Stablecoin issuer / redeemer in Myanmar

Stablecoins are not classified as legal e-money, payment tokens, or securities by the CBM for legitimate use within the financial system.

Instead, they are treated as "virtual currencies" or "cryptocurrencies" that are not recognized as legal tender or permissible financial instruments.

The CBM views them as high-risk, unregulated assets that could destabilize the financial system and facilitate illegal activities.

Since stablecoins are prohibited, there are no specific reserve requirements for them.

The CBM does not license or regulate any entity to issue stablecoins, therefore no such requirements exist.

No licensing regime exists for stablecoin issuers.

Issuing stablecoins in Myanmar, or operating a platform that facilitates their issuance or trading, would likely be considered an illegal financial activity under existing CBM directives.

There are no legally protected redemption rights for stablecoin holders in Myanmar.

Any individual or entity engaging with stablecoins does so outside the legal framework and without regulatory protection or recourse.

Central Bank of Myanmar (CBM) Notification No. 1/2020 (29 January 2020):

No specific test exists for crypto: The official government in Myanmar has not adopted a specific legal test equivalent to the Howey Test or any other framework for classifying cryptocurrency tokens as securities. This is primarily because its stance is one of outright prohibition, rendering such classification frameworks largely irrelevant under the current official policy.

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.

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

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:

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.