Myanmar
Retail_Trading_Status
- Analysis ID
- #736
- Version
- Latest
- Created
- 2025-12-12 04:54
- Run
- 9781c66c...
- History
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- Workflow Stage
- Step 1
Executive Summary
Retail cryptocurrency trading is explicitly illegal in Myanmar under the authority of the ruling military junta and the Central Bank of Myanmar (CBM). While the government-in-exile (National Unity Government) has declared USDT as legal tender to bypass financial sanctions, the de facto power (State Administration Council) criminalizes the possession and trading of digital assets, equating them with illegal currency conversion and terrorism financing. Offenders face severe penalties, including imprisonment and fines, under the Anti-Money Laundering Law and the Financial Institutions Law.
Key Pillars
Central Bank of Myanmar (CBM) - Primary regulator enforcing the ban
Anti-Money Laundering Law - Used to prosecute crypto users for 'illegal' financial flows
Financial Institutions Law - Legal basis for freezing bank accounts associated with crypto
State Administration Council (SAC) - Military body directing enforcement actions
Landmark Laws
CBM Notification No. 9/2020 (Notification No. 9/2020) - Enacted: 2020-05-15
- Explicitly prohibits the sale, purchase, and exchange of digital currencies (Bitcoin, Litecoin, Ethereum, Perfect Money) through personal Facebook accounts and websites. Declares that these assets are not legal tender.
- Source
CBM Public Notice on Digital Currency (Public Notice May 2024) - Enacted: 2024-05-24
- Reiterated the 2020 ban, specifically warning that violators face imprisonment and fines under the Anti-Money Laundering Law and Financial Institutions Law. Highlighted the use of USDT for illegal hundi transfers.
- Source
Anti-Money Laundering Law (Pyidaungsu Hluttaw Law No. 11/2014) - Enacted: 2014-03-14
- Broad legislation used to prosecute crypto traders by categorizing unauthorized digital asset flows as money laundering or financing of terrorism (specifically targeting support for the NUG).
Considerations
Dual Legality Conflict: The NUG (government-in-exile) recognizes USDT as legal tender, but following this puts residents at immediate risk of arrest by the Junta.
Terrorism Financing Charges: Crypto usage is often conflated with funding the 'Spring Revolution,' leading to charges under the Counter-Terrorism Law which carries potential death sentences or life imprisonment.
Surveillance: The military actively monitors mobile phones and Facebook usage for crypto apps and VPNs; physical checkpoints often involve phone searches.
Bank Account Freezes: The CBM actively orders banks to freeze accounts suspected of interacting with crypto traders or hundi agents.
Notes
The analysis date is December 2025. Recent reports indicate the CBM issued a fresh warning in November 2025, reinforcing the ban. The environment is highly volatile; 'legal' status under the NUG offers no protection against Junta enforcement.
Remaining Uncertainties
- Specific statistics on the number of arrests solely for crypto trading versus those combined with political charges.
- The technical capabilities of the Junta to track on-chain transactions versus relying on physical phone searches and informant reports.
Detailed Explanation
Detailed Explanation
As of December 2025, retail cryptocurrency trading is explicitly banned and illegal in Myanmar under the de facto authority of the military junta, the State Administration Council (SAC). The Central Bank of Myanmar (CBM) is the primary regulator enforcing this prohibition, which it first established via CBM Notification No. 9/2020 on May 15, 2020. This notification explicitly prohibited the sale, purchase, and exchange of digital currencies like Bitcoin, Litecoin, and Ethereum, declaring them not to be legal tender. The regulatory framework was reinforced on May 24, 2024, by a CBM Public Notice that reiterated the ban and specifically warned that violators face imprisonment and fines. The legal basis for these severe penalties stems from the Anti-Money Laundering Law (Pyidaungsu Hluttaw Law No. 11/2014) and the Financial Institutions Law, which are used to prosecute individuals for unauthorized digital asset flows, equating them with illegal currency conversion, money laundering, and terrorism financing. Enforcement actions are directed by the SAC, and the CBM actively orders banks to freeze accounts suspected of interacting with crypto traders. A critical and dangerous consideration is the dual legality conflict: while the government-in-exile, the National Unity Government (NUG), has declared USDT as legal tender, following this pronouncement puts residents at immediate risk of arrest by the Junta. Crypto usage is often conflated with funding opposition groups, leading to charges under the Counter-Terrorism Law, which carries potential death sentences or life imprisonment. The environment is one of intense surveillance, with the military actively monitoring mobile phones and Facebook for crypto apps and VPNs, and conducting physical phone searches at checkpoints. Recent reports indicate the CBM issued a fresh warning in November 2025, reinforcing the ban in this highly volatile landscape.
Summary Points
I. Regulatory Status
- Retail cryptocurrency trading is explicitly illegal and banned under the authority of the ruling military junta (State Administration Council).
- A dual legality conflict exists: the government-in-exile (National Unity Government) recognizes USDT as legal tender, but this offers no protection against Junta enforcement.
II. Key Regulatory Bodies
- Central Bank of Myanmar (CBM): The primary regulator issuing and enforcing the ban on digital currencies.
- State Administration Council (SAC): The military body directing enforcement actions against crypto usage.
III. Important Legislation
- CBM Notification No. 9/2020 (Enacted: 2020-05-15): Explicitly prohibits the sale, purchase, and exchange of specified digital currencies (Bitcoin, Litecoin, Ethereum, Perfect Money) and declares they are not legal tender.
- CBM Public Notice on Digital Currency (Enacted: 2024-05-24): Reiterated the 2020 ban, warning of imprisonment and fines under the Anti-Money Laundering Law and Financial Institutions Law, and highlighted the use of USDT for illegal hundi transfers.
- Anti-Money Laundering Law (Pyidaungsu Hluttaw Law No. 11/2014) (Enacted: 2014-03-14): Broad legislation used to prosecute crypto traders by categorizing unauthorized digital asset flows as money laundering or financing of terrorism.
- Financial Institutions Law: Provides the legal basis for the CBM to order banks to freeze accounts associated with crypto trading.
- Counter-Terrorism Law: Referenced for conflating crypto usage with funding the 'Spring Revolution,' carrying potential extreme penalties including death sentences or life imprisonment.
IV. Compliance Requirements
- There are no compliance pathways for retail cryptocurrency trading; the activity is entirely prohibited.
- The only de facto 'requirement' is absolute abstention from trading, holding, or transacting in digital assets to avoid severe legal consequences.
V. Notable Restrictions or Limitations
- All retail trading, possession, and exchange of digital assets like Bitcoin, Litecoin, Ethereum, and USDT are criminalized.
- Bank accounts suspected of interacting with crypto traders or hundi agents are subject to being frozen by order of the CBM.
- The military conducts active surveillance of mobile phones and Facebook usage for crypto apps and VPNs, with physical checkpoints often involving phone searches.
- Crypto usage is severely restricted by its conflation with terrorism financing charges aimed at cutting off support for the National Unity Government.
VI. Recent Developments or Notes
- The analysis date is December 2025.
- Recent reports indicate the CBM issued a fresh warning reinforcing the ban in November 2025.
- The environment is described as highly volatile; the legal status under the NUG offers no practical protection.
- Offenders face severe penalties, including imprisonment and fines, under the cited laws.
Full Analysis Report
Full Analysis Report
The regulatory status of cryptocurrency in Myanmar is characterized by a strict and actively enforced ban imposed by the military junta's Central Bank of Myanmar (CBM). Since the coup in 2021, the regime has tightened its grip on the financial system to prevent capital flight and cut off funding for resistance forces. The legal foundation for this ban was established in May 2020 via Notification No. 9/2020, which declared digital currencies like Bitcoin, Ethereum, and USDT unrecognized and illegal to trade. This stance was significantly escalated in May 2024 and again in late 2025, with public notices explicitly threatening imprisonment and fines for any individual caught buying, selling, or holding crypto assets.
A unique and dangerous dynamic exists due to the parallel government structure. The National Unity Government (NUG), which opposes the junta, declared Tether (USDT) as legal tender in December 2021 to facilitate domestic trade and bypass military-controlled banks. However, for a retail trader physically located in Myanmar, adhering to the NUG's policy is extremely perilous. The military junta controls the police, courts, and physical infrastructure, meaning that possession of a crypto wallet is often treated as evidence of funding 'terrorism' (i.e., the resistance movement).
Enforcement is rigorous and often arbitrary. Security forces frequently conduct physical checks of smartphones at checkpoints to look for VPNs and crypto applications. The CBM has directed all financial institutions to monitor for transactions related to crypto trading and to freeze suspicious accounts immediately. Under the Anti-Money Laundering Law and the Counter-Terrorism Law, charges can be severe, ranging from heavy fines to long-term imprisonment. The regime views crypto not just as a financial risk but as a threat to national security.
Despite the ban, a black market exists, primarily utilizing USDT for cross-border payments and wealth preservation amidst the collapsing Myanmar Kyat. However, this activity occurs in a 'Gray-Zone' of extreme risk, where participants rely on informal networks (hundi) and face immediate arrest if discovered. The CBM's consistent issuance of warnings, most recently in November 2025, confirms that the state's policy remains one of zero tolerance and criminalization.
The regulatory status of cryptocurrency in Myanmar is characterized by a strict and actively enforced ban imposed by the military junta's Central Bank of Myanmar (CBM). Since the coup in 2021, the regime has tightened its grip on the financial system to prevent capital flight and cut off funding for resistance forces. The legal foundation for this ban was established in May 2020 via Notification No. 9/2020, which declared digital currencies like Bitcoin, Ethereum, and USDT unrecognized and illegal to trade. This stance was significantly escalated in May 2024 and again in late 2025, with public notices explicitly threatening imprisonment and fines for any individual caught buying, selling, or holding crypto assets. A unique and dangerous dynamic exists due to the parallel government structure. The National Unity Government (NUG), which opposes the junta, declared Tether (USDT) as legal tender in December 2021 to facilitate domestic trade and bypass military-controlled banks. However, for a retail trader physically located in Myanmar, adhering to the NUG's policy is extremely perilous. The military junta controls the police, courts, and physical infrastructure, meaning that possession of a crypto wallet is often treated as evidence of funding 'terrorism' (i.e., the resistance movement). Enforcement is rigorous and often arbitrary. Security forces frequently conduct physical checks of smartphones at checkpoints to look for VPNs and crypto applications. The CBM has directed all financial institutions to monitor for transactions related to crypto trading and to freeze suspicious accounts immediately. Under the Anti-Money Laundering Law and the Counter-Terrorism Law, charges can be severe, ranging from heavy fines to long-term imprisonment. The regime views crypto not just as a financial risk but as a threat to national security. Despite the ban, a black market exists, primarily utilizing USDT for cross-border payments and wealth preservation amidst the collapsing Myanmar Kyat. However, this activity occurs in a 'Gray-Zone' of extreme risk, where participants rely on informal networks (hundi) and face immediate arrest if discovered. The CBM's consistent issuance of warnings, most recently in November 2025, confirms that the state's policy remains one of zero tolerance and criminalization.
Source Evidence
Primary and secondary sources cited in this analysis
"Legal action is taken against those involved in such transactions in accordance with the provisions of the Anti-Money Laundering Law and the Financial Institutions Law... imprisonment or fine or both."
"Financial institutions are not allowed to accept or facilitate transactions using digital currencies."
"The CBM's warning, issued November 16, 2025, reminded the public... that all online and offline cryptocurrency transactions are strictly prohibited."
"The National Unity Government (NUG)... said it would allow the use of the world's largest stablecoin, Tether, as an official currency."
Web Sources (7)
Sources discovered via web search grounding
Search queries used (5)
- NUG Myanmar USDT legal tender status
- Myanmar military junta crypto ban arrests
- Central Bank of Myanmar cryptocurrency regulation status 2024 2025
- Central Bank of Myanmar notification 2020 crypto
- Myanmar Anti-Money Laundering Law crypto
https://www.tilleke.com/insights/myanmars-central-bank-issues-further-warning-against-crypto-trading/12/
https://www.tilleke.com/insights/myanmars-central-bank-issues-further-warning-against-crypto-trading/3/
https://www.moi.gov.mm/moi:eng/news/14062
https://www.mtnewstoday.com/en/?p=5957
https://www.lightspark.com/knowledge/is-crypto-legal-in-myanmar
https://coinfomania.com/cryptocurrency-regulation-in-myanmar/
https://www.tilleke.com/insights/myanmar-affirms-cryptocurrency-controls/13/