Custodial wallet / SaaS in Myanmar

None by official government: From the perspective of the official Myanmar government (SAC), no cryptocurrency tokens are officially recognized or considered as securities for regulatory purposes. All cryptocurrencies are generally deemed illegal for use as currency or investment.

The CBM issued a strong warning in May 2020 (reiterated multiple times since, especially after the 2021 coup) stating that cryptocurrencies are not legal tender in Myanmar and that engaging in their use, trading, or mining is illegal. It warned the public about the risks involved, including financial loss, fraud, and money laundering.

Following the NUG's declaration of USDT as an official currency in late 2021, the CBM under the SAC further intensified its warnings, explicitly stating that it would take legal action against anyone trading or using digital assets like USDT.

Central Bank of Myanmar Warnings (2020/2021 onwards):

Non-existent: Given the official prohibition on cryptocurrencies, there are no established registration or exemption requirements for token issuers in Myanmar. Issuing or facilitating the trading of cryptocurrency tokens would likely be viewed as an unauthorized financial activity.

Prohibited: Similarly, there are no specific rules for secondary trading of cryptocurrency tokens because all such activities are generally prohibited by the Central Bank of Myanmar. Any platforms or individuals engaging in secondary trading would be operating outside the legal framework and subject to enforcement actions.

Potential for Legal Action: Individuals or entities found to be dealing in cryptocurrencies could face charges under existing financial laws relating to unauthorized financial services, foreign exchange regulations, or potentially even broader laws depending on the specific activities involved (e.g., money laundering if large sums are involved). While specific public enforcement cases leading to conviction often receive less international media attention from Myanmar, the regulatory pronouncements themselves serve as a significant deterrent and official stance.

The Central Bank of Myanmar Directive 9/2020 banning cryptocurrencies remains formally in effect, but enforcement has shifted as the military government proposed the Anti-Online Fraud Bill in 2026 targeting specific crypto-related crimes with penalties of 10 years to life, indicating a move from a blanket prohibition to targeted prosecution of fraud.

Warnings: The CBM has issued repeated warnings against crypto use.

Arrests/Seizures: Individuals found to be trading or using cryptocurrencies might face arrest under general financial laws, anti-money laundering regulations, or even emergency decrees. These arrests are rarely publicized with detailed information, specific penalty amounts, or clear "outcomes" in a transparent legal process that can be sourced.

Nature of Enforcement: Enforcement under an outright ban is often not through public regulatory fines against entities, but rather through:

No Specific Crypto Enforcement Framework: Since crypto is banned, there isn't a dedicated "crypto enforcement" framework with specific "violation types" and "penalty amounts" distinct from general financial or illegal activity laws.

Entity Targeted: All citizens and financial institutions in Myanmar. Violation Type: Engaging in activities related to cryptocurrencies (mining, trading, holding, facilitating transactions). Penalty Amount: Not specified for individual enforcement actions, but the CBM warns against legal action. The general ban implies potential penalties under existing financial and criminal laws.

General Prohibition/Warnings: Given the CBM's stance, any involvement in cryptocurrencies could be deemed illegal, potentially leading to fines, asset seizure, or other legal consequences, although explicit legislation detailing penalties specifically for crypto use can be difficult to pinpoint publicly.

Central Bank of Myanmar (CBM) Regulations: Engaging in financial activities not permitted by the CBM or using instruments not recognized as legal tender. The specific penalties would depend on the interpretation of existing laws by the authorities.

Foreign Exchange Management Law: If cryptocurrencies are considered a form of foreign exchange or unauthorized currency, engaging in their trade or use could lead to penalties under this law.

Penalties for Non-Compliance: There are no penalties specifically for non-compliance with the FATF Travel Rule in Myanmar, as it is not law. However, individuals or entities involved in cryptocurrency activities could face penalties under existing Myanmar laws related to: