ISSUE: 2026 No. 47 ISSN 2335-6677 option of FATF standards by ill-intentioned states has provided a powerful tool and a veneer of legitimacy for these actions. MYANMAR AND THE FATF: NEW REALITIES, OLD ACTION PLANS Myanmar has a complicated history with AMF/CFT compliance, including multiple stints on the FATF blacklist. The most recent started in October 2022. The FATF called on Myanmar to address numerous strategic deficiencies by improving understanding of money laundering risks, improving oversight of hundis, and improving investigation and prosecution of money laundering, amongst others. 11 Myanmar’s last evaluation from the FATF-linked regional body, the Asia/Pacific Group on Money Laundering (APGML), was in 2018, and it outlined a range of steps that Myanmar should take to improve its AML/CFT effectiveness. While the evaluation is relatively strong in its analysis of technical compliance, it often lacks sufficient contextual knowledge and analysis. This is particularly noticeable in the evaluation’s failure to note the role of the military – and military-affiliated border guard forces and other armed allies – in illicit revenuegenerating activities. Since that evaluation, Myanmar has seen extraordinary change – most notably a military coup that placed state institutions, including those overseeing Myanmar’s FATF action plan, under military control. The military has continued working on aspects of the FATF action plan. It established a Working Group on AML/CFT in October 2022. 12 It expanded licensing and registration and increased enforcement for informal money transfer agents. 13 It published an AML/CFT supervision guide and inspection manual. 14 It also published a list of AML/CFT actions the regime has conducted or intends to conduct. 15 The FATF released a statement after its October 2025 plenary, highlighting four strategic deficiencies Myanmar should address – down from eight a few years prior. 16 However, during this time, the military regime has also changed many economic and financial sector policies, often in ways that shape the financial incentives of individuals and businesses, as well as their choice of financial service providers. These changes are not noted in the FollowUp Reports to Myanmar’s FATF evaluation, nor has the country’s action plan been updated to reflect contextual changes. The result is a new regime tasked with addressing old priorities. In some cases, this is inconsequential. In others, it raises the risk of unintended harm or for AML/CFT recommendations to be used to legitimise regime controls and actions. MYANMAR’S HUNDI CRACKDOWN: A QUESTIONABLE CRUSADE Since 2022, Myanmar authorities have significantly increased enforcement against informal money transfer agents, also called hundis. These efforts were called for in Myanmar’s FATF action plan. The tightly controlled state media regularly describes these efforts as efforts to combat money laundering. However, a closer look at the hundi system and the regime’s broader economic and financial policies suggests that there is more to the regime’s crackdown than AML goals alone. The regime is using AML/CFT compliance less to address actual money laundering, and more as an excuse to force individuals and businesses to use the statecontrolled financial system. This increases the regime’s access to and control over foreign currency, which is a key part of its strategy to retain political power. 4