Dismantling due process in financial enforcement
A central feature of civilian resistance to the military coup has been the rejection of the regimecontrolled formal banking system in favour of mobile wallets, informal hundi payments, and
cryptocurrency to support civil disobedience, humanitarian relief, and mutual aid. This Bill is
designed to disrupt those alternative financial routes by enabling rapid freezes, compelling bank-led
enforcement, and denying meaningful avenues of challenge or remedy.
Emergency account freezes and asset deprivation
The Bill authorises the immediate freezing of accounts within 15 minutes of an “emergency” report
and permits banks to hold funds for up to 72 hours without prior judicial authorisation. In practice,
this creates a mechanism for the rapid disruption of crowdfunding for emergency relief, strike
support, and other forms of civilian assistance, particularly where speed is essential.
This is not a narrowly supervised emergency power. By permitting deprivation of access to funds on
an accelerated timetable and without prior judicial review, these provisions create clear scope for
arbitrary interference with property-related interests and due process rights.
Account suspensions based on “unusual” transactions
The Bill further requires banks to freeze accounts unilaterally when they detect “unusual” financial
flows, allowing customers to be deprived of access to their assets before any charge is filed or
wrongdoing established. In the current context, routine transfers to mutual aid networks, displaced
families, or resistance-linked support structures are readily liable to be treated as suspicious.
By using vague indicators such as “unusual” activity without clear legal thresholds or independent
oversight, Article 26 turns ordinary financial behaviour into a basis for pre-emptive punishment. It
thereby undermines the presumption of innocence and normalises punitive financial restrictions in
the absence of adjudication.
Coercive duties imposed on financial institutions
The Bill also weaponises the banking sector by coercing financial professionals into acting as
instruments of State surveillance and repression. Under Article 38, bank officials face up to seven
years’ imprisonment for failing to investigate or report “suspicious” financial activities. This places
financial workers under threat of criminal punishment unless they actively identify and report
transactions deemed suspect by the regime, including efforts to move funds outside militarycontrolled channels.
Article 60 compounds this framework by granting effective impunity to those carrying out arbitrary
account freezes, expressly barring civil or criminal litigation against financial officials for actions taken
under the law. Victims are thus stripped of any meaningful domestic avenue to challenge wrongful
asset seizures, while financial institutions are insulated from accountability for participating in abusive
enforcement.
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