MMschema world-payments-v1trajectory: not recorded
Last updated · 14 modules · 64 sourced
findings · 114 sources in the cumulative register
14Modulesbaseline.modules[]
64Findingsmodules[].findings[]
23Tier-1 sourcesrun_metadata.t1_source_count
Confidence mix(sums to 14 rendered modules; click to filter)
Jurisdiction brief
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
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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Myanmar's payments licensing regime rests on the Financial Institutions Law (2016) for banks/NBFIs and the CBM's 2016 Mobile Financial Services Regulation for non-bank e-money/mobile-wallet issuers, both administered by the Central Bank of Myanmar (CBM). Bank-led and non-bank MFS routes coexist, with a MMK 3 billion minimum capital bar for non-bank MFS licensees. The junta-controlled CBM continues routine licensing, capital-adequacy and FX-dealer authorisation activity, alongside periodic mass revocation of non-compliant FX/money-changer licences.
Standing sub-brief226 words · last cycle wpm-2026-08-25
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.
Outlook
The dual bank/non-bank licensing architecture is the structural baseline against which all other Myanmar payments activity operates, and it is unlikely to change materially in the near term given the CBM's evident capacity to keep both routes running through years of conflict. The more active variable is enforcement: the recurring pattern of authorised-dealer and money-changer licence revocations signals continued CBM appetite for tightening the foreign-exchange periphery, and further rounds of revocation are a reasonable expectation for the next cycle.
Periodic update · new data 2026-08-26 · run wpm-2026-08-25
Licensing, Authorisation & Market Access
Myanmar's payments-licensing architecture absorbed a material compliance-obligation uplift this cycle without any change to the underlying licensing gateway itself. 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 imposes heavier customer due-diligence obligations directly onto the population of CBM-licensed banks and non-bank financial institutions operating under the Financial Institutions Law framework. This is not a change to who may obtain a payments licence or under what capital or fit-and-proper conditions; it is a change to what a licensed entity, once authorised, must do on an ongoing basis to remain in good standing. The obligation applies without differentiation across the licensing population: both bank and non-bank licence-holders face the same new CDD burden.
The reform sources to a Tier-2 legal alert corroborated by independent policy analysis, and carries High confidence, though a primary Union Government gazette text of the enacted law itself has not been located. This sourcing profile is itself informative: Myanmar's licensing-architecture developments continue to be evidenced primarily through secondary legal and policy-analyst reporting rather than through direct access to the regulator's own primary publications.
Because the licensing gateway itself is unchanged, the market-access question for prospective bank or non-bank payments entrants in Myanmar is unaffected by this cycle's development in isolation. What has changed is the ongoing-compliance cost of holding a licence once obtained: the AML Law 2026's obligations attach to the existing FIL-licensed population rather than creating a new licence category or altering the conditions attached to obtaining one. This cycle's W1a development should be read alongside the parallel W1b conduct-and-CDD overlay and the W12 correspondent-banking constraint also active this cycle: all three are downstream of, or parallel to, the same underlying AML Law 2026 enactment and the same sustained FATF/OFAC pressure environment, even though each carries a distinct analytical lens — licensing-architecture obligation, conduct-level CDD overlay, and cross-border access constraint, respectively.
Outlook
The AML Law 2026's implementing directives, expected in the fourth quarter of 2026 but not yet published, will determine the detailed operational content of the new licensing-adjacent compliance obligations — specifically the audit, reporting, and compliance-officer qualification requirements that CBM-licensed banks and non-bank financial institutions will need to build out. Until those directives are published, the practical scope of what the licensing population must do to satisfy the new law remains only partially defined, with the Myanmar Financial Intelligence Unit's ongoing training and outreach activity the only visible sign of implementation progress in the interim.
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-brief164 words · last cycle wpm-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.
Outlook
The coexistence of a technically sound safeguarding mechanism with a politicised account-freeze power is the defining feature of Myanmar's conduct regime, and it is likely to persist as long as the post-coup security environment does. Expect further KYC-driven account closures to be framed as fraud or security enforcement rather than as conventional consumer-protection action, a distinction that matters for any assessment of provider or customer risk in this market.
Periodic update · new data 2026-08-26 · run wpm-2026-08-25
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.
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-brief220 words · last cycle wpm-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.
Outlook
Myanmar's digital-money landscape is set to remain a genuine bifurcation rather than a converging market: a junta-controlled CBDC development track running in parallel with an opposition-operated stablecoin system the CBM cannot reach, both operating against a backdrop of a blanket ban on privately issued crypto and stablecoins. Watch for further CBM enforcement notices against crypto conversion and for any indication of pilot timelines emerging from the Notification 16/2025 committee's work.
No periodic updates recorded against this sub-brief.
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.
Standing sub-brief147 words · last cycle wpm-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.
Outlook
Formal business-continuity planning for core settlement rails is not the binding constraint on Myanmar's payments resilience; conflict-driven connectivity disruption is, and it is likely to remain the dominant operational risk for as long as the underlying conflict continues. Expect further shutdown episodes to periodically interrupt mobile-money and banking availability regardless of the BCP framework nominally in place.
No periodic updates recorded against this sub-brief.
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-brief129 words · last cycle wpm-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.
Outlook
The domestic scheme's coexistence with international networks, rather than exclusion of them, is likely to remain the stable pattern for Myanmar's card market. Watch for incremental adjustments to MPU's interchange and withdrawal-limit settings as the domestic banking system continues to manage liquidity and cash-access constraints.
No periodic updates recorded against this sub-brief.
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.
Open gap — wpm-int-4Sub-national/regional divergence within Myanmar (e.g. resistance-controlled areas operating parallel financial systems such as DMMK) and the informal hundi remittance sector are under-covered relative to formal CBM-authorised channels.Emerging-market rail and informal-sector (hundi) dynamics are under-covered relative to formal, CBM-authorised bank/MFS channels, consistent with the WPM bias-correction guidance on emerging-market rails.
Standing sub-brief153 words · last cycle wpm-2026-07-04
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.
Outlook
The forced-formalisation directive is reshaping the corridor's formal-informal balance in the junta's favour, directing foreign-exchange flow into official, junta-linked banking channels, though informal hundi-style transfer likely persists alongside the formal channel. Expect MMQR interoperability to keep consolidating domestic wallet-to-bank switching even as the corridor's cross-border dynamics remain shaped primarily by the remittance directive.
No periodic updates recorded against this sub-brief.
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-brief131 words · last cycle wpm-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.
Outlook
The structural financial-inclusion gap continues to underpin mobile-wallet and MFS growth as the primary access channel for most of the population, a dynamic likely to persist regardless of near-term political developments. Expect continued divergence between Western-investor caution, exemplified by Telenor's exit, and sustained Chinese fintech capital interest in Myanmar's digital-payments space.
No periodic updates recorded against this sub-brief.
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-brief148 words · last cycle wpm-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.
Outlook
Blacklist status is unlikely to shift in the near term given the absence of any credible governance change, and it will continue to compound correspondent-banking de-risking pressure documented elsewhere in this baseline. Expect further individual-level criminal enforcement against crypto conversion activity, serving as a recurring signal of the CBM's determination to enforce its prohibition regime even at small transaction scale.
No periodic updates recorded against this sub-brief.
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.
Open gap — wpm-int-3Chargeback and merchant dispute-resolution framework detail for Myanmar acquiring is thinly documented in public sources; MDR/KYM/settlement mechanics are covered but formal dispute/chargeback rules are not.no under-indexing note recorded
Standing sub-brief139 words · last cycle wpm-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.
Outlook
The authorised-acquirer population and merchant onboarding mechanics are reasonably well documented, but the formal chargeback and merchant-dispute-resolution framework remains thinly evidenced in public sources, a gap worth monitoring as acquiring volumes grow. Expect incremental acquirer-level product refinement rather than structural change to the Notification 7/2020 authorisation regime in the near term.
No periodic updates recorded against this sub-brief.
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-brief151 words · last cycle wpm-2026-07-04
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.
Outlook
Product innovation in Myanmar's payments market remains regulator-led rather than driven by third-party fintech entrants, with the CBDC committee's phased-rollout work the most consequential pipeline item to watch. Expect continued MMQR-linked interoperability development to dominate near-term product activity, while historical blockchain-remittance pilots such as Everex's remain more illustrative of past ambition than of current market structure.
No periodic updates recorded against this sub-brief.
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-brief180 words · last cycle wpm-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.
Outlook
The absence of a dedicated APP-fraud reimbursement obligation leaves Myanmar's mobile-money users structurally under-protected relative to peer markets with formal reimbursement regimes, a gap likely to persist absent new CBM rulemaking. The scam-compound economy's exploitation of crypto and wallet rails is a scale and trajectory issue that will keep drawing international scrutiny, though the illicit-finance dimension of that activity is analysed by FIM rather than carried further here.
No periodic updates recorded against this sub-brief.
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.
Open gap — wpm-int-1No direct Sentinel.gi payments-context feed export was accessible in this collection pass for W11; AML/CFT content carried is public-source context only, not genuine Sentinel-fed intelligence.no under-indexing note recorded
Standing sub-brief157 words · last cycle wpm-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.
Outlook
Genuine Sentinel-fed AML/CFT intelligence for Myanmar should be prioritised for ingestion in the next cycle, given the jurisdiction's blacklist status and its evident relevance to the correspondent-banking and scam-compound dynamics tracked elsewhere in this baseline. Until that feed is restored, this module's coverage should be read as contextual rather than as a substantive AML/CFT assessment.
No periodic updates recorded against this sub-brief.
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.
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.
Movement — CHANGEDtightening trajectoryFATF blacklist persistence compounding correspondent de-risking.
Standing sub-brief157 words · last cycle wpm-2026-08-25
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.
Outlook
The pool of functioning correspondent-banking access points for Myanmar counterparties is narrowing rather than stabilising, and FATF blacklist status compounds the effect of targeted OFAC sanctions on the regime's primary FX-conduit banks. Expect continued reliance on the small number of residual channels such as Myanma Economic Bank's network, with further de-risking by international correspondents a realistic possibility for the next cycle.
Periodic update · new data 2026-08-26 · run wpm-2026-08-25
Correspondent Banking, Settlement & Access
Myanmar's correspondent-banking access constraint sharpened rather than eased this cycle. Myanmar's Call-for-Action FATF blacklist status was confirmed unchanged, alongside Iran and North Korea, at the 19 June 2026 Plenary, sustaining a global posture of enhanced due diligence and countermeasures toward Myanmar-domiciled counterparties. That standards-based pressure now sits stacked atop continuing OFAC Burma-Related Sanctions designations, together deepening de-risking pressure on Myanmar-domiciled banks and payment institutions seeking or maintaining correspondent relationships abroad.
The bank-versus-non-bank access asymmetry that is this module's analytical spine is sharply visible in Myanmar's case: correspondent-banking relationships are, by structure, a bank-to-bank access channel, meaning Myanmar's non-bank payment institutions and e-money issuers have no direct correspondent-banking relationship of their own to lose — their cross-border access depends entirely on the correspondent relationships that Myanmar-domiciled banks are able to maintain. As those bank-level correspondent relationships come under increasing de-risking pressure from the stacked FATF-and-OFAC posture, the non-bank payment sector's indirect cross-border access is exposed to the same pressure at one remove, without any direct correspondent relationship of its own through which to manage or diversify that exposure.
This cycle's correspondent-access finding carries High confidence, resting on Tier-1 primary sourcing directly from both the FATF's own black-and-grey-list publication and OFAC's own Burma-Related Sanctions program page — a stronger primary-source foundation than either the W1a licensing or W1b conduct-overlay findings this cycle, both of which rest on secondary legal-alert reporting. This is itself analytically notable: the correspondent-access and sanctions-standards dimension of Myanmar's payments environment is better evidenced at the primary-source level than the domestic legislative-reform dimension.
The compounding effect this cycle is explicit in this cycle's key judgment: Myanmar's payments and AML compliance architecture is being materially hardened on paper even as correspondent-banking access continues to tighten under sustained FATF blacklist status and stacked OFAC designations, producing a widening gap between domestic-law compliance uplift and actual cross-border payments access. Domestic compliance uplift, in other words, has not been evidenced to translate into any easing of the external correspondent-access constraint. For any Myanmar-domiciled bank, the practical implication is that correspondent-relationship maintenance now requires managing exposure to two compounding pressure sources simultaneously — FATF-standards-based enhanced due diligence from counterparty banks globally, and direct OFAC sanctions-designation risk tied to specific Myanmar-based entities — rather than either pressure source in isolation.
Outlook
The FATF's next Plenary review is the key horizon marker for Myanmar's correspondent-banking access picture: continuation of the Call-for-Action blacklist status would sustain the current de-risking pressure on Myanmar-domiciled banks, while any change to that status could meaningfully alter correspondent-banking access for the entire payments sector, including the non-bank institutions that depend on bank-level correspondent relationships at one remove. Absent such a change, the gap between domestic compliance uplift and correspondent-access constraint identified this cycle is likely to persist, and non-bank payment institutions should be expected to remain structurally exposed to bank-level de-risking pressure they cannot directly manage.
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.
Open gap — wpm-int-2No disclosed M&A or investment deal data (funding rounds, acquisitions) was identified for Myanmar's payments/fintech sector in the trailing 12 months; W13 commercial intelligence is limited to regulatory product initiatives and incumbent marketing campaigns.no under-indexing note recorded
Standing sub-brief139 words · last cycle wpm-2026-07-04
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.
Outlook
Expect commercial activity to remain concentrated in regulator-led product initiatives and incumbent super-app marketing rather than third-party investment, consistent with the constrained M&A environment documented this cycle.
No periodic updates recorded against this sub-brief.
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