ISSUE: 2026 No. 47 ISSN 2335-6677 INTRODUCTION In October 2022, Myanmar was labelled a “Jurisdiction of Concern” by the Financial Action Task Force (FATF), an independent inter-governmental body which sets global standards for anti-money laundering and countering the financing of terrorism (AML/CFT). FATF called on members and other jurisdictions to “apply enhanced due diligence measures proportionate to the risks” arising from Myanmar. 1 Since then, Myanmar’s military regime has taken a number of steps to improve its compliance with FATF recommendations. Despite this, illicit economic activity continues to flourish in Myanmar. The country is still perceived as a high-risk jurisdiction for money laundering: the Basel AML Index ranks Myanmar as the highest-risk jurisdiction in the world. 2 This briefing paper reviews the post-coup AML/CFT situation in Myanmar, including steps taken by the State Administration Council/State Security and Peace Commission (SAC/SSPC) military regime. It finds that Myanmar’s post-coup approach to AML/CFT compliance has been at least in part self-serving, an excuse to push individuals and businesses to use a statecontrolled financial system, and to target various non-profits. It argues that the FATF process has largely ignored changes in the political environment and the military’s obvious conflicts of interest; it is supposed to regulate informal financial flows that are incentivised by its own selfserving economic policies. It concludes by arguing that actual improvements in AML/CFT in Myanmar will require a fundamental rethink about how FATF recommendations are applied in the context. FATF AND AML/CFT STANDARDS FATF sets global standards for AML/CFT. It has 40 members and nine regional associate organisations. FATF aims to promote a “coordinated response by national authorities to combat money laundering and terrorism financing.” 3 It also seeks to promote effective implementation of legal, regulatory and operational measures to achieve these goals. 4 In practice, FATF recommendations have significant sway over national-level legislation. 5 Over 200 countries have committed to implementing FATF standards. Countries regularly undergo a ‘mutual evaluation’, implemented by either the FATF or FATFaffiliated regional bodies. Evaluations assess countries’ technical compliance with the 40 FATF Recommendations, and a country’s effectiveness across 11 immediate outcomes. Between these evaluations, countries work to address issues detailed in follow-up reports that assess improvements in technical compliance. However, follow-up reports do not assess improvements in effectiveness. 6 While FATF standards address important problems, they have sometimes been co-opted or used by authoritarian states and actors to “control threats and meet ulterior objectives.” 7 FATF standards on states collecting financial information on persons of interest – regardless of whether they are subject to a formal investigation – have “enabled ill-intentioned regimes to target their opponents through politically motivated criminal charges or the initiation of asset freezes during an investigation.” 8 Recommendations criminalising money laundering and terrorist financing have been abused – often in conjunction with provisions allowing pre-trial detention – to detain target individuals. 9 FATF recommendations allowing provisional asset freezes have been misused. The FATF recommendation on the targeting of non-profit organisations for potential terrorist financing abuse has also been regularly abused, or has contributed to significant unintended consequences for non-profits. 10 Collectively, the co3