On-shore VASP in Myanmar

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

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.

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.

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.

Whether Adopted: No, it has not been adopted. The Central Bank of Myanmar (CBM) has consistently issued warnings against the use of cryptocurrencies and has stated that they are not legal tender. There is no specific legislation or guidance that enables or regulates Virtual Asset Service Providers (VASPs), let alone implements the Travel Rule.

Effective Date: Not applicable. Since the Travel Rule has not been adopted, there is no effective date.

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.

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:

FATF statement on High-Risk Jurisdictions: https://www.fatf-gafi.org/countries-and-regions/high-risk-and-other-monitored-jurisdictions.html (Check the "Jurisdictions subject to a FATF call on members and other jurisdictions to apply enhanced due diligence" section).

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.

Post-Coup Environment: Since the February 2021 military coup, Myanmar's financial and legal landscape has become highly opaque. The military junta (State Administration Council - SAC) maintains the ban.

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

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.

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.

Date: Ongoing since May 2020, with reiterated warnings post-coup.

Outcome: Risk of legal prosecution, imprisonment, and financial penalties for individuals and entities caught using or facilitating cryptocurrency transactions within Myanmar.

Outcome: All cryptocurrency activities are illegal. Individuals and entities found engaging in them face legal risks, including fines and imprisonment.

The Irrawaddy (February 14, 2022): "Myanmar Military Regime Cracks Down on Crypto as NUG Embrace It." (This article confirms the ban is still in effect and highlights the regime's efforts to curb it).

Bitcoin.com News (May 20, 2020): "Myanmar Central Bank Bans Cryptocurrencies, Citing Financial Risk."

Eleven Myanmar (May 17, 2020): "Central Bank of Myanmar warns to not use, trade crypto currency." (While from 2020, this is the foundational ban).