Myanmar

MM schema world-payments-v1 trajectory: not yet assessed

Last updated 2026-10-21 · 14 modules · 64 sourced findings · 118 sources in the cumulative register

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Jurisdiction brief

Latest update · 18 October 2026

Lead Signal

Myanmar's correspondent-banking and settlement-access picture saw a single, narrowly-scoped movement this cycle rather than any structural change. On 9 October 2026 the US Treasury's Office of Foreign Assets Control removed Theint Win Htet from the Burma-related Specially Designated Nationals List, with the Federal Register notice published 15 October 2026. The delisting is individual-scoped: it does not alter the Burma sanctions program established under Executive Order 14014, and it does not change Myanmar's correspondent-banking access architecture generally. For payment-system purposes, this is best read as a single data point within an otherwise unchanged sanctions-constrained environment rather than a signal of loosening correspondent-access conditions for Myanmar-connected flows.

Other Developments

No development was located this cycle across licensing and market access, conduct and safeguarding, stablecoins and digital money, operational resilience, scheme and network compliance, payment corridor dynamics, industry structure, legal and litigation, merchant acquiring, product innovation, consumer protection and APP fraud, AML/CFT, or commercial intelligence. Myanmar's standing payment-corridor position, shaped by the Central Bank of Myanmar's Foreign Remittance Business Regulations under Notification 18/2026 and the overseas-access block on local e-wallets, predates this window and carries forward unchanged.

Cross-Monitor Connections

The OFAC delisting underlying this cycle's sole correspondent-banking data point is also being tracked, in its sanctions-architecture framing, by the financial-integrity monitor, which treats it as an isolated individual-level easing against an otherwise intact EO 14014 program and against unchanged UK, EU, Canadian and Australian Myanmar sanctions lists. Separately, large-scale illicit-finance infrastructure in Myanmar's Kokang borderlands, evidenced this cycle through Chinese court sentences, is a financial-integrity and gambling-regulatory finding with no direct correspondent-banking data point of its own, but it is the kind of enabling-environment condition that typically underlies de-risking and correspondent-access caution by international banks toward Myanmar-connected counterparties generally.

Outlook

Myanmar's correspondent-banking access remains constrained by the Burma EO 14014 sanctions program and by the Central Bank of Myanmar's own foreign-exchange and capital controls. This cycle's sole data point, a narrow individual-level US easing, does not change that constrained baseline. The FATF Plenary scheduled for 26 to 30 October 2026, at which FATF will decide whether to escalate Myanmar from enhanced due diligence to full countermeasures, is the event most likely to affect correspondent-access conditions in the near term, though that decision point falls after this research window closes.

3 earlier updates not shown here.

Standing brief · as of 4 July 2026

Written before the update above. Where they differ, the update is the more recent position.

Lead Signal

Myanmar's payments regime has been baselined this cycle, and it shows a formally coherent licensing architecture operating inside a deeply distressed, increasingly politicised environment. The Central Bank of Myanmar administers a dual bank-led and non-bank mobile-financial-services licensing regime under the Financial Institutions Law of 2016 and the 2016 Mobile Financial Services Regulation. Wave Money became the first non-bank institution licensed under that regime, in August 2016, setting the precedent later followed by KBZPay, AYAPay and CBPay. Yet the same apparatus that licenses providers and mandates segregated safeguarding accounts has, since the 2021 coup, been repurposed for political-security enforcement: junta authorities ordered closure of mobile accounts lacking updated KYC data, and froze at least 721 accounts across KBZPay, WavePay, AYAPay and CBPay in May 2023 on suspicion of anti-junta financing. A parallel digital-currency fault line has also emerged. The CBM formed a Central Committee for the Issuance of a Central Bank Digital Currency under Notification 16/2025 to plan a phased digital-kyat rollout, while the opposition National Unity Government operates a rival Digital Kyat, called DMMK, on the Stellar blockchain via its NUGPay wallet, pegged to the black-market rate and reportedly moving around 2.3 trillion kyat, or roughly US$500 million, across some 38,000 accounts as of March 2025. Correspondent banking access has deteriorated sharply in parallel: Myanmar has remained on the FATF blacklist since October 2022, unchanged as of the February 2026 Plenary, and OFAC sanctioned Myanma Investment and Commercial Bank and Myanma Foreign Trade Bank in June 2023 as the regime's primary foreign-exchange conduits, leaving Myanma Economic Bank's residual network of 48 correspondent banks across 10 countries among the few remaining formal channels.

Other Developments

Operational resilience is the system's most acute vulnerability. CBM-NET, the RTGS/CSD settlement platform, has run under published Business Continuity Planning guidelines since January 2016, but conflict-driven internet shutdowns -- 329 or more recorded since February 2021 -- have repeatedly disrupted deposit, withdrawal and mobile-money availability. The 2021 shutdowns alone are estimated to have cost US$2.8 billion, the largest such loss recorded globally that year, a toll compounded by March 2025 earthquake damage. Scheme compliance is comparatively settled: the Myanmar Payment Union, founded in September 2011, provides domestic ATM/POS switching alongside CBM-permitted co-badging with Visa, Mastercard, JCB and UnionPay, applying a 0.5% off-us interchange fee since 2022 plus per-transaction and weekly ATM withdrawal caps. Corridor dynamics show forced formalisation underway: a 2024 directive requiring migrant workers to remit at least 25% of foreign earnings through official channels helped push formal Thailand-Myanmar remittance flows to US$5.6 billion in 2025, up from just US$670 million in 2022. The MyanmarPay MMQR interoperability standard, built on Mojaloop and officially launched in 2025, is consolidating domestic wallet-to-bank switching alongside that shift. Consumer protection still relies on tiered KYC transaction limits -- Level-1 accounts capped at 400,000 kyat per day, Level-2 at 2,000,000 kyat -- rather than a dedicated authorised-push-payment fraud reimbursement regime, a gap set against the scale of Myanmar's border scam-compound economy, where a single Chinese-operated company at KK Park is estimated to have moved over US$100 million in cryptocurrency through Tether-based fraud schemes.

Cross-Monitor Connections

Three strands of this baseline sit outside the Monitor's payments-infrastructure remit and have been flagged to the Financial Intelligence Monitor. The NUG's DMMK stablecoin, tied to reported financing of over US$11.5 million in civil-war donations, raises sanctions-evasion questions beyond WPM's payment-instrument-trust scope. The OFAC designation of MICB and MFTB as regime foreign-exchange conduits implicates a sanctions-compliance surface broader than correspondent-banking infrastructure alone. And the exploitation of crypto and mobile-wallet rails by trafficking-linked scam compounds such as KK Park, tied to an estimated 120,000 trafficked workers per the UN Human Rights Office, is an illicit-finance question for FIM, not a WPM conclusion about the instruments themselves.

Outlook

Myanmar's payments environment is likely to stay bifurcated along the fault lines set out this cycle: a functioning bank/non-bank licensing and settlement architecture running alongside a politicised conduct-enforcement track, a junta-versus-opposition digital-currency contest, and a correspondent-banking network narrowed to a small set of residual channels. Watch points for the next cycle include further FATF Plenary treatment of Myanmar's blacklist status, the pace of the CBM's CBDC committee work under Notification 16/2025, and whether further FX-dealer or mobile-account enforcement actions extend the licence-revocation and account-freeze pattern already documented in this baseline.

trust tier: ai_unverified

Latest update · 28 September 2026

Regulatory Status

Myanmar's payments regulatory picture this cycle is defined by a single licensing development: the Central Bank of Myanmar's 18 May 2026 Offshore Remittance Business Regulations, which repeal 2019-era rules and expand licensing and reporting obligations for offshore remittance operators, agents, and branch offices. This is a non-bank payment-institution and e-money-issuer channel development, distinct from bank-operated correspondent arrangements, and it is consistent with the broader post-2021 foreign-exchange control environment that continues to shape Myanmar's cross-border payments landscape. The finding rests on a single Tier 3 secondary source, with the Central Bank's own primary notification text not independently retrieved this cycle, so the specific compliance thresholds described in secondary reporting should be treated as probable pending primary verification.

Outlook

Watch for retrieval and confirmation of the Central Bank's primary notification text, which would clarify the specific licensing thresholds and any transition arrangements for existing remittance agents and branch offices. Continued tightening of the non-bank remittance channel would be consistent with Myanmar's existing foreign-exchange control trajectory.

2 earlier updates not shown here.

Standing brief · as of 4 July 2026

Written before the update above. Where they differ, the update is the more recent position.

Regulatory Status

Myanmar's payments regulatory status this cycle is best described as a formally coherent architecture operating inside acute conflict-driven stress and international isolation. Licensing rests on a dual bank-led and non-bank mobile-financial-services regime under the Financial Institutions Law of 2016 and the 2016 Mobile Financial Services Regulation, a framework active enough to have licensed Wave Money as its first non-bank entrant in August 2016 and to sustain periodic foreign-exchange dealer licence revocations, including nine dealers in March 2024. Conduct and safeguarding present a similar duality: segregated trust-account safeguarding with daily reconciliation coexists with a politicised post-coup enforcement track that has closed mobile accounts and frozen at least 721 accounts across major wallets in May 2023 on national-security grounds. Digital money is genuinely bifurcated: the CBM's blanket crypto and stablecoin prohibition under Directive 9/2020 sits alongside its own Central Committee for the Issuance of a Central Bank Digital Currency under Notification 16/2025, while the opposition National Unity Government operates a rival Digital Kyat, DMMK, moving an estimated US$500 million across some 38,000 accounts as of March 2025. Operational resilience is dominated by conflict rather than by planning gaps: CBM-NET carries a formal Business Continuity Planning framework, but 329 or more internet shutdowns since February 2021, plus March 2025 earthquake damage, have repeatedly disrupted banking and mobile-money availability. Scheme compliance and merchant acquiring are comparatively settled, with the Myanmar Payment Union co-badging alongside international schemes and CBM Notification 7/2020 authorising bank and non-bank acquirers, though formal chargeback rules remain thinly documented. Corridor dynamics show forced formalisation, with a 2024 directive pushing formal Thailand-Myanmar remittance flows to US$5.6 billion in 2025, alongside the MyanmarPay MMQR interoperability rollout. Consumer protection relies on tiered KYC transaction limits rather than a dedicated fraud-reimbursement regime, set against a large-scale border scam-compound economy exploiting crypto and wallet rails. Myanmar remains on the FATF blacklist since October 2022, and OFAC's June 2023 sanctions on Myanma Investment and Commercial Bank and Myanma Foreign Trade Bank have left Myanma Economic Bank's 48-correspondent network as one of the few remaining formal channels. Commercial activity this cycle is regulator-led, concentrated in the CBM's CBDC committee formation and incumbent super-app marketing, with no disclosed third-party M&A identified.

Outlook

Myanmar's payments environment is likely to remain defined by parallel, sometimes contradictory tracks: functioning formal infrastructure operating alongside politicised enforcement, conflict-driven disruption, and a bifurcated digital-currency contest between the CBM and the opposition. Correspondent-banking access is likely to keep narrowing rather than stabilising, and FATF Plenary treatment of Myanmar's blacklist status, further CBM enforcement actions, and the pace of CBDC committee work under Notification 16/2025 are the principal watch points for the next cycle.

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Signal

Density

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Non-bank cross-border remittance business in Myanmar is now governed by CBM Notification No. 18/2026 (28 Apr 2026), which replaced the 2019 licensing framework with tighter beneficial-owner/management vetting, an escrow security deposit, and a 3-year licence validity.

Standing sub-brief · as of 4 July 2026226 words · last cycle 2026-09-28

Licensing, Authorisation & Market Access

Myanmar's payments market access rests on two coexisting legal instruments administered by the Central Bank of Myanmar: the Financial Institutions Law of 2016 and the CBM's 2016 Mobile Financial Services Regulation. Together they establish a bank-led licensing route alongside a non-bank mobile-financial-services track, the latter requiring a minimum paid-up capital of MMK 3 billion and registration as an NBFI or non-bank MFS licence holder. Wave Money became the first non-bank institution licensed under this regime in August 2016, a grant that set the precedent for mobile-network-operator and non-bank market entry later followed by KBZPay, AYAPay and CBPay. Licensing enforcement extends well beyond mobile-financial-services providers to the foreign-exchange dealer population, and it remains active: in March 2024 the CBM revoked or suspended the licences of nine foreign-currency dealer companies, following a much larger September 2023 mass revocation that affected 123 money-changer companies.

Periodic update · new data 2026-09-28

Licensing, Authorisation & Market Access

The Central Bank of Myanmar issued new Offshore Remittance Business Regulations on 18 May 2026, repealing the previous rules under CBM Notification No. 21/2019 and expanding licensing and reporting requirements for remittance agents and branch offices. This is a market-access development squarely within the non-bank payment institution and e-money issuer channel: offshore remittance operators, as distinct from bank-operated correspondent channels, are the direct subject of the new licensing conditions. The regulation sits within a national federal regulatory layer, issued by Myanmar's central monetary authority acting under its own notification power rather than through primary legislation, and it repeals and replaces a seven-year-old regulatory instrument rather than amending it incrementally.

The finding rests on a single Tier 3 secondary source; the Central Bank's own primary notification text was not independently retrieved this cycle, so the specific scope of the expanded licensing and reporting requirements, including whether existing licensed agents face a transition period or immediate compliance obligations, remains probable rather than confirmed. This licensing tightening is consistent with, and should be read against, Myanmar's broader post-2021 foreign-exchange control environment, in which cross-border payment channels generally face closer supervisory scrutiny than in a liberalised payments market. The distinction between bank-operated and non-bank payment-institution channels is material here: this instrument speaks to the non-bank remittance-agent and branch-office structure specifically, and no parallel bank-channel licensing change has been identified this cycle.

Outlook

The primary open question is whether the Central Bank's own notification text, once retrieved, confirms the specific licensing thresholds and reporting obligations described in secondary reporting, and whether existing remittance agents and branch offices face a defined transition period. Given the trajectory already evident in this instrument, further tightening of the non-bank remittance channel would be consistent with Myanmar's broader foreign-exchange control posture rather than a departure from it.

2 earlier distinct update(s)

Periodic update · new data 2026-09-14

Licensing, Authorisation & Market Access

Myanmar's non-bank remittance licensing framework underwent a substantial overhaul this cycle with the Central Bank of Myanmar's issuance of Notification No. 18/2026 on 28 April 2026, which replaces the 2019 remittance-licensing framework in its entirety. The new regime imposes a materially higher entry bar for applicants: beneficial-owner, management and shareholder disclosure is now required, alongside criminal-record certificates for relevant individuals, a level of scrutiny not present under the prior framework.

Alongside the disclosure requirements, licensees must now maintain a security deposit held in an escrow account at an authorised-dealer bank, plus a separate revolving fund account dedicated to remittance transactions. This dual-account structure functions as a safeguarding-adjacent capital requirement for the non-bank payment-institution/EMI category specifically, distinguishing the treatment of these non-bank licensees from the bank-channel remittance business, which operates under separate prudential and licensing arrangements as an authorised-dealer institution rather than under Notification 18/2026's non-bank licensing track.

A further structural change concerns the treatment of foreign partners and representatives. Where a licence application names such a party, the applicant must now provide evidence that the foreign partner holds a valid remittance licence in its own home jurisdiction. This extends CBM's licensing due-diligence beyond Myanmar's domestic entity into the corridor's foreign counterparty leg, a cross-border market-access control that raises the effective bar for entities seeking to establish remittance corridors touching Myanmar even where the Myanmar-side entity itself is straightforward to license.

Offsetting this tightened entry bar, the same Notification 18/2026 reversed the 2019 definition under which agent or branch offices were overseas-appointed, moving to a Myanmar-appointed model, and removed the prior per-transaction cap of USD 1,000 and monthly cap of USD 5,000 that had constrained non-bank remittance volume. This produces the bifurcated posture that defines this cycle's Myanmar payments picture: a higher bar to become a licensed non-bank remittance operator, paired with materially greater transactional freedom once licensed.

Outlook

The key open question is the transition arrangement for entities licensed under the superseded 2019 framework: whether they face a grace period, a re-application requirement, or automatic grandfathering under Notification 18/2026's new BO-disclosure and escrow-deposit requirements was not evidenced this cycle and represents a material gap for market-access assessment. The interaction between the tightened entity bar and the loosened transaction ceiling will determine whether overall licensed remittance volume through Myanmar rises or falls over the coming reporting periods.

Periodic update · new data 2026-08-26

Licensing, Authorisation & Market Access

Myanmar's non-bank payment and mobile-financial-services market access continues to run on the Central Bank of Myanmar's Regulation on Mobile Financial Services, dated 30 March 2016. This is a High-confidence, Tier-3-sourced finding for the regulation's content and a Tier-1-sourced finding for the Central Bank's separately published current list of licensed Mobile Financial Service Providers. Applicants must hold a CBM registration certificate, and MFS transactions conducted under this framework are restricted to Myanmar kyat. There is no dedicated, more recent electronic-money-institution or payment-institution statute; the 2016 MFS Regulation remains the operative legal basis a decade after its issuance.

The published licensed-provider list itself is analytically significant beyond its function as a registry: it is one of relatively few Tier-1 primary-source Central Bank publications available for Myanmar's payments sector this cycle, and its continued maintenance and publication indicates that, notwithstanding the country's broader political instability, the Central Bank continues to perform at least the basic administrative functions of licensing-list maintenance for the non-bank payments sector. Both bank and non-bank entities are captured by the underlying regulatory basis, though the licensed-provider list itself is understood to be a non-bank-PI/EMI-facing registry.

Outlook

Watch for any successor statute to the 2016 MFS Regulation, which would be a material development given the regulation's age relative to the pace of change in Myanmar's payments landscape, including the MyanmarPay/MMQR interoperability initiative and the CBDC committee's work. Watch also for movement, additions, or removals on the published licensed-MFSP list, as the most current available indicator of non-bank market structure.

Sources and findings (6)

T1https://servicetrade.gov.mm/service/law-detail/financial%20institutions%20lawretrieved 2026-07-04
T1https://servicetrade.gov.mm/service/regulation-detail/regulations-on-mobile-financial-serviceretrieved 2026-07-04
T3https://enterslice.com/mm/mobile-financial-service-licenseretrieved 2026-07-04
T3https://en.wikipedia.org/wiki/Wave_Moneyretrieved 2026-07-04
T2https://www.myanmaritv.com/news/mmqr-payment-mmqr-merchant-acquiring-service-launchedretrieved 2026-07-04
T3https://eng.mizzima.com/2024/03/17/8106retrieved 2026-07-04

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Safeguarding of MFS customer float is mandated via segregated trust/deposit accounts at partner commercial banks with daily reconciliation duties, tiered KYC limits, and CBM suspension/revocation powers for non-compliance. Post-coup, conduct enforcement has taken on a political-security dimension, with the CBM ordering mass account closures/upgrades framed as fraud prevention but also used to monitor and disrupt suspected anti-junta financial flows.

Standing sub-brief · as of 4 July 2026164 words · last cycle 2026-08-25

Conduct, Safeguarding & Promotions

Myanmar's mobile financial service providers must safeguard customer float through segregated trust or deposit accounts held at partner commercial banks, reconciled daily by 4pm local time, with a duty to replenish the account if the liquidity receivable falls short. That formal safeguarding regime sits alongside a starkly different conduct track: junta authorities have ordered the closure of mobile payment accounts, including KPay and WavePay accounts, lacking updated KYC information, and in May 2023 froze at least 721 mobile accounts across KBZPay, WavePay, AYAPay and CBPay on suspicion of anti-junta financing.

Periodic update · new data 2026-08-26

Conduct, Safeguarding & Financial Promotions

Myanmar's conduct-and-CDD overlay tightened on two fronts this cycle. The Central Bank of Myanmar's digital-payment transaction-limit framework, in effect since 12 June 2024, continues to cap peer-to-peer payments at 1 million kyats per transaction and 5 million kyats daily, applying to both bank and non-bank payment-service providers. Layered directly on top of that existing conduct control, the Anti-Money Laundering Law 2026 now imposes a five-year retention obligation for customer due-diligence and beneficial-ownership records, together with a mandatory senior-level compliance-officer appointment, on Myanmar reporting organizations. Both obligations apply without a bank-versus-non-bank distinction: a non-bank e-money or payment-institution operator faces the same transaction-limit conduct control and the same new CDD-retention and compliance-officer mandate as a CBM-licensed bank.

This is a conduct-overlay tightening rather than a safeguarding-specific development in the ring-fenced client-money sense; Myanmar's evidenced conduct architecture this cycle centers on transaction-value limits and CDD/beneficial-ownership record-keeping duration rather than on client-asset segregation requirements. The practical effect for any payment-service provider — bank or non-bank — operating in Myanmar is a compounding compliance burden: an existing transaction-value ceiling now sits alongside a materially longer beneficial-ownership record-retention duty and a new compliance-officer staffing requirement, all attaching to the same licensed population without differentiation by institutional type.

Both developments carry High confidence in this cycle's evidence, sourced from Tier-2 legal-alert reporting; no primary CBM circular text or AML Law 2026 gazette text was directly located, meaning both conduct-overlay findings rest on secondary rather than primary-source confirmation.

Outlook

The AML Law 2026's not-yet-published implementing directives will determine the detailed operational content of the new compliance-officer and CDD obligations for both bank and non-bank payment-service providers, while the CBM's digital-payment transaction limits remain a stable, unchanged conduct control this cycle. The compounding effect of a stable transaction-limit regime and a newly tightened CDD/retention regime is the conduct-overlay picture to track into the next cycle, particularly for non-bank payment-institution and e-money-issuer operators who face the identical obligation set as licensed banks without any lighter-touch conduct track.

Sources and findings (5)

T1https://servicetrade.gov.mm/service/regulation-detail/regulations-on-mobile-financial-serviceretrieved 2026-07-04
T1https://servicetrade.gov.mm/service/regulation-detail/regulations-on-mobile-financial-serviceretrieved 2026-07-04
T3https://www.bnionline.net/en/news/concerns-over-myanmar-junta-mobile-payment-termsretrieved 2026-07-04
T3https://www.rfa.org/english/news/myanmar/accounts-06052023092340.htmlretrieved 2026-07-04
T3https://www.kbzpay.com/en/privacy-policyretrieved 2026-07-04

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Myanmar has no licensing or legislative framework for cryptocurrency or stablecoins; the CBM maintains a blanket prohibition (Directive 9/2020, reiterated in a May 2024 public notice) enforced via account freezes and prosecutions under the AML Law, Financial Institutions Law and CBM Law. In parallel, the CBM formed a Central Committee for the Issuance of a Central Bank Digital Currency (digital kyat) in 2025, while the opposition National Unity Government operates its own de facto stablecoin/CBDC (DMMK/NUGPay) outside CBM control.

Standing sub-brief · as of 4 July 2026220 words · last cycle 2026-07-04

Stablecoins & Digital Money

The Central Bank of Myanmar prohibits the sale, purchase, exchange or transfer of unregulated digital currencies and stablecoins under Directive 9/2020, a ban it reiterated in a 24 May 2024 public notice threatening account closure and legal action against violators. Alongside that blanket prohibition, the CBM formed a Central Committee for the Issuance of a Central Bank Digital Currency under Notification 16/2025, with State Administration Council approval dated 1 May 2025, tasked with researching and phasing a digital-kyat rollout rather than deploying one immediately. The opposition National Unity Government operates a rival digital-currency system entirely outside CBM control: a Digital Kyat, or DMMK, issued on the Stellar blockchain via the NUGPay wallet and pegged to the black-market kyat rate, with approximately 2.3 trillion kyat, or roughly US$500 million, transacted as of March 2025 across some 38,000 accounts, alongside a USD-pegged nUSDT token introduced in 2023.

no periodic updates on record for this sub-brief

Sources and findings (5)

T1https://www.tilleke.com/insights/myanmars-central-bank-issues-further-warning-against-crypto-trading/retrieved 2026-07-04
T2https://www.lightspark.com/knowledge/is-crypto-legal-in-myanmarretrieved 2026-07-04
T1https://www.dfdl.com/insights/legal-and-tax-updates/central-bank-establishes-digital/retrieved 2026-07-04
T3https://www.elliptic.co/blog/the-digital-kyat-tracing-the-cbdc-financing-over-11.5-million-in-civil-war-donations-to-myanmars-oppositionretrieved 2026-07-04
T3https://www.lowyinstitute.org/publications/china-s-myanmar-project-could-end-us-sanctionsretrieved 2026-07-04

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CBM-NET (Myanmar's RTGS/CSD platform, live since January 2016) carries formal Business Continuity Planning guidelines, but the wider payments operating environment suffers acute, recurring operational-resilience stress from conflict-driven telecom infrastructure destruction and government-imposed internet shutdowns, which repeatedly disrupt banking deposit/withdrawal services and mobile-money availability.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. Open this jurisdiction's page on Dataprotection.gi →

Standing sub-brief · as of 4 July 2026147 words · last cycle 2026-07-04

Operational Resilience & Critical Infrastructure

CBM-NET, Myanmar's RTGS/CSD settlement platform, has operated under published Business Continuity Planning guidelines since it went live in January 2016. That formal framework sits against a starkly different operational reality: conflict-driven internet shutdowns, 329 or more of them recorded since February 2021, have repeatedly disrupted banking deposit and withdrawal services and mobile-money availability, with the 2021 shutdowns alone estimated to have cost US$2.8 billion, the largest such economic loss recorded globally that year, a toll further compounded by damage from the March 2025 earthquake.

no periodic updates on record for this sub-brief

Sources and findings (5)

T1https://www.cbm.gov.mm/content/national-payment-system-myanmarretrieved 2026-07-04
T3https://progressivevoicemyanmar.org/2024/07/16/no-end-in-sight-situation-of-internet-shutdown-and-infrastructure-damages-in-myanmarretrieved 2026-07-04
T3https://fulcrum.sg/myanmars-internet-shutdowns-silencing-resistance-in-the-battle-for-connectivity/retrieved 2026-07-04
T3https://borgenproject.org/myanmars-internet-shutdowns/retrieved 2026-07-04
T3https://thefintechtimes.com/myanmar-and-fintech-under-pressure-in-a-fragmented-economy/retrieved 2026-07-04

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The Myanmar Payment Union (MPU), founded in 2011 by state and private banks under CBM direction, is the domestic card scheme providing ATM/POS switching, with the CBM subsequently permitting international schemes (Visa, Mastercard, JCB, UnionPay) to operate domestically and co-badge with MPU. A published interchange fee structure (0.5% for off-us cash withdrawals from 2022) and standard ATM withdrawal limits exist; PCI-DSS-aligned POS acceptance is provided by acquiring banks and gateways.

Standing sub-brief · as of 4 July 2026129 words · last cycle 2026-07-04

Scheme & Network Compliance

Myanmar Payment Union, founded on 15 September 2011 and counting 23 member banks by 2017, operates the country's domestic card scheme, providing ATM and POS switching while the Central Bank of Myanmar permits international schemes -- Visa, Mastercard, JCB and UnionPay -- to operate domestically and co-badge with MPU. MPU applies a 0.5% interchange fee on off-us cash withdrawals, effective from 2022, alongside a 500,000 kyat per-transaction cap and a 2,000,000 kyat weekly ATM withdrawal cap for its cardholders.

no periodic updates on record for this sub-brief

Sources and findings (4)

T3https://en.wikipedia.org/wiki/Myanmar_Payment_Unionretrieved 2026-07-04
T1https://www.cbm.gov.mm/content/national-payment-system-myanmarretrieved 2026-07-04
T2https://www.myanmarpaymentunion.com/faqsretrieved 2026-07-04
T3https://www.yomabank.com/en/news-and-activities/yom-bank-launches-the-first-co-badged-mpu-mastercard-debit-card/retrieved 2026-07-04

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The Thailand-Myanmar corridor, spanning over 2,400 km and among the 20 largest migration corridors globally, dominates Myanmar's remittance flows, historically reliant on informal hundi channels but increasingly forced into formal banking rails via a 2024 directive requiring migrant workers to remit at least 25% of foreign earnings through official channels. Domestically, the MyanmarPay MMQR national QR interoperability standard (implemented 2022, launched 2025, operated by PayPlus/MyanmarPay Co.) is unifying wallet/bank payment acceptance on Mojaloop-based infrastructure.

Standing sub-brief · as of 4 July 2026153 words · last cycle 2026-09-05

Payment Corridor Dynamics

The Thailand-Myanmar remittance corridor is subject to a forced-formalisation directive, introduced in 2024, requiring migrant workers to remit at least 25% of their foreign earnings through official banking channels. Formal remittances on the corridor rose to US$5.6 billion in 2025, around 38% of Myanmar's foreign-exchange inflows, up sharply from just US$670 million in 2022. Alongside that shift, MyanmarPay MMQR has become the national QR-code interoperability standard, implemented from 2022 and officially launched in 2025, operated by PayPlus/MyanmarPay Co. as a central switch built on Mojaloop open-source software that enables interoperable payments across banks and mobile wallets.

Periodic update · new data 2026-09-14

Payment Corridor Dynamics

On 7 January 2026 the Central Bank of Myanmar announced Notification No. 2/2026, a further relaxation of foreign-exchange regulations that builds on the compulsory-conversion regime introduced in 2022. This is a corridor-level liberalisation measure operating on general foreign-exchange controls, distinct from the remittance-licensing regime addressed separately under CBM Notification 18/2026, though the two instruments interact directly for any cross-border payment corridor touching Myanmar that involves both foreign-currency conversion and licensed remittance activity.

The corridor-dynamics significance of Notification 2/2026 lies in its direction: it is a relaxation, not a tightening, and it arrives within the same regulatory year as the licensing-side tightening described under W1a. Read together, the CBM appears to be pursuing a strategy in which the currency-conversion and transaction-volume dimensions of Myanmar's payment corridors are being loosened even as the entity-level control over who may operate as a licensed remittance provider is being tightened. This is consistent with a regulator seeking to expand formal, licensed payment-corridor volume while simultaneously raising the compliance and ownership-transparency bar for the entities permitted to carry that volume.

No specific corridor-pair data, such as remittance-flow volumes between Myanmar and particular partner jurisdictions, was evidenced this cycle, and the finding here rests at the level of general FX-control policy direction rather than corridor-specific settlement or volume detail.

Outlook

Whether Notification 2/2026's FX relaxation, combined with the removal of remittance transfer caps under Notification 18/2026, produces an observable increase in formal cross-border payment-corridor volume through Myanmar over the coming cycles is the key indicator to watch. This would require corridor-level volume data not available this cycle to confirm.

1 earlier distinct update(s)

Periodic update · new data 2026-08-26

Payment Corridor Dynamics

Central Bank of Myanmar foreign-exchange and currency-control directives materially constrain formal cross-border payment settlement, an Assessed-confidence, Tier-1-sourced finding reflecting the country's post-2021 political and macro-financial context. This constraint operates at the level of the currency and capital-control regime itself rather than through a single dated directive, and it shapes the broader payment-corridor environment within which both bank and non-bank payment flows into and out of Myanmar must operate.

This corridor-level constraint is the structural backdrop against which Myanmar's domestic payments-modernisation initiatives, MyanmarPay/MMQR and the CBDC committee, should be read: both are domestically-facing initiatives that do not directly address formal cross-border settlement capacity, which remains constrained by currency-control policy rather than by payment-rail technology. The persistence of this constraint, combined with correspondent-banking de-risking pressure tied to Myanmar's FATF status, describes a payment-corridor environment in which formal cross-border rails are narrowing even as domestic rails are being modernised.

Outlook

Watch for any easing or further tightening of Central Bank foreign-exchange and currency-control policy, which would be the primary driver of any change to Myanmar's formal cross-border payment-corridor capacity. In the absence of such a policy shift, this corridor dynamic should be treated as a stable structural constraint rather than an evolving one.

Sources and findings (5)

T2https://thailand.iom.int/sites/g/files/tmzbdl1371/files/documents/2025-03/myanmar_migrants_thailand_jan25_final-1.pdfretrieved 2026-07-04
T3https://mekongmigration.org/?p=24805retrieved 2026-07-04
T2https://amro-asia.org/wp-content/uploads/2024/07/AMRO-Analytical-Note_Remittances-in-Myanmar-Recent-Developments-and-Outlook.pdfretrieved 2026-07-04
T3https://www.lightspark.com/knowledge/instant-payments-myanmarretrieved 2026-07-04
T3https://www.kbzbank.com/en/remittance/international-remittance/retrieved 2026-07-04

#

Myanmar's banking sector remains capital-constrained and highly concentrated at the top tier, with 77% of the population unbanked. Digital payments are dominated by a handful of super-apps (KBZPay, Wave Money) and bank-linked wallets (AYAPay, CB Pay), overlaid by the CBM's interoperable MMQR standard. Post-coup political risk drove Telenor's exit from Wave Money, while Chinese fintech capital (Ant Group) has entered via minority stakes.

Standing sub-brief · as of 4 July 2026131 words · last cycle 2026-07-04

Industry Structure & Commercial Dynamics

Myanmar's banking sector remains severely capital-constrained and highly concentrated, with 77% of the population unbanked -- the highest rate in the region -- according to Roland Berger's 2025 study. Ownership of the leading mobile-wallet operators has shifted sharply since the 2021 coup: Telenor Group exited its stake in Wave Money amid post-coup regulatory uncertainty, a reversal from May 2020, when Ant Financial Group had invested US$73.5 million intending a 33% stake in the company.

no periodic updates on record for this sub-brief

Sources and findings (4)

T3https://www.rolandberger.com/en/Media/Myanmar-banking-industry-2025.htmlretrieved 2026-07-04
T3https://www.cbinsights.com/company/digital-money-myanmarretrieved 2026-07-04
T3https://en.wikipedia.org/wiki/Wave_Moneyretrieved 2026-07-04
T3https://marketingmyanmar.com/digital-payment-marketing-in-myanmar-kbzpay-wave-money-ayapay-and-beyond/retrieved 2026-07-04

#

Enforcement activity centres on CBM licence revocations against non-compliant foreign-exchange dealers/money changers, criminal prosecutions of individuals for crypto-linked currency conversion under the AML and Financial Institutions Laws, and a distinct national-security enforcement track targeting mobile-payment accounts linked to anti-junta financing. Myanmar remains on the FATF blacklist (since October 2022), the most severe multilateral AML/CFT enforcement designation.

Standing sub-brief · as of 4 July 2026148 words · last cycle 2026-07-04

Legal & Litigation

Myanmar remains designated on the FATF blacklist, alongside Iran and North Korea, since October 2022, a status unchanged as of the February 2026 FATF Plenary and representing the most severe multilateral AML/CFT designation available. Criminal enforcement against crypto activity is active at the individual level too: in an August 2024 case, a Yangon-based USDT trader was sentenced to 18 months' imprisonment for converting USDT to kyat via a peer-to-peer platform, with the CBM separately ordering closure of both his personal and business bank accounts.

no periodic updates on record for this sub-brief

Sources and findings (5)

T3https://eng.mizzima.com/2024/03/17/8106retrieved 2026-07-04
T1https://www.gnlm.com.mm/cbm-suspends-two-money-changer-licences-for-three-months/retrieved 2026-07-04
T4https://tokenfollow.com/myanmar-crypto-account-closure-penalties-what-you-need-to-knowretrieved 2026-07-04
T3https://sanctionslawyers.net/blog-en/the-fatf-grey-list-and-blacklist-complete-guide/retrieved 2026-07-04
T3https://www.rfa.org/english/news/myanmar/accounts-06052023092340.htmlretrieved 2026-07-04

#

Merchant acquiring in Myanmar operates under the CBM's Merchant Acquiring Service directive (Notification 7/2020), with bank acquirers (e.g. Yoma Bank, MOB, AYA) and four CBM-authorised non-bank acquirers running POS/QR acceptance alongside international gateways such as 2C2P. Merchant discount rates (MDR), Know-Your-Merchant (KYM) onboarding, and same-day/T+1 settlement cycles are standard; consumer/merchant dispute and chargeback frameworks remain thinly documented in public sources.

Standing sub-brief · as of 4 July 2026139 words · last cycle 2026-07-04

Merchant Acquiring & Risk

CBM Notification 7/2020, the Merchant Acquiring Service directive, authorises merchant-acquiring services via bank acquirers -- including Yoma Bank, MOB and AYA Bank -- and four CBM-authorised non-bank institutions, Trusty, OK$, Zego Pay and Unipay, for QR and POS acceptance under the National Standard Code MMQR. At the acquirer level, Yoma Bank's SMILE POS product requires merchants to complete Merchant Discount Rate disclosure for MPU, Visa, Mastercard and QR transactions, plus Know-Your-Merchant documentation at onboarding, with settlement options of 30-minute, same-day or T+1 timing.

no periodic updates on record for this sub-brief

Sources and findings (4)

T2https://www.myanmaritv.com/news/mmqr-payment-mmqr-merchant-acquiring-service-launchedretrieved 2026-07-04
T3https://www.yomabank.com/en/business/pos-payment/retrieved 2026-07-04
T3https://www.mobmyanmar.com/?page_id=3110retrieved 2026-07-04
T4https://www.hulkapps.com/blogs/shopify-payment-providers/2c2p-payment-gateway-shopify-integration-in-myanmarretrieved 2026-07-04

#

Product innovation centres on the CBM's national interoperability push (MMQR/PayPlus, built on Mojaloop) and the nascent digital-kyat CBDC pilot under the newly formed Central Committee for CBDC Issuance. Historical blockchain-remittance pilots (Everex) and super-app expansion (KBZPay mini-apps) round out the innovation picture, occurring against a backdrop of sanctions, conflict, and currency instability that constrain investor-backed fintech build-out.

Standing sub-brief · as of 4 July 2026151 words · last cycle 2026-08-25

Product Innovation & Market Development

The Central Bank of Myanmar is developing a phased digital-kyat rollout plan through the newly formed Central Committee for the Issuance of Central Bank Digital Currency established under Notification 16/2025, a product-development counterpart to the regulatory framing of the same committee described elsewhere in this baseline. Historically, Everex piloted a distributed-ledger cross-border remittance service in partnership with Shwe Urban and Rural Development Bank, targeting the Myanmar-Thailand migrant-worker corridor with the aim of cutting remittance fees and transfer times to under a minute, though its current operating status is unconfirmed.

Periodic update · new data 2026-08-26

Product Innovation & Market Development

Myanmar's Central Bank launched MyanmarPay, a national standardised QR-code interoperable payment system, on 27 February 2025, built on Mojaloop open-source payment-switching rails and operated through the national switch operator PayPlus. This is a Probable-confidence finding given its Tier-4 sourcing, and it represents the most significant product-innovation development in Myanmar's payments landscape this cycle: an official attempt to unify bank and mobile-money interoperability under a single national QR standard, known as MMQR, rather than leaving interoperability to bilateral arrangements between individual providers.

In parallel, the Central Bank established a Central Committee for the Issuance of a Central Bank Digital Currency in June 2025, tasked with developing a state-controlled digital kyat. This is an Uncertain-confidence, Tier-4-sourced finding given its early-stage, committee-level status; no pilot, technical design, or issuance timeline has been evidenced this cycle. The CBDC initiative is explicitly positioned as an alternative to, rather than an integration with, decentralised cryptocurrency, consistent with the Central Bank's separate and unrelated blanket cryptocurrency prohibition.

Together, MyanmarPay and the CBDC committee describe a coherent state strategy of centralising and modernising domestic payment-rail infrastructure under direct Central Bank control, pursued in parallel with, rather than as a response to, the country's deepening correspondent-banking isolation.

Outlook

Watch for MyanmarPay/MMQR adoption data, additional participating institutions, or merchant-acceptance metrics, as the leading indicator of whether the interoperability initiative achieves real usage beyond its official launch. Watch separately for any public output from the CBDC committee, including a pilot announcement or legislative framework, though its early-stage status means no near-term digital-kyat launch should be expected.

Sources and findings (4)

T3https://www.lightspark.com/knowledge/instant-payments-myanmarretrieved 2026-07-04
T1https://www.dfdl.com/insights/legal-and-tax-updates/central-bank-establishes-digital/retrieved 2026-07-04
T3https://www.fintechfutures.com/blockchain-crypto-digital-assets/everex-to-create-myanmar-thailand-blockchain-payments-corridorretrieved 2026-07-04
T3https://marketingmyanmar.com/digital-payment-marketing-in-myanmar-kbzpay-wave-money-ayapay-and-beyond/retrieved 2026-07-04

#

Consumer protection is largely embedded in tiered KYC/transaction-limit rules and provider terms-of-service rather than a dedicated APP-fraud reimbursement regime. Myanmar simultaneously hosts one of the world's largest cyber-scam/pig-butchering industries operating from its Thai-border special economic zones, exploiting crypto (particularly USDT) and mobile-wallet rails to move fraud proceeds, with no formal consumer redress mechanism for victims and provider terms disclaiming liability.

Standing sub-brief · as of 4 July 2026180 words · last cycle 2026-07-04

Consumer Protection & APP Fraud

Myanmar's mobile-payment consumer-protection regime substitutes tiered KYC transaction limits for a dedicated authorised-push-payment fraud reimbursement regime: Level-1 customers are capped at 400,000 kyat per day, roughly US$135, and Level-2 customers at 2,000,000 kyat per day, roughly US$670, with provider terms disclaiming liability and requiring user indemnification rather than guaranteeing reimbursement. Set against that thin consumer-protection layer is the scale of Myanmar's border scam-compound economy: a single Chinese-operated company at KK Park is estimated to have moved over US$100 million in cryptocurrency through Tether-based pig-butchering scam payments, with an estimated 120,000 people trafficked into Myanmar's scam compounds as of late 2023, per the UN Human Rights Office.

no periodic updates on record for this sub-brief

Sources and findings (4)

T3https://www.bnionline.net/en/news/concerns-over-myanmar-junta-mobile-payment-termsretrieved 2026-07-04
T3https://www.kbzpay.com/en/privacy-policyretrieved 2026-07-04
T3https://www.biocatch.com/blog/exposing-asias-shadow-banking-ecosystem-osint-insights-into-myanmars-cyber-scam-economyretrieved 2026-07-04
T3https://en.wikipedia.org/wiki/KK_Parkretrieved 2026-07-04

#

W11 baseline content is Sentinel.gi-fed per methodology; this collector pass did not have access to a proprietary Sentinel.gi feed export for Myanmar. Publicly available regulatory posture is carried as context only: Myanmar's AML/CFT framework rests on the Anti-Money Laundering Law (2014) and the CBM's 2017 AML/CFT regulatory and supervisory framework, and Myanmar has remained on the FATF blacklist since October 2022 -- the most severe multilateral designation, alongside Iran and North Korea.

Standing sub-brief · as of 4 July 2026157 words · last cycle 2026-07-04

AML/CFT & Financial Crime

This module is ordinarily sourced from the Sentinel.gi intelligence feed; no direct Sentinel export was accessible in this collection pass, so the content below is carried as public-source AML/CFT context only, pending genuine Sentinel-fed intelligence in a subsequent cycle. Myanmar remains designated on the FATF blacklist since October 2022, unchanged as of the February 2026 Plenary, the most severe multilateral AML/CFT designation, compounding correspondent-banking de-risking documented in W12. The Central Bank of Myanmar enforces AML/CFT obligations through its 19 December 2017 AML/CFT Regulatory and Supervisory Framework, alongside the 2014 Anti-Money Laundering Law and the Financial Institutions Law.

no periodic updates on record for this sub-brief

Sources and findings (7)

T2https://www.lightspark.com/knowledge/is-crypto-legal-in-myanmarretrieved 2026-07-04
T?FIM (sentinel.gi) per-JID baseline profile — Myanmar — Myanmar remains on FATF's Call for Action (black) list since October 2022; military junta controls AML/CFT institutions post-coup. 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.
T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: sourcing-thinness
T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-001) — Sanctions: EU listing
T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) — Sanctions: OFSI divergence
T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: legal-gap
T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: enforcement-absence

#

Myanmar's correspondent banking access has deteriorated sharply since the 2021 coup and the October 2022 FATF blacklisting, compounded by targeted OFAC sanctions on the two primary state-owned FX-conduit banks (MFTB and MICB, June 2023) and broad de-risking by international correspondent banks. Remaining FX access runs through a shrinking pool of authorised-dealer private banks and the state-owned Myanma Economic Bank, which retains a limited correspondent network.

Standing sub-brief · as of 4 July 2026157 words · last cycle 2026-10-18

Correspondent Banking, Settlement & Access

The bank-versus-non-bank access asymmetry is the analytical spine of Myanmar's correspondent-banking position, and it has deteriorated sharply this cycle. OFAC sanctioned Myanma Investment and Commercial Bank and Myanma Foreign Trade Bank in June 2023 for serving as the primary foreign-exchange conduits for Myanmar's military regime, a designation corroborated by the 2025 US State Department Investment Climate Statement on Burma. Myanma Economic Bank retains authorised-dealer status with an established network of 48 correspondent banks across 10 countries, one of the few remaining formal FX and correspondent channels amid broad international de-risking.

Periodic update · new data 2026-10-18

Correspondent Banking, Settlement & Access

Myanmar's correspondent-banking and settlement-access position registered a single development this cycle: on 9 October 2026 the US Treasury's Office of Foreign Assets Control removed Theint Win Htet from the Burma-related Specially Designated Nationals List, with the Federal Register notice published 15 October 2026. This action is individual-scoped. It does not alter the Burma sanctions program established under Executive Order 14014, and it does not change the structural conditions governing Myanmar's correspondent-banking access generally. For the PSP models licensed or operating in connection with Myanmar, direct settlement access and correspondent-bank sponsorship remain shaped by the same underlying architecture as before this cycle: the EO 14014 sanctions overlay, together with the Central Bank of Myanmar's own foreign-exchange and capital-control regime, continues to constrain the correspondent relationships available to any institution with Myanmar exposure.

No further development on settlement mechanics, sponsor-bank dependence, or de-risking behaviour by international correspondent banks toward Myanmar was located this cycle. The standing picture, in which correspondent access for Myanmar-connected payment flows is constrained by sanctions exposure and by Myanmar's own capital controls rather than by any single commercial relationship, carries forward unchanged. The narrow, individually-scoped nature of the OFAC action means it should not be read as a signal of loosening correspondent-access conditions for the jurisdiction as a whole; the broader population of Myanmar-military-linked persons and entities, and the broader architecture that governs correspondent relationships touching Myanmar, is unaffected.

Outlook

The event most likely to affect Myanmar's correspondent-banking and settlement-access conditions in the near term is the FATF Plenary scheduled for 26 to 30 October 2026, at which FATF will decide whether to escalate Myanmar from its current enhanced-due-diligence status to full countermeasures. A countermeasures designation would represent a materially more consequential development for correspondent access than this cycle's individual-level sanctions easing, since countermeasures typically translate into heightened due-diligence or restrictive measures applied by correspondent banks across the board rather than to a single designated person. That decision point falls just after this research window closes, so no outcome exists yet to assess, and the correspondent-banking baseline for Myanmar remains, for now, constrained along the same lines as before this cycle's single OFAC data point.

1 earlier distinct update(s)

Periodic update · new data 2026-08-26

Correspondent Banking, Settlement & Access

Myanmar's continued placement on the FATF "Call for Action" high-risk jurisdiction list compounds de-risking pressure on Myanmar-linked correspondent-banking relationships, an Assessed-confidence, Tier-3-sourced finding with direct consequences for payments access rather than a restatement of the underlying AML/CFT substance, which is tracked by the financial-integrity monitor. The analytical spine of this module is the asymmetry between bank and non-bank access: correspondent-banking relationships sit with licensed banks, which are directly exposed to the FATF-status-driven de-risking pressure, while Myanmar's non-bank mobile-financial-services sector, operating on domestically-focused, kyat-denominated rails under the 2016 MFS Regulation, is comparatively insulated from correspondent-account-level de-risking even as it remains exposed to the same underlying currency-control and macro-financial constraints tracked under payment-corridor dynamics.

This bank/non-bank asymmetry means that Myanmar's correspondent-banking access pressure and its domestic payments-modernisation push, MyanmarPay/MMQR and the CBDC committee, are occurring on largely separate infrastructural tracks: one narrowing under external sanctions and AML-related pressure, the other expanding under direct Central Bank initiative.

Outlook

Correspondent-banking access pressure tied to Myanmar's FATF status is unlikely to ease absent a formal FATF plenary decision. Watch for any evidence of specific correspondent relationships being terminated or newly established, which would be the most direct indicator of whether this de-risking pressure is translating into concrete access restrictions rather than remaining a background structural condition.

Sources and findings (4)

T1https://home.treasury.gov/news/press-releases/jy1555retrieved 2026-07-04
T1https://www.state.gov/reports/2025-investment-climate-statements/burmaretrieved 2026-07-04
T3https://sanctionslawyers.net/blog-en/the-fatf-grey-list-and-blacklist-complete-guide/retrieved 2026-07-04
T3https://www.usasean.org/article/us-treasury-announces-sanctions-against-two-myanmar-state-owned-banksretrieved 2026-07-04

#

Sanctions, conflict and currency instability have severely constrained conventional M&A/investment activity in Myanmar's payments sector over the trailing 12 months; identified discrete commercial events are concentrated in regulatory-driven product initiatives (CBDC committee) and incumbent super-app marketing/product expansion rather than third-party capital transactions.

Standing sub-brief · as of 4 July 2026139 words · last cycle 2026-07-04

Commercial Intelligence (M&A, Investment & Product)

Two discrete commercial events register for Myanmar this cycle, both product-side rather than third-party M&A. The Central Bank of Myanmar launched a commercial product-development track for a digital-kyat CBDC via its newly formed Central Committee for the Issuance of Central Bank Digital Currency (Notification 16/2025, SAC approval 1 May 2025); amount not publicly disclosed. KBZPay ran a Thingyan 2026 marketing campaign in April 2026 rewarding merchant QR payments of 10,000 kyat or more with redeemable 'Padauk Flowers' cashback and prizes; amount not publicly disclosed. No disclosed third-party M&A or investment deal data was identified for Myanmar's payments or fintech sector in the trailing 12 months.

no periodic updates on record for this sub-brief

Sources and findings (2)

T1https://www.dfdl.com/insights/legal-and-tax-updates/central-bank-establishes-digital/retrieved 2026-07-04
T4https://marketingmyanmar.com/digital-payment-marketing-in-myanmar-kbzpay-wave-money-ayapay-and-beyond/retrieved 2026-07-04

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Editorial metadata for Myanmar
Field	Value
`trust.lawyer_review.status`	never_reviewed
`trust.lawyer_review.reviewer`	no reviewer on record
`trust.content_source`	ai_generated

Provenance and declared absence

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Suppressed by doctrine: derived risk score; per-module RAG traffic light; derived_scores = {"legal_accessibility": {"per_product": {"account_to_account": "regulated", "cards": "regulated", "prepaid_emoney": "licensed-emi", "stablecoin": "emerging-regime"}}}.

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Envelope: baseline resolved at jurisdiction_json.baseline; 14 module(s), 64 finding(s), 118 source(s) in the cumulative register.

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Myanmar

Jurisdiction brief

Latest update · 18 October 2026

Lead Signal

Other Developments

Cross-Monitor Connections

Outlook

Standing brief · as of 4 July 2026

Lead Signal

Other Developments

Cross-Monitor Connections

Outlook

Latest update · 28 September 2026

Regulatory Status

Outlook

Standing brief · as of 4 July 2026

Regulatory Status

Outlook

W1aLicensing, Authorisation & Market AccessConfirmedconfirmed 2026-07-04▾#

Licensing, Authorisation & Market Access

Outlook

Licensing, Authorisation & Market Access

Outlook

Licensing, Authorisation & Market Access

Outlook

Licensing, Authorisation & Market Access

Outlook

W1bConduct, Safeguarding & PromotionsProbableconfirmed 2026-07-04▾#

Conduct, Safeguarding & Promotions

Outlook

Conduct, Safeguarding & Financial Promotions

Outlook

W2Stablecoins & Digital MoneyProbableconfirmed 2026-07-04▾#

Stablecoins & Digital Money

Outlook

W3Operational Resilience & Critical InfrastructureProbableconfirmed 2026-07-04▾#

Operational Resilience & Critical Infrastructure

Outlook

W4Scheme & Network ComplianceProbableconfirmed 2026-07-04▾#

Scheme & Network Compliance

Outlook

W5Payment Corridor Dynamicslimited signalProbableconfirmed 2026-07-04▾#

Payment Corridor Dynamics

Outlook

Payment Corridor Dynamics

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Payment Corridor Dynamics

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W6Industry Structure & CommercialProbableconfirmed 2026-07-04▾#

Industry Structure & Commercial Dynamics

Outlook

W7Legal & LitigationProbableconfirmed 2026-07-04▾#

Legal & Litigation

Outlook

W8Merchant Acquiring & RiskProbableconfirmed 2026-07-04▾#

Merchant Acquiring & Risk

Outlook

W9Product Innovation & Market DevelopmentProbableconfirmed 2026-07-04▾#

Product Innovation & Market Development

Outlook

Product Innovation & Market Development

Outlook

W10Consumer Protection & APP FraudProbableconfirmed 2026-07-04▾#

Consumer Protection & APP Fraud

Outlook

W11AML/CFT & Financial CrimeSourced from Sentinel.gi ↗Probableconfirmed 2026-07-04▾#

AML/CFT & Financial Crime

Outlook

W12Correspondent Banking, Settlement & Accesslimited signalProbableconfirmed 2026-07-04▾#

Correspondent Banking, Settlement & Access

Outlook

Correspondent Banking, Settlement & Access

Outlook

Correspondent Banking, Settlement & Access

Outlook

W13Commercial Intelligence (M&A, Investment & Product)Uncertainconfirmed 2026-07-04▾#

Commercial Intelligence (M&A, Investment & Product)

Outlook

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