the junta. As has previously been exposed by Justice For Myanmar, Shwe Byain
Phyu Group has business links to the military conglomerate Myanma Economic
Holdings Limited (MEHL) including for the import to Myanmar of petroleum and the
company and its founders are sanctioned by the USA and Canada.40
In a reply to Justice For Myanmar, Investcom claimed that ATOM does not “design,
direct &/or conduct mass, unlawful surveillance” and that it applies internal humanrights due-diligence procedures aligned with the UN Guiding Principles”. The
company noted that it was “aware of claims relating to third-party technologies in
Myanmar” but, referring to company policy, refused to “confirm or deny the
existence of third-party systems”.
Ooredoo Myanmar Limited
Ooredoo Myanmar Limited (OML) is one of the four nationwide mobile network
operators in Myanmar. It has implemented Geedge systems in Yangon and
Mandalay. It was established as a fully owned subsidiary of Ooredoo Q.P.S.C.,
domiciled in Qatar and majority owned by the state of Qatar.41 Founded in 2014,
OML along with Telenor entered Myanmar when there were no laws in place to
regulate the use of interception technologies. Before and immediately after entering
Myanmar, concerns were raised publicly regarding the human rights risks of
operating a telecommunications company in Myanmar, including with Ooredoo
Group's CEO directly.42
On September 8, 2022, Ooredoo announced the entry into a sales agreement for
OML through its parent company, Ooredoo Asian Investments Pte. Ltd. (OAI),
domiciled in Singapore, to Nine Communications Pte. Ltd., a Singapore-domiciled
special project vehicle.43 Ooredoo's exit was completed on May 31, 2024.44
According to Singaporean registry data accessed in August 2025, Nine
Communications biggest shareholder is Nyan Win through the Singaporeregistered company, Sunny Aqua Mountain Pte. Ltd., followed by Aion Ventures
Limited and then the Myanmar companies National Telecommunication
Development Co. Ltd., Pyi Taw Tha Pyi Telecom Co. Ltd. and Mahar Kyunt Mong
Co. Ltd. Aion Ventures Limited is domiciled in the British Virgin Islands, a
jurisdiction that is required to comply with UK sanctions on Myanmar.
Frontiir Company Limited (Myanmar Net)
Frontiir is one of Myanmar's largest ISPs and it has implemented Geedge
technology in Yangon. Founded in 2013 by two US citizens and a Canadian, it is
led by Myanmar-born US citizen Godfrey Tan (Wai Lin Tun).45 Frontiir provides
20