II. International Legal Framework and Analysis 62 Since the Special Rapporteur’s report, Amnesty International, Global Witness, Justice for Myanmar, and Burma Campaign U.K. have gone on to identify companies based in the U.K., Greece, Japan, India, China, Luxembourg, Singapore, and elsewhere involved in the junta’s aviation fuel supply chain.167 In response to the report’s findings, Singapore’s Ministry of Foreign Affairs (MFA) reiterated the nation’s firm stance against the Myanmar military’s use of force against civilians. The MFA emphasized that Singapore prohibits the transfer of arms to Myanmar and does not authorize the transfer of dual-use items with potential military applications, especially when there’s a serious risk they may be used to inflict violence on unarmed civilians. The Monetary Authority of Singapore (MAS) has been actively engaging financial institutions to prevent transactions that could facilitate such activities.168 Thailand has also come under scrutiny in the wake of the report. In July 2024, U.N. Special Rapporteur Tom Andrews testified before Thailand’s Parliamentary Committee on National Security, urging the Thai government to take stronger measures against businesses facilitating arms and aviation fuel sales to Myanmar. In response, Thailand’s Anti-Money Laundering Office (AMLO) and the Bank of Thailand set up a task force to assist financial institutions in monitoring transactions linked to military procurement. However, Thai banks have acknowledged challenges in thoroughly investigating all transactions that might be connected to the junta’s military purchases.169 The Chain of Command: Individuals Who Should Be Subject to Investigation and Prosecution The Myanmar junta military comprises six Bureaus of Special Operations (BSOs), 14 Regional Military Commands (RMCs), seven Regional Operations Commands (ROCs), 21 Military Operations Commands (MOCs), and 10 Light Infantry Divisions (LIDs).170 In addition, the Myanmar Air Force maintains eight airbase headquarters, four airbases, one aviation training airbase headquarters, one ground operations airbase headquarters, and two aircraft maintenance and production headquarters across the country, which are used to deploy aircraft conducting airstrikes against civilian targets.171 These military commands, divisions, and airbases have remained active nationwide since the coup, including during operations targeting civilians.172 Based on evidence collected and analyzed by Fortify Rights, at least 22 high-ranking officials serving the Myanmar military junta may be criminally liable under Article 28 or Article 25 of the Rome Statute for their roles in airstrikes against Kachin and Karenni civilians in 2023 and 2024. 167 U.N. Special Rapporteur on the Situation of Human Rights in Myanmar Tom Andrews, Banking on the Death Trade: How Banks and Governments Enable the Military Junta in Myanmar; Amnesty International, “Myanmar: ‘Reckless’ Shipments of Jet Fuel Continue as Air Strikes Multiply,” July 8, 2024, https://www.amnesty.org/en/latest/news/2024/07/myanmarreckless-shipments-of-jet-fuel-continue-as-air-strikes-multiply/; Global Witness, “Myanmar: New Shipments of Aviation Fuel Revealed Despite the Military’s War Crimes,” March 1, 2023, https://www.globalwitness.org/en/pressreleases/myanmar-new-shipments-of-aviation-fuel-revealed-despite-the-militarys-war-crimes/; Justice for Myanmar, “US Should Enforce Jet Fuel Sanctions on Myanmar,” July 8, 2024, https://www.justiceformyanmar.org/ press-releases/us-should-enforce-jet-fuel-sanctions-on-myanmar; and Burma Campaign UK, “British Companies: Stop Insuring Aviation Fuel Deliveries to Burma,” April 30, 2023, https://burmacampaign.org.uk/british-companiesstop-insuring-aviation-fuel-deliveries-to-burma/. 168 Singapore Ministry of Foreign Affairs, “MFA Spokesperson’s Comments on the Report of the United Nations Special Rapporteur on the Situation of Human Rights in Myanmar Issued on 26 June 2024,” June 28, 2024, https://www.mfa. gov.sg/Newsroom/Press-Statements-Transcripts-and-Photos/2024/06/20240628-UN-HR-Report. 169 “Thai Banks Admit Lack of Capacity to Investigate Myanmar Weapon Payments,” Reuters, July 11, 2024, https://www.reuters. com/world/asia-pacific/thai-banks-admit-lack-capacity-investigate-myanmar-weapon-payments-2024-07-11/. 170 Fortify Rights communication with active-duty military personnel, February and March 2021. See also, Security Force Monitor, website, https://securityforcemonitor.org/. 171 Fortify Rights communication with Myanmar Defense & Security Institute, July and August 2025. See also, Centre for Information Resilience (Myanmar Witness), Myanmar Witness Guides-Airbases, website, https://www.info-res.org/ myanmar-witness/guides/bases/; Myanmar Defense & Security Institute, Changes in the Junta’s Air Force Command and Air Operations Strategy, May 1, 2025, https://mdsi-myanmar.org/changes-in-the-juntas-air-force-commandand-air-operations-strategy/. 172 Ibid.