ISSUE: 2026 No. 47 ISSN 2335-6677 Yet the newfound zeal to crack down on hundis contrasts with the approaches of past military regimes. In Myanmar’s last FATF Mutual Evaluation under the State Peace and Development Commission government in 2008, the authorities “openly acknowledged that hundi operated unregulated in Myanmar and it was used for legitimate purposes, despite technically being illegal” (APGML, 2008). 27 The regime did not regularly prosecute or convict hundi operators for operating without a license, though it sometimes prosecuted hundis for other acts, such as transferring money to a criminal group. 28 This raises questions about the current regime’s motivations for aggressively targeting hundis, given limited enforcement in other areas and the lack of evidence of increased hundi involvement in illicit (e.g. drug, scams, etc.) financial flows. While the regime announced new registration and reporting requirements for real estate agents, enforcement actions have been limited, despite the widespread use of real estate for money laundering in Myanmar. 29 Similarly, illicit industries seem to rely primarily on other means of value transfer. Scam centres use numerous tactics to move money, including having scammed individuals send wire transfers to fabricated virtual asset service providers or purchase prepaid cards to purchase virtual currency. 30 The US government has identified one financial institution - Cambodiabased Huione – as a “primary money laundering concern” because of its connections to organised crime and the facilitation of proceeds of crime through virtual assets. 31 However, this should not be misconstrued to suggest that the hundi system is not without risks. There is acknowledgement and evidence that the system “is used in criminal activity.” 32 Historically, the lack of action had likely been due to the “value and importance of the system to communities throughout Myanmar,” combined with limited resources and other higher priorities, such as the formal banking system. 33 There is some evidence that Myanmar’s hundis are a method of value transfer for scam centres. However, the extent of the links to scam centres and other illicit sectors, such as drug production, drug trafficking, arms trafficking, human trafficking, illicit resource extraction, and environmental crimes, is not clearly elaborated in the 2018 Mutual Evaluation report on Myanmar. 34 TARGETING NON-PROFITS AND POLITICAL OPPONENTS Myanmar’s military authorities have used AML/CFT regulations to legitimise crackdowns on political opponents and non-profit organisations. They have increased surveillance and reporting requirements, including financial reporting, for many NGOs. The ILO publicly noted that the CBM froze their Myanmar bank accounts in February 2021. 35 The regime also conducted an extensive data-collection survey among non-profits in 2025, raising fears of military surveillance. In 2022, the regime also adopted a new Registration of Associations Law, which has been used in conjunction with AML/CFT regulations in ways that negatively affect non-profits. Similarly, the SAC/SSPC regime used CFT-related regulations to target individuals and groups, including labelling political and conflict opponents as ‘terrorists.’ In 2021, the regime labelled the National Unity Government (NUG) a terrorist group in 2021, and did the same to the Committee Representing Pyidaungsu Hluttaw. 36 It also declared a number of armed groups as terrorists, including the Arakan Army, Ta’ang National Liberation Army and Myanmar National Democratic Alliance Army in September 2024, 37 and the Karen National Union in August 2025. 38 6