Myanmar

{
  "analysis_text": "The regulatory status of cryptocurrency in Myanmar is characterized by a strict and actively enforced ban imposed by the military junta\u0027s 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.\n\nA 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\u0027s 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 \u0027terrorism\u0027 (i.e., the resistance movement).\n\nEnforcement 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.\n\nDespite 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 \u0027Gray-Zone\u0027 of extreme risk, where participants rely on informal networks (hundi) and face immediate arrest if discovered. The CBM\u0027s consistent issuance of warnings, most recently in November 2025, confirms that the state\u0027s policy remains one of zero tolerance and criminalization.",
  "confidence_level": "High",
  "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.",
  "grounding_urls": [
    {
      "resolved_url": "https://www.tilleke.com/insights/myanmars-central-bank-issues-further-warning-against-crypto-trading/12/",
      "title": "tilleke.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFBwAD8ezzrutHJly8A2IZ1CN6kDqjhAKVoVYTMz9sv4fxvZ5sqyr6uJP5V3brMkQVWpSE6hutZnZPdSoYysbVa6Wq8kinEBaLB1cOCRhVr5xc4nR8Or52imtBe6qsotMwMkRnOc0dpfXO7LpP-PLOh_ACSGsmuWCeVNwW0WjTOqLMFDo6WxCJSACryotNOx2Yc9GzLR8GKlmrnusFHApdCtl3J"
    },
    {
      "resolved_url": "https://www.tilleke.com/insights/myanmars-central-bank-issues-further-warning-against-crypto-trading/3/",
      "title": "tilleke.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEHsTgkjTZB6thLr_-NbVFm855hok8FOKkk-f2GOAS4GSDe1kttJDBe1CUR9h9abiyDejWBr86OrZ_XiP-TpJlHeLSlKSbu-sIPRfov9BazQYvVEAvA870iN-ID40pD9AzG4l0HYCEAgM5xbQd9w5HNJDNrA6f_zbIsA0BB56h3LOMtgwydzpmHOSUb7Ss3RqgyVcW3DxXlE_jG86HpEIgK92U="
    },
    {
      "resolved_url": "https://www.moi.gov.mm/moi:eng/news/14062",
      "title": "moi.gov.mm",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQF_Vj3AectnTXMOMrriLMF3MWwZTDDsuro9oo8Bkfizlcdp3NtyiO_AuZd7UZq9uoKFkr1zclS7xnInh6czyFcz5MkI3cup8-xlTBLnz197y305XwUX1oOUHuafffOUf2hWlNBT"
    },
    {
      "resolved_url": "https://www.mtnewstoday.com/en/?p=5957",
      "title": "mtnewstoday.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQET47pYX7UIAMFy8nzkf33KY3jfoPXP9GMSg1B0SRmOqBVAUqKBAQNRy4EDzk-pHBZ7a6vJWssaPURAQ4e-25pgg-oTqLylAw4wDAqaoQ3oO_N0p2FnRUwx685knYqFVXaL"
    },
    {
      "resolved_url": "https://www.lightspark.com/knowledge/is-crypto-legal-in-myanmar",
      "title": "lightspark.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQHZyjTM2nZjF07qmJ4xfLMmpeUQFdGb6JzNfrDhUjCWpbik-lr_5TDrPM3adHNHIwlDbls1EiX_ZT5PI5M5GcSgcfl3eY6Zvz4blnyz2LwSa7jZjh90qsd35_UfYILNLtW-5jXHO4HRhvoNGdFiua-6PxgcReZGF8LSeQ=="
    },
    {
      "resolved_url": "https://coinfomania.com/cryptocurrency-regulation-in-myanmar/",
      "title": "coinfomania.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFMaUH4vpqdVJxbHufwQsKIka2i3nde-Lhfw2jmnsVESwcfE4yZw95QIMBwaWvKi6a90WT6z7pUydzsXfuyK0SKPKR3TRKhcFZul6-b5GgX5Adr0vsZ_6QICKYUIi9nPpgeCHt6vOdSVUbi1vSM0l4bTCvo8fkz_Ms="
    },
    {
      "resolved_url": "https://www.tilleke.com/insights/myanmar-affirms-cryptocurrency-controls/13/",
      "title": "tilleke.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFNvinTO5x4BpQzmUv9xuuoWCuTSSIXLHi0R_i2C2hceQc07K6HCkgKU1skAkM7FuZrJecwjKHTG2gtJrsqlpAOeUE3mNj78Qc3UKk-PHkD_Iw186qvtnAYqhYT-xZKtQ7RJiV8KsEUfXezE-Q6X4laKGTVFPQa-kURCItX5jrfZ-2pBy3mylw="
    }
  ],
  "status": "Banned",
  "structured_data": {
    "confidence_level": "High",
    "detailed_analysis": "The regulatory status of cryptocurrency in Myanmar is characterized by a strict and actively enforced ban imposed by the military junta\u0027s 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.\n\nA 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\u0027s 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 \u0027terrorism\u0027 (i.e., the resistance movement).\n\nEnforcement 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.\n\nDespite 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 \u0027Gray-Zone\u0027 of extreme risk, where participants rely on informal networks (hundi) and face immediate arrest if discovered. The CBM\u0027s consistent issuance of warnings, most recently in November 2025, confirms that the state\u0027s policy remains one of zero tolerance and criminalization.",
    "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.",
    "important_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 \u0027Spring Revolution,\u0027 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."
    ],
    "key_regulatory_pillars": [
      "Central Bank of Myanmar (CBM) - Primary regulator enforcing the ban",
      "Anti-Money Laundering Law - Used to prosecute crypto users for \u0027illegal\u0027 financial flows",
      "Financial Institutions Law - Legal basis for freezing bank accounts associated with crypto",
      "State Administration Council (SAC) - Military body directing enforcement actions"
    ],
    "landmark_legislation": [
      {
        "date_enacted": "2020-05-15",
        "identifier": "Notification No. 9/2020",
        "name": "CBM Notification No. 9/2020",
        "summary": "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.",
        "url": "https://www.moi.gov.mm"
      },
      {
        "date_enacted": "2024-05-24",
        "identifier": "Public Notice May 2024",
        "name": "CBM Public Notice on Digital Currency",
        "summary": "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.",
        "url": "https://www.moi.gov.mm"
      },
      {
        "date_enacted": "2014-03-14",
        "identifier": "Pyidaungsu Hluttaw Law No. 11/2014",
        "name": "Anti-Money Laundering Law",
        "summary": "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).",
        "url": null
      }
    ],
    "notes_and_comments": "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; \u0027legal\u0027 status under the NUG offers no protection against Junta enforcement.",
    "primary_sources": [
      {
        "date": "2024-05-27",
        "key_quote": "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.",
        "source_type": "official_government",
        "title": "Public Notice: CBM Warning Against Digital Currencies",
        "url": "https://www.moi.gov.mm"
      },
      {
        "date": "2020-05-15",
        "key_quote": "Financial institutions are not allowed to accept or facilitate transactions using digital currencies.",
        "source_type": "regulator",
        "title": "Central Bank of Myanmar Notification No. 9/2020",
        "url": "https://www.cbm.gov.mm"
      }
    ],
    "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."
    ],
    "secondary_sources": [
      {
        "date": "2025-11-24",
        "key_quote": "The CBM\u0027s warning, issued November 16, 2025, reminded the public... that all online and offline cryptocurrency transactions are strictly prohibited.",
        "source_type": "analysis",
        "title": "Myanmar Affirms Cryptocurrency Controls",
        "url": "https://www.tilleke.com/insights/myanmar-affirms-cryptocurrency-controls/"
      },
      {
        "date": "2021-12-14",
        "key_quote": "The National Unity Government (NUG)... said it would allow the use of the world\u0027s largest stablecoin, Tether, as an official currency.",
        "source_type": "news",
        "title": "NUG declares USDT as official currency",
        "url": "https://www.aljazeera.com/economy/2021/12/14/myanmar-shadow-govt-approves-crypto-as-official-currency"
      }
    ],
    "status": "Banned"
  }
}