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ISSUE: 2026 No. 47 ISSN 2335-6677 2 Basel AML Index, “Global Rankings in 2025,” https://index.baselgovernance.org/ranking; Note that some jurisdictions, such as Iran, were not ranked. 3 FATF-GAFI, “What we do,” https://www.fatf-gafi.org/en/the-fatf/what-we-do.html 4 FATF “The FATF Recommendations,” October 2025, https://www.fatfgafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html 5 Georgios Pavlidis, “The dark side of anti-money laundering: Mitigating the unintended consequences of FATF standards,” Journal of Economic Criminology, Vol. 2, December 2023, https://www.sciencedirect.com/science/article/pii/S2949791423000404 6 Asia/Pacific Group on Money Laundering, “7th Follow-up Report: Mutual Evaluation of Myanmar,” October 2024 https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Myanmar-FUR-October2024.pdf.coredownload.inline.pdf 7 Stephen Reimer, “Suppression Laundering: Using FATF as a Fig Leaf to Target Civil Society,” Royal United Service Institute (RUSI), June 13, 2024, https://www.rusi.org/explore-ourresearch/publications/policy-briefs/suppression-laundering-using-fatf-fig-leaf-target-civilsociety#footnotes 8 Stephen Reimer, “Suppression Laundering: Using FATF as a Fig Leaf to Target Civil Society,” RUSI, June 13, 2024, https://www.rusi.org/explore-our-research/publications/policybriefs/suppression-laundering-using-fatf-fig-leaf-target-civil-society#footnotes 9 Stephen Reimer, “Suppression Laundering: Using FATF as a Fig Leaf to Target Civil Society,” RUSI, June 13, 2024, https://www.rusi.org/explore-our-research/publications/policybriefs/suppression-laundering-using-fatf-fig-leaf-target-civil-society#footnotes 10 Georgios Pavlidis, “The dark side of anti-money laundering: Mitigating the unintended consequences of FATF standards,” Journal of Economic Criminology, Vol. 2, December 2023, https://www.sciencedirect.com/science/article/pii/S2949791423000404 11 FATF-GAFI, “High-Risk Jurisdictions Subject to a Call for Action – 21 October 2022,” https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-actionoctober-2022.html 12 Central Bank of Myanmar, “Measures Taken by the Working Group on Anti-Money Laundering and Combatting the Financing of Terrorism,” January 13, 2023, https://www.cbm.gov.mm/sites/default/files/inline-files/Myanmar%20AML-CFT%20WC%20Writeup%28Website%29%2813-1-23%29-7.pdf 13 Asia/Pacific Group on Money Laundering, “6th Follow-up Report: Mutual Evaluation of Myanmar,” February 2024 https://apgml.org/about-us/members/members/myanmar 14 Asia/Pacific Group on Money Laundering, “6th Follow-up Report: Mutual Evaluation of Myanmar,” February 2024 https://apgml.org/about-us/members/members/myanmar 15 Central Bank of Myanmar, “Measures Taken by the Working Group on Anti-Money Laundering and Combatting the Financing of Terrorism,” January 13, 2023, https://www.cbm.gov.mm/sites/default/files/inline-files/Myanmar%20AML-CFT%20WC%20Writeup%28Website%29%2813-1-23%29-7.pdf 16 FATF, “High-Risk Jurisdictions subject to a Call for Action – 24 October 2025,” Oct. 24, 2025, https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-actionoctober-2025.html 17 World Bank, “Economic Aftershocks: Myanmar Economic Monitor June 2025,” https://documents1.worldbank.org/curated/en/099061125205014652/pdf/P507203-cbcf81b5-01074517-8ad7-82b588a6328f.pdf 18 Jared Bissinger et al, “Coping Strategies and Preemptive Adaptations of Trading Firms in PostCoup Myanmar,” 2026, forthcoming. 19 Rates as of February 9, 2026. Migrant worker remittance rate is available on websites of many banks, including www.kbzbank.com 20 Allen & Gledhill, “Myanmar workers overseas required to remit foreign earnings,” October 29, 2024, https://www.allenandgledhill.com/mm/publication/articles/29235/workers-overseas-requiredto-remit-foreign-earnings-home 21 Global New Light of Myanmar, “CBM intensifies crackdown on illegal Hundi businesses,” January 14, 2024, https://www.gnlm.com.mm/cbm-intensifies-crackdown-on-illegal-hundi-businesses/ 9

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Rules or Ruse? Myanmar’s Anti-Money Laundering Efforts Coerce Compliance with a Rigged Financial System

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Digital Surveillance
Military Coup

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ISEAS Yusof Ishak Institute

Date Published: Jun 29, 2026

Abstract: Since being labelled a “Jurisdiction of Concern” by the Financial Action Task Force (FATF) in 2022, Myanmar’s military government has undertaken efforts to improve its technical compliance with the FATF’s recommendations on anti-money laundering and countering the financing of terrorism (AML/CFT). The focus on technical compliance has not adequately addressed the interaction of AML/CFT recommendations with economic policy changes – namely, the regime’s multiple exchange rate system, which is a key driver of informal financial flows. This points to a fundamental challenge – Myanmar’s regime is supposed to regulate informal financial flows that are incentivised by its own self-serving economic policies. The target of the regime’s crackdowns on informal financial flows includes money agents, known as hundis. Though connections between hundis and illicit activities such as drug production and scam centres exist, hundis’ primary business is facilitating informal trade and migrant worker remittances. Previous military regimes have acknowledged the largely legitimate nature of the hundi system. Myanmar’s military regime uses AML/CFT compliance less to address actual money laundering, and more as a tool to compel individuals and businesses to use the state-controlled financial system. This increases the regime’s access to and control over foreign currency and is a novel method of using global rules on financial crime as a cover for authoritarian economic controls to capture foreign exchange. The regime also uses AML/CFT compliance to target politically connected persons, conflict opponents and non-profit organisations. This tactic, when combined with the lack of an independent judiciary, raises questions about the effectiveness and potential abuse of AML/CFT compliance. FATF should acknowledge that a traditional AML approach is not an appropriate or useful response to financial transactions facilitated by hundis for humanitarian or legitimate economic reasons in present-day Myanmar, and should adjust the application of recommendations accordingly.

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Rules or Ruse? Myanmar’s Anti-Money Laundering Efforts Coerce Compliance with a Rigged Financial System

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