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.