Remote VASP serving residents 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.

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.

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.

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.

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:

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.

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.

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.

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.

NUG's Stance: The National Unity Government (NUG), the parallel civilian government, recognized Tether (USDT) as an official currency in December 2021 to raise funds for its resistance, creating a stark contrast to the SAC's position. This is not a recognized legal tender by the de facto government.

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.

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