period — enforcement bursts tied to specific raids or prosecutions rather than a sustained administrative campaign — is consistent with a structurally thin-record jurisdiction in which periodic, high-profile action substitutes for continuous oversight. What would change this picture is evidence of a sustained, rather than episodic, joint or coordinated enforcement effort between Myanmar authorities and neighbouring states, or evidence that the connectivity-infrastructure inquiry produces findings that extend scrutiny to the providers enabling the compounds rather than only to the compounds' operators. Absent either, the enabler-jurisdiction assessment for Myanmar's border territories should be read as a capacity-constrained environment where enforcement, however severe when it occurs, has not yet been shown to durably reduce the underlying infrastructure. Judgment: Myanmar continues to function as an enabler jurisdiction for cross-border scam/gambling compound finance, with weak central authority and fragmented territorial control hosting the infrastructure despite periodic raids. Probable #### Conflict Finance and Extractive-Industry Integrity Myanmar's conflict-finance architecture this cycle operates through two structurally distinct but interlocking channels. The first is extraction-sector control: military and armed groups control jade extraction in Kachin and ruby and gemstone extraction around Mogok through Myanma Economic Holdings Ltd, the Myanma Economic Corporation, and extortion of informal miners, a dynamic that has intensified since formal licensing lapsed in 2020. Proceeds are smuggled through Thailand for cutting and processing before entering global luxury supply chains with no chain-of-custody documentation at any stage, meaning there is currently no mechanism by which an external buyer of finished gemstones could verify that proceeds did not fund either the Tatmadaw or a nominally opposing armed group. This is the defining feature of the racket: it funds both sides of the conflict simultaneously, which makes it resistant to any conflict-finance intervention premised on identifying and isolating a single hostile actor. Continue reading The second channel is correspondent-banked military procurement. Junta arms and jet-fuel procurement, financed through correspondent banking relationships and holding companies in Singapore and Thailand, directly sustains the military's conflict capacity against ethnic armed groups and the civilian population. UN Special Rapporteur reporting quantifies this channel at sixteen banks across seven countries processing junta procurement transactions and twenty-five banks providing correspondent services to junta-controlled state banks, a scale that indicates a durable financing architecture rather than an isolated transaction pattern. Both channels share a common structural precondition: the absence of any beneficial-ownership disclosure requirement at Myanmar's DICA registry allows MEHL and MEC to hold their extraction-sector shareholdings without any public ownership trail, insulating the conflict-finance function of jade and gemstone extraction from the kind of scrutiny that a functioning UBO regime would otherwise impose. The baseline's state-capture judgment, that the junta directs rather than merely tolerates this financial architecture, applies with particular force here: this is not informal exploitation of a weak state by criminal actors operating around its edges, but conflict finance run directly through formally constituted, though undisclosed, military-commercial conglomerates. #### Outlook No chain-of-custody transparency mechanism for Myanmar's jade and gemstone sector has been identified this cycle, and the informal exploitation of a licensing regime frozen since 2020 shows no sign of formal resolution. The correspondent-banking channel financing military procurement remains similarly unaddressed by any sanctions action identified this cycle beyond existing designations, meaning both structural conflict-finance channels should be expected to persist through the near-term horizon absent a change either in Singapore/Thailand correspondent-banking practice or in international demand-side pressure on the jade and gemstone luxury-market supply chain. Judgment: Scam-compound revenue in BGF/EAO territory is a documented adjacent revenue stream to armed-actor finance; not independently quantified this cycle. Uncertain #### Crypto, Digital Assets, and Financial Innovation Myanmar's own digital-asset environment, rather than any global framework, is the correct starting point for reading this cycle's D5 signal, since no domestic VASP regulatory framework exists to govern the crypto activity documented here. Karen State scam compounds solicit pig-butchering fraud proceeds via fake USDT/USDC trading platforms and layer those proceeds through Chinese-language money-laundering networks and Telegram-based guarantee markets, specifically Huione and Xinbi, before cash-out through OTC desks and shell companies. This layering architecture is purpose-built to evade centralized-exchange freezes, and the compounds themselves, including KK Park, Shwe Kokko, Tai Chang and Huanya, are staffed substantially by forced and trafficked labor, meaning the crypto-laundering infrastructure and the human-trafficking economy that sustains it are functionally the same operation viewed from different angles. Continue reading A second, structurally distinct digital-asset development inside Myanmar is the National Unity Government's issuance of DMMK and nUSDT tokens, blockchain-based quasi-central-bank digital currencies operating as parallel financial infrastructure amid the civil war, entirely outside junta control and outside any AML, CTF or CPF supervisory perimeter. This is a conflict-driven monetary instrument rather than a conventional VASP product, and it complicates monitoring of conflict-related crypto flows regardless of which side of the conflict any given transaction is assessed against, since neither the issuing rebel administration nor the junta operates a supervisory framework capable of monitoring it. Globally, frameworks such as FATF's virtual-asset standards and jurisdiction-specific VASP registration regimes elsewhere set the direction for crypto-asset AML/CFT supervision, but they function here only as contextual backdrop: Myanmar has no domestic equivalent framework, and the crypto activity documented in this cycle exists entirely outside any such perimeter. The one enforcement development touching this ecosystem from outside Myanmar is FinCEN's 2025 Section 311 action against the Cambodia-based Huione Group, which disrupted a laundering conduit used to move Myanmar-linked scam proceeds. That action targeted a regional facilitator rather than Myanmar itself, and its practical effect on the Myanmar-based compounds' laundering capacity depends on whether replacement guarantee-market infrastructure has absorbed the disrupted volume, a question not resolved within this cycle's evidence base. #### Outlook Absent any domestic VASP regulatory framework, Myanmar's crypto-enabled fraud and quasi-CBDC infrastructure should be expected to persist as a supervisory blind spot regardless of external enforcement actions against individual laundering conduits. The Section 311 action against Huione Group demonstrates that disruption of a single facilitator does not resolve the underlying gap; the durability of the DMMK/nUSDT quasi-CBDC instrument as a conflict-finance and CPF monitoring challenge should likewise be expected to continue for as long as the underlying civil conflict and the absence of any unified Myanmar financial supervisory authority persist. Judgment: No new crypto-specific finding was located this cycle; subscribed coverage sits with the crypto consumer. Uncertain #### Compliance Technology and Active Defence This cycle's D6 signal for Myanmar is defined less by any specific regulatory technology guidance change than by the degradation of formal domestic supervisory capacity and the private-sector analytical response filling that gap. Myanmar's Financial Intelligence Unit, now junta-controlled, has had its supervisory capacity degraded by conflict, state capture and sanctions isolation, meaning conventional AML/CFT reporting channels that would normally anchor a jurisdiction's compliance-technology posture cannot be relied upon here. In their place, blockchain analytics vendors, including Elliptic and Chainalysis, deploy behavioral wallet-flagging and typology-detection methodologies specifically to identify pig-butchering scam patterns tied to Myanmar-based compounds. This third-party analytical capability functions as an open-source substitute for the FIU reporting function that would ordinarily exist, a distinctly D6 active-defence development in which private analytics infrastructure, rather than any formal regulatory technology mandate, is doing the work of surfacing suspicious activity linked to Myanmar-nexus crypto flows. Continue reading The operational compliance-technology impact of this cycle's sanctions-architecture change also belongs in this domain: the UK's closure of the OFSI Consolidated List on 28 January 2026, and its consolidation of Myanmar designations into the unified UK Sanctions List, requires firms relying on legacy OFSI feeds for Myanmar screening to migrate their screening infrastructure to the new list format. This is a pure RegTech and screening-architecture implication flowing from a D1 structural development, illustrating how a sanctions-list architecture change at the source cascades directly into firms' transaction-monitoring and screening-feed configuration regardless of whether the underlying designations themselves have changed. Underlying both of these developments is a more basic evidentiary constraint: Myanmar's AML/CFT open-source evidence base relies on third-party sourcing, FATF, OFAC, EU, UN and NGO and vendor reporting, rather than independently verifiable Myanmar national primary reporting, a direct consequence of junta information control. This sourcing thinness is itself a coverage gap in the intelligence evidence base rather than a statement about any individual firm's internal control inventory, but it materially affects how confidently any compliance-technology assessment of Myanmar-nexus exposure can be made, since the analytical substitutes described above, however sophisticated, cannot fully compensate for the absence of verifiable domestic supervisory data. #### Outlook No jurisdiction-specific regulatory-technology guidance change has been identified for Myanmar this cycle, and the structural drivers of this domain, degraded FIU capacity and reliance on third-party sourcing, show no sign of near-term resolution given the junta's continued information control. Firms with Myanmar-nexus exposure should expect to continue relying on third-party blockchain analytics as a practical substitute for formal domestic supervisory reporting, and should treat the UK Sanctions List migration as an operational compliance-technology task distinct from, but triggered directly by, the underlying D1 sanctions-architecture developments documented elsewhere this cycle. Judgment: No RegTech/guidance development was located this cycle. Uncertain #### AML/CTF Regime The Financial Action Task Force's 30 October 2026 Plenary statement retained Myanmar on its call-for-action list, the most severe tier of FATF's public designation architecture. What changed this period is not Myanmar's list position but the structure of the review attached to it: FATF has now set a dated point, February 2027, by which it will consider countermeasures absent further progress. FinCEN's relay of the FATF statement is explicit that Myanmar remains a high-risk jurisdiction subject to a call for action, and FATF's own framing continues to tie the underlying deficiencies directly to fraud and cyber-scam risk — the same risk category associated with the border-area compound economy enforcement activity recorded elsewhere this period. This connection is not incidental: FATF is treating the scam-compound phenomenon as symptomatic of the broader AML/CFT architecture weakness that keeps Myanmar on the call-for-action list, rather than as a separate problem. Continue reading For institutions maintaining Myanmar-linked correspondent or payment relationships, the practical significance of a dated review is considerable even though the designation itself has not moved. Industry practice already applies enhanced due diligence to Myanmar counterparties under the existing call-for-action status; the gap between that posture and full countermeasures is the gap between enhanced scrutiny and near-blanket de-risking. A move to countermeasures in February 2027 would place Myanmar alongside the small set of jurisdictions subject to FATF's most severe measures, with corresponding effects on correspondent-banking access, cross-border payment-company relationships, and cross-sector financial exposure generally. This is a jurisdiction-wide architectural risk, not a sector-specific one: it attaches to banks, payment companies, and cross-sector counterparties alike, independent of any particular transaction type. The three-pillar balance is worth stating plainly here: FATF's framing of this cycle's escalation explicitly centres fraud and cyber-scam risk, a theme more commonly associated with countering-financing-of-terrorism-adjacent or proliferation-financing discourse being under-weighted relative to anti-money-laundering enforcement volume. That FATF has chosen to anchor a countermeasures deadline in fraud and cyber-scam risk specifically, rather than in traditional money-laundering predicate offences alone, signals that the scam-compound economy described under enforcement activity this period is being read by FATF as a structural driver of Myanmar's AML/CFT deficiency, not a peripheral concern. #### Outlook February 2027 is the operative date. Between now and then, the architecture risk is binary at the macro level — either FATF finds sufficient progress and the call-for-action status continues unchanged, or it does not and countermeasures proceed — but the practical risk-management question for exposed institutions is not binary: enhanced due diligence postures should already reflect the possibility of escalation, given that FATF has now attached an explicit deadline and an explicit causal link to the fraud and cyber-scam risk documented in parallel enforcement activity. No gazetted Myanmar-domestic AML legislative change accompanies this period's development; the movement is entirely at the level of FATF's own external assessment process. Judgment: FATF's retained call-for-action status now carries an explicit February 2027 countermeasures review, a time-bound escalation risk to the standing AML/CTF architecture record. Probable #### Commercial Activity Two financial-sector technology partnerships involving Myanmar banks were reported in trade press around 5 January 2026. Temenos, a global banking software provider, entered into a partnership with Myanmar Citizens Bank, reported in connection with digital-core banking technology. Separately, FinbotsAI was reported to have partnered with KBZ Bank on an artificial-intelligence credit-scoring capability. Neither partnership carries a disclosed deal value, and both rest on a single trade-press source, Fintech News Singapore, with no corroborating primary-source confirmation, such as a bank press release or regulatory filing, located this cycle. Continue reading From a financial-integrity perspective, these partnerships are notable less for their commercial terms, which are not disclosed, than for their infrastructure implications. A digital-core banking platform deployment at Myanmar Citizens Bank and an AI-based credit-scoring capability at KBZ Bank both touch directly on how customer data, transaction records and risk-scoring logic are structured and processed at the institutions concerned. Infrastructure of this kind can have downstream bearing on transaction-monitoring and customer-due-diligence capability, though no claim about a specific compliance-technology function or AML/CTF integration was located in the sourcing reviewed this cycle, and none should be inferred beyond what is reported. The commercial development sits alongside, but is not established as connected to, Myanmar's broader financial-sector reform trajectory this cycle, including the enactment of AML Law No. 16/2026. No source reviewed ties either banking-technology partnership to AML Law compliance preparation specifically, and this sub-brief does not assert such a connection. #### Outlook Given the single-source nature of the reporting on both partnerships, confirmation from a primary source, whether a bank announcement, regulatory filing, or vendor disclosure, would materially strengthen confidence in the scope and status of these engagements. Future cycles should watch for whether either Temenos or FinbotsAI publishes further detail on deployment status, and whether any Myanmar bank discloses linkage between new core-banking or AI infrastructure and its AML Law No. 16/2026 compliance programme. Judgment: No financial-integrity-sector commercial event involving Myanmar was located this cycle. Uncertain Regulatory horizon In Force Pending 1 Feb 2027 · ±quarter ### FATF Myanmar countermeasures review deadline If FATF escalates in February 2027, Myanmar moves from the enhanced-due-diligence tier to the countermeasures tier alongside Iran and North Korea. [Source](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-6) In Force Pending 2027-Q1 · ±year ### AML Law 2026 implementing regulations/notifications Progressive issuance of sector notifications and training under the new AML Law framework. [Myanmar Financial Intelligence Unit / Anti-Money Laundering Central Body Source](https://mfiu.gov.mm/en/home) In Force Pending 2027-Q1 · ±quarter ### FATF Myanmar countermeasures review If FATF escalates in February 2027, Myanmar moves from the enhanced-due-diligence tier to the countermeasures tier alongside Iran and North Korea. [FATF Source](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-6) 3 dated · 1 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### FATF set a February 2027 deadline before considering countermeasures against Myanmar, tied explicitly to fraud and cyber-scam risk. Existing enhanced due diligence on Myanmar counterparties remains the applicable standard today, but the dated review raises the prospect of a shift to full countermeasures, which would materially change correspondent-banking and SAR-trigger considerations for any Myanmar-linked relationship. 1 evidence refs Compliance ### Myanmar remains on FATF's call-for-action list with a newly dated countermeasures review for February 2027. The existing enhanced-due-diligence control framework for Myanmar counterparties should be read against a defined escalation date rather than an open-ended designation, and continued cross-border enforcement against Myanmar-linked scam compounds sustains the risk profile the designation addresses. 2 evidence refs Legal ### A Chinese court imposed death sentences on scam-compound operators linked to Myanmar's border region, while OFAC separately delisted one Burma-designated individual. The criminal-justice action in China signals that liability exposure for scam-compound-linked activity touching Myanmar can be prosecuted with severe sanction outside Myanmar itself, while the OFAC delisting is isolated single-designee maintenance with no indication of a broader sanctions-policy shift. 2 evidence refs Board ### FATF's dated countermeasures review for Myanmar creates a defined near-term point at which correspondent-banking exposure to the jurisdiction could tighten materially. The institution's exposure to Myanmar-linked flows should be reviewed against a specific February 2027 horizon rather than treated as a static high-risk designation, given FATF's explicit linkage of the decision to continuing fraud and cyber-scam risk. 1 evidence refs CTO ### A US congressional inquiry is examining whether satellite connectivity services supplied Myanmar-based scam and gambling compounds. Technology and platform risk assessments touching Myanmar-linked infrastructure should account for the possibility that connectivity-provider scrutiny, not only financial-institution scrutiny, could extend to this compound economy; the inquiry is open and has produced no finding to date. Risk ### Myanmar's enabler-jurisdiction risk and AML/CTF architecture risk both escalated this period through FATF's dated review and continued cross-border scam-compound enforcement. Exposure concentration analysis should treat Myanmar as carrying two converging risk vectors — a time-bound FATF escalation and an active, if episodic, enforcement campaign against the border-area compound economy — that together raise the near-term probability of tightened correspondent access. 2 evidence refs Audit ### OFAC's delisting of a single Burma-designated individual under EO 14014 was published in the Federal Register on 15 October 2026, effective 9 October 2026. Sanctions-screening lists and audit trails should reflect the delisting date precisely, since the action is documented as routine single-designee maintenance with no corresponding EU or UK action located. 1 evidence refs Scenario sketches ### Illustrative pathway to FATF countermeasures on Myanmar Illustrative scenario for analytical orientation only: if Myanmar's call-for-action status converts to countermeasures in February 2027, correspondent banks currently applying enhanced due diligence could move toward a near-blanket de-risking posture, compressing available payment rails for all Myanmar-linked flows, licit and illicit alike. Architecture-over-incident framing: this describes a possible structural mechanism following from the dated review already in evidence, not an observed fact or a prediction. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. ### Illustrative EU AML Package / AMLA supervisory transition Illustrative scenario for analytical orientation only: as the AML Regulation (Reg (EU) 2024/1624) and the Anti-Money Laundering Authority established under the AMLA Regulation (Reg (EU) 2024/1620) move supervision of cross-border obliged entities from purely national authorities toward a hybrid EU-level regime, alongside per-state transposition of the sixth AML Directive, the supervisory treatment of non-EEA high-risk-jurisdiction exposures such as Myanmar's could be harmonised more tightly across EU member-state correspondent banks than under the prior fragmented national approach. This is architecture-over-incident illustration of a structural transition already underway, not a prediction of any specific outcome for Myanmar. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No Russia-linked sanctions-evasion signal with a Myanmar nexus surfaced this cycle. T2 · EU AML Package / AMLA no_change Not applicable to Myanmar (non-EEA, autonomous jurisdiction). T3 · FATF Grey List material_change FATF's 30 Oct 2026 Plenary retained Myanmar on the call-for-action blacklist with a new February 2027 countermeasures deadline. T4 · Beneficial-Ownership Register Status no_change Myanmar has no functioning centralised beneficial-ownership register; no development located this cycle. T5 · Crypto & Digital-Asset Integrity no_change No new CBM crypto directive located this cycle; standing CBM Directive 9/2020 prohibition and March 2026 AML Law remain operative. T6 · Sanctions Regime Divergence watch OFAC's 9 Oct 2026 delisting of a single Burma EO-14014 designee is autonomous US listing-maintenance action; no corresponding EU/UK action located. Registers ### Enforcement actions - 5 May 2025 - 8 Sep 2025 - 12 Nov 2025 - 21 Oct 2025 - 25 Apr 2025 - 8 Sep 2025 - 23 Apr 2026 - 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 - 27 Apr 2026 - 28 Jan 2026 - 8 Sep 2025 - 12 Nov 2025 - 8 Sep 2025 - 16 Jun 2026 - 13 Nov 2025 - 6 May 2025 - 9 Oct 2026 - 9 Oct 2026 - 9 Oct 2026 - 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) - UK ECCTA 2023 failure-to-prevent-fraud offence implementation - AML Law 2026 implementing regulations - AML Law 2026 implementing regulations/notifications - FATF Myanmar countermeasures review - FATF Myanmar countermeasures review deadline - 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 - [https://presoffministry.gov.mm/en/news/28022](https://presoffministry.gov.mm/en/news/28022) - [https://www.dfdl.com/insights/legal-and-tax-updates/myanmar-anti-money-laundering-law-2026-key-compliance-updates/](https://www.dfdl.com/insights/legal-and-tax-updates/myanmar-anti-money-laundering-law-2026-key-compliance-updates/) - [https://www.dfdl.com/insights/legal-and-tax-updates/myanmar-new-offshore-remittance-business-regulations/](https://www.dfdl.com/insights/legal-and-tax-updates/myanmar-new-offshore-remittance-business-regulations/) - [https://www.fatf-gafi.org/en/countries/detail/Myanmar.html](https://www.fatf-gafi.org/en/countries/detail/Myanmar.html) - [https://home.treasury.gov/news/press-releases/sb0312](https://home.treasury.gov/news/press-releases/sb0312) - [https://home.treasury.gov/news/press-releases/sb0129](https://home.treasury.gov/news/press-releases/sb0129) - [https://www.tilleke.com/insights/myanmar-affirms-cryptocurrency-controls/](https://www.tilleke.com/insights/myanmar-affirms-cryptocurrency-controls/) - [https://ofac.treasury.gov/recent-actions/20261009](https://ofac.treasury.gov/recent-actions/20261009) - [https://www.consilium.europa.eu/en/press/press-releases/2026/04/27/myanmar-eu-restrictive-measures-extended-until-april-2027/](https://www.consilium.europa.eu/en/press/press-releases/2026/04/27/myanmar-eu-restrictive-measures-extended-until-april-2027/) - [https://mfiu.gov.mm/en/home](https://mfiu.gov.mm/en/home) - [https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [https://fintechnews.sg/myanmar/](https://fintechnews.sg/myanmar/) - [https://www.tilleke.com/insights/myanmar-affirms-cryptocurrency-controls/35/](https://www.tilleke.com/insights/myanmar-affirms-cryptocurrency-controls/35/) - [https://www.federalregister.gov/documents/2026/10/15/2026-21085/notice-of-ofac-sanctions-actions](https://www.federalregister.gov/documents/2026/10/15/2026-21085/notice-of-ofac-sanctions-actions) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-june-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-june-2026.html) - [https://www.fatf-gafi.org/en/calendars/events.html](https://www.fatf-gafi.org/en/calendars/events.html) - [https://www.cbsnews.com/news/death-sentences-scam-centers-myanmar/](https://www.cbsnews.com/news/death-sentences-scam-centers-myanmar/) - [https://www.scmp.com/week-asia/people/article/3371148/thai-raid-foils-cross-border-cable-ruse-powering-myanmar-scam-centre](https://www.scmp.com/week-asia/people/article/3371148/thai-raid-foils-cross-border-cable-ruse-powering-myanmar-scam-centre) - [https://thediplomat.com/2026/10/us-drops-sanctions-on-daughter-of-prominent-myanmar-businessman-thein-win-zaw/](https://thediplomat.com/2026/10/us-drops-sanctions-on-daughter-of-prominent-myanmar-businessman-thein-win-zaw/) - [https://www.aljazeera.com/news/2026/10/13/china-sentences-three-people-to-death-for-running-myanmar-scam-centres](https://www.aljazeera.com/news/2026/10/13/china-sentences-three-people-to-death-for-running-myanmar-scam-centres) - [https://www.myanmaritv.com/news/anti-money-laundering-myanmars-position-statement-fatf-public-statement](https://www.myanmaritv.com/news/anti-money-laundering-myanmars-position-statement-fatf-public-statement) - [https://www.irrawaddy.com/news/burma/scam-centers-flooding-myawaddy-town-after-myanmar-junta-crackdown.html](https://www.irrawaddy.com/news/burma/scam-centers-flooding-myawaddy-town-after-myanmar-junta-crackdown.html) - [FinCEN](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-6) - [US Treasury / Federal Register](https://www.federalregister.gov/documents/2026/10/15/2026-21085/notice-of-ofac-sanctions-actions) - [CBS News](https://www.cbsnews.com/news/death-sentences-scam-centers-myanmar/) - [Chiang Rai Times](https://www.chiangraitimes.com/chiang-rai/myanmar-chinese-scam-gang/) - [AMLUAE](https://amluae.com/fatf-grey-list-update-october-2026/) - [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [High-Risk Jurisdictions subject to a Call for Action - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-june-2026.html) - [Outcomes FATF Plenary, 17-19 June 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [Myanmar](https://www.fatf-gafi.org/en/countries/detail/Myanmar.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [High-Risk Jurisdictions subject to a Call for Action - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-october-2025.html) - [Mutual Evaluation of Myanmar](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofmyanmar.html) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [Outcomes FATF Plenary, 11-13 February 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-february-2026.html) - [Burma-Related Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/burma) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Burma Sanctions](https://ofac.treasury.gov/faqs/topic/1536) - [Burma-related Designations and Designation Removal; Issuance of Burma-related General License | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20230621) - [Myanmar: list of designations and sanctions notices - GOV.UK](https://www.gov.uk/guidance/myanmar-list-of-designations-and-sanctions-notices) - [The UK Sanctions List - GOV.UK](https://www.gov.uk/government/publications/the-uk-sanctions-list) - [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service) - [Burma-related Designations; Transnational Criminal Organizations Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250505) - [What the GENIUS Act PPSI Rule Means for Stablecoin Issuers | TRM Labs](https://www.trmlabs.com/resources/blog/what-the-genius-act-ppsi-rule-means-for-stablecoin-issuers) - [481 | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/481) - [The Scam Center Strike Force: A Whole-of-Government Response to Global Crypto Fraud | TRM Labs](https://www.trmlabs.com/resources/blog/the-scam-center-strike-force-a-whole-of-government-response-to-global-crypto-fraud) - [Pig Butchering Gangs, Human Trafficking, and Crypto: An Analysis](https://www.chainalysis.com/blog/pig-butchering-human-trafficking/) - [U.S. Crackdown on Southeast Asian Crypto Scam Centers](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [What is Pig Butchering? Crypto Investment Scam - Chainalysis](https://www.chainalysis.com/glossary/pig-butchering/) - [Scam](https://www.unodc.org/roseap/uploads/documents/KnowScam/english/en-scam.html) - [The behavioral detection of pig butchering scams on blockchain: Flagging suspect wallets and speeding up investigations](https://www.elliptic.co/blog/the-behavioral-detection-of-pig-butchering-scams-on-blockchain-flagging-suspect-wallets-and-speeding-up-investigations) - [US Charges Two Chinese Nationals Over Myanmar Crypto Scam Hub - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-24/us-charges-two-chinese-nationals-over-myanmar-crypto-scam-hub) - [Crypto and Human Trafficking: 2026 Crypto Crime Report](https://www.chainalysis.com/blog/crypto-human-trafficking-2026/) - [The Chinese-language Underground Crypto Money Laundering Ecosystem](https://www.chainalysis.com/blog/2026-crypto-money-laundering/) - [Online scam operations and trafficking into forced criminality in Southeast Asia :](https://digitallibrary.un.org/record/4020504) - [Timeline - EU sanctions against Myanmar - consilium.europa.eu](https://www.consilium.europa.eu/en/policies/sanctions-against-myanmar/timeline-sanctions-against-myanmar/) - [Global Witness welcomes significant new EU sanctions, including on Myanmar state-owned oil and gas company MOGE | Global Witness](https://globalwitness.org/en/press-releases/global-witness-welcomes-significant-new-eu-sanctions-including-on-myanmar-state-owned-oil-and-gas-company-moge/) - [Myanmar: EU restrictive measures extended until April 2027 - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2026/04/27/myanmar-eu-restrictive-measures-extended-until-april-2027/) - [Sanctions against Myanmar - consilium.europa.eu](https://www.consilium.europa.eu/en/policies/sanctions-against-myanmar/) - [UK, EU and Canada impose new sanctions targeting Myanmar military regime and its associates - GOV.UK](https://www.gov.uk/government/news/uk-eu-and-canada-impose-new-sanctions-targeting-myanmar-military-regime-and-its-associates) - [Myanmar/Burma: EU imposes sixth round of sanctions against 9 individuals and 7 entities - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2023/02/20/myanmar-burma-eu-imposes-sixth-round-of-sanctions-against-9-individuals-and-7-entities/) - [US Sanctions Individuals and Companies Linked to Myanmar's Jet Fuel Sector | OCCRP](https://www.occrp.org/en/news/us-sanctions-individuals-and-companies-linked-to-myanmars-jet-fuel-sector) - [Assessing the use of sanctions in response to Myanmar coup | Global Witness](https://globalwitness.org/en/campaigns/transition-minerals/missed-opportunities-assessing-the-use-of-sanctions-in-response-to-myanmar-coup/) - [Myanmar: EU restrictive measures renewed until 30 April 2026 - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/04/25/myanmar-eu-restrictive-measures-renewed-until-30-april-2026/) - [Transnational Criminal Organizations Designations; Burma-related Designations; Global Magnitsky Designations; Cyber-related Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250908) - [Counter Terrorism Designations; Burma-related Designations; Cyber-related Designations; Non-Proliferation Designations and Designation Updates; Iran-related Designation Update | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251112) - [Burma-related Designations; Cyber-related Designation; North Korea Designation; Iraq-related Designation Removal; Publication of Burma-related Determination and Associated Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20230823) - [US Sanctions Myanmar Militia Tied to Cyber-Scams, Human Trafficking | OCCRP](https://www.occrp.org/en/news/us-sanctions-myanmar-militia-tied-to-global-scam-empire-human-trafficking) - [North Korea and Burma-related Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250925) - [U.S. Cracks Down on Myanmar Rebel Group Behind $10 Billion Scam | OCCRP](https://www.occrp.org/en/news/us-cracks-down-on-myanmar-rebel-group-behind-10-billion-scam) - [Myanmar Says It Repatriated 70,000 Foreigners Forced to Work in Scam-Centers | OCCRP](https://www.occrp.org/en/news/myanmar-says-it-repatriated-70000-foreigners-forced-to-work-in-scam-centers) - [Myanmar Military Arrests Hundreds in Raid on Thai-Border Scam Center | OCCRP](https://www.occrp.org/en/news/myanmar-military-arrests-hundreds-in-raid-on-thai-border-scam-center) - [Myanmar: Military Raids Scam Center, Detains Over 2,000 Suspects | OCCRP](https://www.occrp.org/en/news/myanmar-military-raids-scam-center-detains-over-2000-suspects) - [Myanmar Junta Arrests Over 1,600 in Latest Scam Center Raid | OCCRP](https://www.occrp.org/en/news/myanmar-junta-arrests-over-1600-in-latest-scam-center-raid) - [Myanmar Detains Over 10,000 Foreigners in Scam Center Crackdown - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-28/myanmar-detains-over-10-000-foreigners-in-scam-center-crackdown) - [Myanmar/Burma: EU lists three individuals and one entity responsible for scam operations entailing serious human rights violations and threatening the peace, security and stability of Myanmar and the region - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2024/10/29/myanmarburma-eu-lists-three-individuals-and-one-entity-responsible-for-scam-operations-entailing-serious-human-rights-violations-and-threatening-the-peace-security-and-stability-of-myanmar-and-the-region/) - [Myanmar Seizes 10,000 Phones in Online Scams Crackdown - Bloomberg](https://www.bloomberg.com/news/articles/2025-11-19/myanmar-seizes-10-000-phones-in-online-scams-crackdown) - [Jade: Myanmar's "big state secret" | Global Witness](https://www.globalwitness.org/en/campaigns/oil-gas-and-mining/myanmarjade/) - [Jade and Conflict: Myanmar’s Vicious Circle | Global Witness](https://www.globalwitness.org/en/campaigns/natural-resource-governance/jade-and-conflict-myanmars-vicious-circle/) - [How luxury jewellers risk funding military abuses in Myanmar | Global Witness](https://www.globalwitness.org/en/campaigns/natural-resource-governance/conflict-rubies-how-luxury-jewellers-risk-funding-military-abuses-myanmar/) - [Report: Myanmar’s Jade Fuels Military | OCCRP](https://www.occrp.org/en/news/report-myanmars-jade-fuels-military) - [Myanmar | Global Witness](https://www.globalwitness.org/en/all-countries-and-regions/myanmar/) - [Jade and Conflict: Myanmars vicious circle | Global Witness](https://globalwitness.org/en/campaigns/conflict-resources/jade-and-conflict-myanmars-vicious-circle/) - [International ruby sales funding Myanmar military, armed groups and human rights abuses – buyers include top jewellery brands | Global Witness](https://globalwitness.org/en/press-releases/international-ruby-sales-funding-myanmar-military-armed-groups-and-human-rights-abuses-buyers-include-top-jewellery-brands/) - [Jade and the Generals | Global Witness](https://www.globalwitness.org/en/campaigns/myanmar/jade-and-generals/) - [Myanmar’s military tightened its grip on the country’s corrupt jade trade under the NLD | Global Witness](https://www.globalwitness.org/en/press-releases/myanmars-military-tightened-its-grip-on-the-countrys-corrupt-jade-trade-under-the-nld/) - [Global Witness welcomes groundbreaking UN-authorized report calling for international sanctions against Myanmar military businesses | Global Witness](https://www.globalwitness.org/en/press-releases/global-witness-welcomes-groundbreaking-un-authorized-report-calling-international-sanctions-against-myanmar-military-businesses/) - [Report of the Special Rapporteur on the Situation of Human Rights in Myanmar, Thomas H. Andrews](https://digitallibrary.un.org/record/3950241?ln=en) - [Rights expert urges banks to stop financing Myanmar junta weapons trade | UN News](https://news.un.org/en/story/2024/06/1151541) - [UK and international partners target Myanmar arms dealers and military financiers with new sanctions - GOV.UK](https://www.gov.uk/government/news/uk-and-international-partners-target-myanmar-arms-dealers-and-military-financiers-with-new-sanctions) - [MYANMAR Please check against delivery](https://estatements.un.org/estatements/11.0030/20241029100000000/AwPIvILWmRV/KfmwkylJ_vDdo_nyc_en.pdf) - [UN HCR53: Interactive Dialogue with Special Rapporteur on Myanmar - GOV.UK](https://www.gov.uk/government/speeches/un-hcr53-interactive-dialogue-with-special-rapporteur-on-myanmar) - [Report of the Special Rapporteur on the situation of human rights in Myanmar | United Nations in Myanmar](https://myanmar.un.org/en/21890-report-special-rapporteur-situation-human-rights-myanmar) - [UN Human Rights Council 61: UK Statement for the Special Rapporteur on Myanmar - GOV.UK](https://www.gov.uk/government/speeches/un-human-rights-council-61-uk-statement-for-the-special-rapporteur-on-myanmar) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council by identifying high-risk third countries with strategic deficiencies (Text with EEA relevance) (c. 1675)](https://www.legislation.gov.uk/eur/2016/1675/2020-07-09/data.xht?view=snippet&wrap=true) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [Anti-money laundering: the Commission updates its list of high-risk third-country jurisdictions to strengthen the international fight against financial crime - Finance](https://finance.ec.europa.eu/news/anti-money-laundering-commission-updates-its-list-high-risk-third-country-jurisdictions-strengthen-2022-12-20_en) - [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2) - [High-risk third countries](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries) - [HM Treasury publish updated list of high risk third jurisdictions](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasury-publish-updated-list-of-high-risk-third-jurisdictions) - [Changes to the FATF's Public Lists The Money Laundering, ...](https://assets.publishing.service.gov.uk/media/69988878b33a4db7ff889ef3/Annex_C_-_Advisory_Notice_-_February_2026.pdf) - [Notices and updates](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notices/aml) - [The Money Laundering and Terrorist Financing (High-Risk ...](https://www.legislation.gov.uk/uksi/2024/69/made) - [Financial Action Task Force](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-june-2026.html) - [Financial Action Task Force](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html) - [Financial Action Task Force](https://www.fatf-gafi.org/en/countries/detail/Myanmar.html) - [US Department of the Treasury, OFAC](https://ofac.treasury.gov/recent-actions/20250505) - [US Department of the Treasury, OFAC](https://ofac.treasury.gov/recent-actions/20250908) - [US Department of the Treasury, OFAC](https://ofac.treasury.gov/recent-actions/20251112) - [Council of the European Union](https://www.consilium.europa.eu/en/press/press-releases/2026/04/27/myanmar-eu-restrictive-measures-extended-until-april-2027/) - [UK Foreign, Commonwealth & Development Office / OFSI](https://www.gov.uk/guidance/myanmar-list-of-designations-and-sanctions-notices) - [United Nations / UN Special Rapporteur on Myanmar](https://news.un.org/en/story/2024/06/1151541) - [OCCRP](https://www.occrp.org/en/news/myanmar-military-raids-scam-center-detains-over-2000-suspects) - [Global Witness](https://globalwitness.org/en/campaigns/transition-minerals/missed-opportunities-assessing-the-use-of-sanctions-in-response-to-myanmar-coup/) Coverage gaps fim-int-2026-07-05-G001: Independently verifiable Myanmar do… fim-int-2026-07-05-G001: Independently verifiable Myanmar domestic AML/CFT supervisory data and FIU enforcement statistics are absent due to junta information control, limiting reasoning to third-party (FATF/OFAC/EU/UN/NGO/vendor) sourcing. [resolved] fim-int-2026-07-05-G002: No chain-of-custody or shareholder-… fim-int-2026-07-05-G002: No chain-of-custody or shareholder-transparency documentation exists for Myanmar's jade/gemstone licensing regime, preventing verification of specific proceeds flows from mine to global market. [resolved] fim-int-2026-07-05-G003: Sequencing/coordination detail betw… fim-int-2026-07-05-G003: Sequencing/coordination detail between EU, US and UK on the 2022 MOGE sanctioning is documented only at a high level by Global Witness/EarthRights; primary diplomatic-cable-level evidence of the coordination failure is not available. [resolved] fim-int-2026-07-05-G004: Dedicated baseline research with ju… fim-int-2026-07-05-G004: Dedicated baseline research with jurisdiction-level source_quality metrics for Singapore and Thailand (named enabler jurisdictions in the correspondent-banking scheme) has not yet been collected in this pipeline. [resolved] fim-int-2026-07-05-G005: Exact date of the FinCEN Section 31… fim-int-2026-07-05-G005: Exact date of the FinCEN Section 311 action against Huione Group is not established beyond calendar year 2025, preventing precise recency dating of that claim. [resolved] fim-int-2026-08-05-G001: No Tier-1 primary government gazett… fim-int-2026-08-05-G001: No Tier-1 primary government gazette text of AML Law 2026 (Law No.16/2026) was located; confidence rests on secondary reporting. [resolved] fim-int-2026-08-05-G002: Tier-D jurisdictions LA/MX/CO were … fim-int-2026-08-05-G002: Tier-D jurisdictions LA/MX/CO were not searched this cycle, which was scoped to MM. [resolved] fim-int-2026-08-05-G003: No unified public beneficial-owners… fim-int-2026-08-05-G003: No unified public beneficial-ownership register was identified for Myanmar; BO evidence rests on the DICA Directive No.17/2019 and the new AML Law's retention mandate only. [resolved] fim-int-2026-09-28-G001: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-09-28-G001: Tier D jurisdictions (KH, LA, MX, CO) were not independently searched this cycle beyond incidental mentions in Southeast Asia scam-corridor reporting; this is an earned gap, not a finding of no material change. [resolved] fim-int-2026-09-28-G002: Implementing regulations under the … fim-int-2026-09-28-G002: Implementing regulations under the 2026 AML Law, particularly DNFBP scope determinations relevant to casinos and gold traders, were not independently verified this cycle. [resolved] fim-int-2026-09-28-G003: D2, D3 and D4 domains carry thin co… fim-int-2026-09-28-G003: D2, D3 and D4 domains carry thin coverage this cycle; no dedicated beneficial-ownership, enabler-jurisdiction, or conflict-finance development was independently located for Myanmar. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No beneficial-ownership registry mechanics for Myanmar (DICA/company registry) were located this cycle; primary-source access awaited. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No enforcement actions (fines/DPAs) against Myanmar-linked obliged entities were located this cycle. [resolved] fim-int-2026-10-18-G001: Tier-D watch jurisdictions (KH, LA,… fim-int-2026-10-18-G001: Tier-D watch jurisdictions (KH, LA, MX, CO) could not be substantively re-examined within this single-JID Myanmar-bound dispatch. [resolved] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Myanmar beneficial-ownership registry development or crypto/digital-asset integrity development was located this cycle. [resolved] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No FATF October 2026 plenary outcome for Myanmar located this cycle; the review point falls inside this dispatch window. [resolved] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): No MM-specific new OFAC/OFSI/EU sanctions designation found this cycle; D1/D2/D4/D6 thin coverage. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No beneficial-ownership (D2) development was located for Myanmar this cycle. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): Conflict-finance (D4) scam-compound revenue in BGF/EAO territory is referenced qualitatively but not independently quantified this cycle. [open] fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): Tier D jurisdictions (KH/LA/MX/CO) were not independently queried this cycle; search budget concentrated on the bound jurisdiction (MM). [open] fim-int-2026-11-01-G004: Tier D check (KH/LA/MX/CO) not inde… fim-int-2026-11-01-G004: Tier D check (KH/LA/MX/CO) not independently queried this cycle; run-level budget constraint, not a jurisdictional finding. [open] FIM-GAP-001 (D1): UN reporting identified 16 banks across se… FIM-GAP-001 (D1): 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. FIM-GAP-002 (D2): Myanmar's company registry (DICA) does not… FIM-GAP-002 (D2): 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. FIM-GAP-003 (D1): Global Witness/EarthRights International d… FIM-GAP-003 (D1): 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. FIM-GAP-004 (D6): Myanmar's own AML/CFT supervisory data, FI… FIM-GAP-004 (D6): 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 Enacted 11 March 2026 by the National Defence and Security Council, repealing the 2014 AML Law. [[Source 1]](#sec-sources) Probable · 1 source Deleted Theint Win Htet (Burma-EO14014, linked to Zaw Thein Win) from the SDN List on 9 October 2026. [[Source 1]](#sec-sources) Probable · 1 source Prolonged EU restrictive measures on Myanmar for a further twelve months to 30 April 2027, covering 105 individuals and 22 entities. [[Source 1]](#sec-sources) Probable · 1 source Remains on FATF blacklist (High-Risk Jurisdictions Subject to a Call for Action) unchanged since the 19 June 2026 Plenary. [[Source 1]](#sec-sources) Probable · 1 source Financial-technology partnerships reported around 5 January 2026 (digital core and AI credit scoring); no deal value disclosed. [[Source 1]](#sec-sources) Probable · 1 source OFAC unblocked and removed Theint Win Htet from the Burma-related SDN List under EO 14014, effective 9 October 2026, published Federal Register 15 October 2026. [[Source 1]](#sec-sources) Probable · 1 source Chinese courts sentenced three Wei-clan leaders to death, three to life imprisonment, and 55 others to 3-24 years, for operating illegal casinos, telecoms fraud, drug trafficking and forced labour from compounds in Myanmar's Kokang region; funds processed exceeded RMB12.2bn since 2019. [[Source 1]](#sec-sources) Probable · 1 source Thai authorities raided a border village and severed a 48-core fibre-optic cable illegally run across the border, which was powering an illegal casino and suspected scam centre on the Myanmar side. [[Source 1]](#sec-sources) Probable · 1 source Myanmar retained on FATF call-for-action list; February 2027 countermeasures deadline set [[Source 1]](#sec-sources) Probable · 1 source US sanctions easing on a narrow, individual basis (Theint Win Htet delisting, 9 Oct 2026) contrasts with unchanged UK, EU, Canadian and Australian Myanmar sanctions lists this cycle. [[Source 1]](#sec-sources) Probable · 1 source Three Wei-clan Kokang syndicate leaders sentenced to death for scam/casino compounds in Myanmar [[Source 1]](#sec-sources) Probable · 1 source Scam operations demolished at KK Park/Shwe Kokko relocated into Myawaddy town; new base near Mong Hsat raided 21 Oct 2026, 99 Chinese nationals arrested [[Source 1]](#sec-sources) Probable · 1 source Enacted 11 March 2026, repeals 2014 AML Law, extends coverage to digital-currency transactions and foreign residents, CDD and 5-year record retention required [[Source 1]](#sec-sources) Probable · 1 source October 2026 is the point at which FATF will consider countermeasures against Myanmar absent further progress; no plenary outcome located this cycle [[Source 1]](#sec-sources) Probable · 1 source No evidence found of crypto-scam proceeds entering the regulated financial system, consistent with Central Bank of Myanmar's cryptocurrency prohibition [[Source 1]](#sec-sources) Probable · 1 source FATF 30 Oct 2026 Plenary retains Myanmar on call-for-action list; countermeasures to be considered absent progress by February 2027 [[Source 1]](#sec-sources) Probable · 1 source China death sentences for Kokang-compound operators; Myanmar military raid at Mong Hsat 21 Oct 2026 [[Source 1]](#sec-sources) Probable · 1 source OFAC removed Theint Win Htet (Burma, EO 14014) from SDN List effective 2026-10-09 [[Source 1]](#sec-sources) Probable · 1 source China death sentences (13 Oct 2026) and Myanmar military raid (21 Oct 2026) against cross-border scam compound operators [[Source 1]](#sec-sources) Probable · 1 source Theint Win Htet removed from SDN List (Burma, EO 14014), effective 9 Oct 2026 [[Source 1]](#sec-sources) Probable · 1 source