Together, these provisions transform banks from service providers into coercive arms of State control. They also raise serious concerns of corporate complicity, particularly for financial actors participating in arbitrary and unreviewable restrictions on access to funds. International legal assessment These provisions are incompatible with core due process guarantees under international human rights law. Article 14 of the ICCPR protects the right to a fair hearing by a competent, independent, and impartial tribunal and reflects the broader principle that punitive measures should not be imposed absent lawful process and the presumption of innocence. Article 2(3) further requires an effective remedy for rights violations. The Bill moves in the opposite direction. It permits rapid account freezes without prior judicial authorisation, encourages deprivation of assets based on vague indicators of suspicion, coerces bank officials into enforcing State repression, and bars victims from seeking civil or criminal redress. In substance, it replaces adjudication with administrative coercion and converts financial regulation into a mechanism for punishing and disabling civilian resistance. In the context of Myanmar, these are not ordinary anti-fraud powers, but tools for dismantling the financial channels on which humanitarian support, mutual aid, and political opposition depend. Imposing the death penalty for economic offences The Bill introduces extreme and grossly disproportionate punishments that are wholly detached from ordinary international criminal justice standards. In the context of Myanmar, these provisions function not as legitimate anti-crime measures, but as a tool of terror against those involved in parallel economic activity, alternative financial networks, and other forms of resistance to military rule. Capital punishment for economic and online offences Articles 53 and 54 permit the death penalty for a broad range of offences linked to so-called online fraud, including operating online fraud centres (Article 44), digital currency fraud (Article 45), recruitment for online fraud (Article 46), violence or detention connected to online fraud (Article 47), labour exploitation (Article 48(a)), and human trafficking (Article 48(b)). Although some of these offences may involve serious criminal conduct, the Bill places different forms of behaviour into a single punitive framework and exposes defendants to capital punishment far beyond the narrow limits recognised under international law. In particular, extending death eligibility to offences such as digital currency fraud or recruitment-related conduct radically departs from the principle that punishment must be proportionate to the gravity and nature of the crime. In Myanmar’s current context, where the regime routinely characterises oppositional or informal economic activity as criminal, these provisions create a legal pathway for imposing the harshest possible punishment on individuals associated with unauthorised financial systems or parallel civilian structures.

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