Issue Brief

The National Unity Government’s Revenue Denial Strategy

Myanmar’s National Unity Government hopes to cut off the military government’s revenue streams to tip the scales in favor of the resistance

By Zachary Abuza

China

September 20, 2023

The Ministry of Planning, Finance, and Investment of Myanmar’s National Unity Government is charged both with raising revenue for the Spring Revolution as well as denying revenue to Myanmar’s military government. In light of an economic downturn and exorbitant spending on the war, the junta cannot afford to lose any additional revenue. The National Unity Government’s broad revenue denial strategy has the potential to both deprive the military government of resources as well as legitimacy by adding further pressure on a regime that has a track record of economic mismanagement. In this issue brief, Zachary Abuza discusses the six ways the National Unity Government is attempting to deny revenue to Myanmar’s military government.

The opposition National Unity Government’s Ministry of Planning and Investment (MOPFI) is charged with two responsibilities: first, the ministry raises revenue to fund the Spring Revolution, which is covered in a previous report.¹ They have raised over $150 million in an innovative and tech-savvy manner through the auction of military-owned property and land preemptively seized under eminent domain, crypto bond sales, lotteries, sale of mining rights, potentially issuing shares in military-owned corporations, and now a full-service online bank.² This has all been possible through their fintech savvy. The NUG has raised all funds in a licit manner as though they are the state they aspire to be.

Second, MOPFI is charged with denying revenue to the State Administrative Council (SAC), as the junta is formally known, “to cripple the military council by limiting its access to all financial flows, including tax revenues, contractual payments, debt, and any type of financial aid, so as to degrade and destroy the machinery of oppression and control.”³ This paper will focus on the NUG’s revenue denial strategies, which can be lumped into six categories: product and service boycotts, seigniorage, establishing alternative lotteries, getting corporations to pay their taxes into escrow, collecting natural resource rents from foreign and domestic businesses, and seizing SAC-held funds overseas.

In the third year of the Spring Revolution, the military still has not consolidated power, and their effective control over the country remains tenuous in large swaths of the country. The Special Advisory Council-Myanmar’s estimates that the military effectively controls only 17 percent of the country⁴ indicate that while there is nowhere the military cannot reach, they also struggle to hold territory. Research by the Free Burma Rangers also shows a dramatic decrease in government control since the coup.⁵ One telling indicator is that the NUG now collects taxes in 38 of 330 townships.⁶

While the NUG has outperformed militarily, they are still up against a state with vastly more resources. The military increased its budget by 51 percent for FY23 to $2.7 billion.⁷ In contrast, the NUG’s Ministry of Defense has a baseline annual budget of $60 million annually.

Given that revenue remains flat, military expenditure is coming at the expense of everything else. So how can the military afford this? They cannot. The economy is the regime’s Achilles heel, and the NUG believes that a concerted strategy to deny it resources will tilt the balance of power in its favor.

Dire Economic Straits

The state of Myanmar’s economy is dismal, so the NUG’s strategy of revenue denial is not as farfetched as one might think.

While the World Bank predicts 3 percent growth in 2023, the Myanmar economy is still 10 percent smaller than it was in 2019, at $59.3 billion.⁸ Foreign trade, with the exception of oil and gas, remains weak. All new foreign investment is Chinese or boomerang money leaving Myanmar and returning via Singapore or Hong Kong. According to government data, FDI shrunk by $227 million between May 2021 and July 2023,⁹ and key manufacturers continue to pull out.¹⁰

Wages have fallen steadily. World Bank surveys indicate widespread food insecurity in the countryside and a decrease in caloric intake due to the ongoing civil war.¹¹ Electricity generation is down significantly with regular outages even in Naypyitaw.

The Central Bank of Myanmar’s (CBM) mismanagement and poorly imposed currency controls have led to a 300 percent decline in the kyat’s value, from K1,300 / $1 before the coup to K3,900 / $1. Gold prices have increased. The government is also now forcing individuals and firms to sell their unauthorized foreign exchange holdings above $10,000 to the state at the official rate of K2,100.¹²

In June 2023, the U.S. Treasury Department sanctioned two state-owned banks, responsible for almost all dollar transactions, the Myanma Foreign Trade Bank and the Myanma Investment and Commerce Bank,¹³ further putting pressure on the kyat. A Bangladesh bank also froze the accounts of the two sanctioned banks.¹⁴ The recent announcement by Singapore’s United Overseas Bank (UOB) that it will stop clearing for Myanmar banks makes foreign transactions even more difficult.¹⁵

The SAC has instructed that all border trade along the frontier with China be conducted in kyat or yuan,¹⁶ while two state-owned banks opened offices in Russia to finance bilateral trade in local currencies. Now, there is news that the government is struggling to repay a $400 million loan to China.¹⁷ The banking system, in particular the state-owned banks, is teetering.

The SAC’s revenue is flat. According to projections by their own Internal Revenue Department in the annual Union Taxation Law, total state revenue only increased from K7.969 trillion in 2019–2020 to an estimated K8.052 trillion in FY2023–24.¹⁸ Internal revenue in that same period fell by 7.5 percent, customs revenue fell by 11.5 percent, and natural resource rents fell by 9 percent.¹⁹ As the official numbers are a state secret, their own estimates are the best observers have to work with right now. So desperate for revenue, in August 2023, the military regime offered bounties up to 30 percent for people who inform on commercial tax cheats.²⁰ The World Bank has also warned of rising deficits.²¹

Another signal that the military is short on cash is that they are starting to shed state assets. A privatization commission had already sold off 55 of 107 state-owned factories by mid-2022.²² The SAC is clearly undervaluing assets for sale to members of the junta and regime cronies. This is criminal profiteering, but it is still a revenue stream.

The CBM is not a normal central bank designed to ensure broad-based economic growth and control inflation. It is a wartime central bank that supports the SAC’s war efforts above all else. To wit, in 2020, the year before the coup, government borrowing from the CBM was K2.872 trillion. In 2021, it leapt 307 percent to K11.677 trillion, before falling to K7.869 trillion in 2022.²³ The CBM acknowledged only having CBM $4.657 billion in hand at the close of Q1 2023.²⁴

The precarious economic condition has gotten the attention of the SAC. In the August 2023 cabinet reshuffle, Min Aung Hlaing appointed Lt. Gen. Nyo Saw, chairman of military-owned conglomerate Myanma Economic Corporation (MEC) and a director of Myanma Economic Holdings Ltd (MEHL), as his advisor on two key economic committees: trade and foreign exchange.²⁵ Nyo Saw is a trusted aide and arguably has more economic management experience than anyone else in the military. Still, the SAC continues to resort to its normal playbook, appointing an array of intelligence and security services to form a task force to investigate the kyat’s devaluation and soaring gold prices²⁶ and blaming speculators rather than their own incompetence.

Revenue Denial

The NUG is acutely aware of the SAC’s economic incompetence and the overall fragility of the economy, the military regime’s real Achilles heel. As such, they have identified six ways to deny the regime revenue to trigger an economic collapse: product and service boycotts, deterring bond sales and seigniorage, establishing alternative lotteries, putting foreign investment taxes in escrow, putting natural resource extraction rents from foreign and domestic businesses in escrow, and seizing SAC-held funds overseas.

1. Boycotts

Myanmar’s economy has long been dominated by the two military-owned conglomerates MEHL and MEC, which are 100 percent owned by the military and report directly to the Quartermaster’s Office. A 2019 UN Human Rights Council report, the most thorough study to date, identified 106 corporations owned by the two conglomerates,²⁷ operating in almost every sector of the economy, including ports, hotels, transportation, jewelry and gems, banks, telecommunications, commodities, food, and industrial estates.

Immediately after the coup, the NUG issued a product and services boycott list that includes 114 products, companies, and services owned directly by the military, as well as those owned by the leaders or their family members.²⁸

This list includes twenty-two individual products, four retail stores, three firms or trading houses in the gems and jewelry business, six trading companies, two banks, two telecommunications firms, two fintech companies, and the ubiquitous Myanmar Beer. In the hospitality and tourism industry, the ban includes a hotel, a travel agency, two restaurants, three venue rentals, two golf courses, and two other sports venues. In the transportation sector, it includes two gas station chains and 11 separate taxi companies. In the health care sector, it includes five military-owned hospitals and a medical supply company. The list includes five construction companies. MOPFI has called for a boycott in placing ads in three military-owned TV and radio stations and two newspapers.

Some of the boycott bans are also geared towards foreign businesses. For example, MOPFI designated three military-owned ports: the MEC-owned Hteedan Port Terminal and Ahlone International Port Terminal, and the MEHL-owned TMT Port (sometimes referred to as Bo Aung Kyaw Terminal). Taiwan’s Evergreen²⁹ and Singapore’s Transworld³⁰ both announced that they would no longer use the three military-owned ports.

The public has also boycotted companies such as Mytel, the country’s largest cellphone provider, with a pre-coup market share of 32 percent, ³¹ which is a 2017 joint venture between the Vietnamese military-owned Viettel (49 percent ownership stake), MEC (28 percent ownership stake), and several smaller military-linked investment vehicles.³² In the first quarter of 2021, it lost nearly 2 million subscribers and suffered estimated losses of $25 million.³³ As a result of the coup, Coda, a Singapore-based payments firm, cut Mytel from its mobile payments platform in March 2021,³⁴ likely contributing to the loss of subscribers. The red ink has not let up: Mytel has lost money every quarter since then and has had to lower subscription rates and offer giveaways to keep users.³⁵

While we do not know how effective all of the boycotts are, they have had an impact on the regime’s bottom line. All soldiers have a compulsory monthly deduction from their salary to buy shares in MEHL. The contribution rate is determined by their rank. All military personnel are supposed to get an annual dividend, yet none have been paid since the coup, evidence of the once-profitable conglomerate’s current financial straits. This has a real impact on morale. Given the paltry salaries of military personnel, these dividends are a financial lifeline.

MEC- and MEHL-owned firms are changing their names or establishing new front companies more frequently in order to evade sanctions, taking advantage of access to the MyCO corporate database that is tightly controlled by the military regime.³⁶ For example, an MEHL subsidiary, Myawaddy Trading Limited, established a new firm called Bhone Min Myat to import oil and palm oil.³⁷ Another recently established MEHL front company, Ever Meter, has been used to import goods from Singapore.

The full scope of sanctions evasion is even larger. Some 17,000 new companies have been registered since the coup,³⁸ incongruous with the 12 percent economic contraction and fall in foreign investment.

Since sanctions evasion is endemic and regulators are always a step behind, in mid-2023, MOPFI refocused their boycott campaign: a social media campaign on a two-month long boycott of solely military-produced alcohol and tobacco products including Myanmar Beer, Mandalay Beer, and Dagon Beer, and Red Ruby and Premium Gold cigarettes. The hope is that if the boycott is narrow and focused enough, the public will respond and ultimately change their consumer behavior.³⁹

2. Deterring Bond Sales and Seigniorage

The NUG is working very hard to stop two sources of revenue generation available to sovereigns: bond sales and seigniorage.

In 2020, the NLD government was able to raise some K17.577 trillion in the sale of short or long-term notes. It has been much harder, but not impossible, for the SAC. In 2021, it was able to sell only K13.265 trillion, a 25 percent decrease. That number remained flat in 2022 at K13.198 trillion.⁴⁰ According to NUG data, the military regime has sold K26.5 trillion in bonds, over $12 billion at the official exchange rate, or $3.1 billion at the black-market rate. Bond sales are increasingly their most reliable income stream: in 2023 they raised K17.8 trillion ($8.5 billion, or $4.5 billion at the black-market rate). U Tin Tun Naing, the minister of MOPFI, described these bonds as “one of the last financial lifelines to the junta”.⁴¹

All that begs the question, who is buying these bonds? The 2023 issuances, for example, were purchased by 14 different state-owned and crony-owned private banks, insurance companies, as well as some state-owned enterprises.⁴²

The best estimates are that domestic financial institutions are now holding the majority of government debt instruments since the coup.⁴³ As the regime is unlikely or unable to pay back the bonds, the bonds are liabilities on the regime’s already shaky balance sheets.

The NUG has unequivocally stated that they will not honor these debts as a deterrent. On June 28, 2023, the MOPFI announced that “any auctions of debt conducted without the approval of the National Unity Government shall result in no lawful liability on the State or the Government, and shall give rise to no valid claim against the State or the Government” if they were conducted after the February 1, 2021 coup.⁴⁴ As U Tin Tun Naing said at the SDB launch:

“We issued a policy notice that said any bonds sold by the SAC as illegal and invalid. This is in accordance with the law. This extends to all debt incurred by the military council. By law, only NUG-issued bonds are legal and legitimate and will be repaid. Any bonds sold by the junta are illegal and illegitimate… My sincerest advice is to not buy any of the bonds issued by the military junta. They will not be honored or repaid.”⁴⁵

A second form of revenue is seigniorage, the printing of money. The NUG estimates that the SAC has printed some K20 trillion, roughly $5.1 billion at black market rates, since the coup. That in part explained some of the 18–22 percent inflation seen in 2022.⁴⁶ In contrast, in the two years before the coup, the NLD government printed K3 trillion.

In July 2023, the government released the highest denomination currency, the K20,000 note, which predictably and immediately caused the devaluation of the currency and inflation.⁴⁷ Though it was supposed to be a limited issue, the larger denomination may be necessary given the current 14 percent inflation rate.⁴⁸ The NUG has called on the public to refuse to use the new note.

3. Alternative Lotteries

In August 2021, the NUG launched their online Victorious Spring Lottery to both take advantage of the popularity of lotteries in Burma while at the same time denying the junta the revenue stream from their own lottery. All 50,000 tickets sold out in just over an hour.⁴⁹ It was hoped that the lottery would provide a steady monthly income for the war effort, but the lottery depended on access to the banking system, which the junta began to tightly police. For the protection of its financial infrastructure as well as the safety of its patrons, the NUG suspended the lottery in May 2022. The Spring Lottery was resumed in September 2022 once its online digital wallet, NUGPay, was established.⁵⁰ It had held 20 drawings for the K2,000 lottery by July 2023.⁵¹

Even without a NUG alternative, the public has largely boycotted the military regime’s official lottery, known as the Aung Bar Lay. Following the coup, revenue from the regime’s lottery fell by 34 percent according to the SAC’s own Internal Revenue Department estimates. Their payouts were reduced to one third of the pre-coup amount. In FY2020–2021, total lottery purchases came to K86 billion compared to K160 billion in FY2019–2020.⁵² The SAC’s Internal Revenue Department predicted state lottery revenue to fall to K90 billion this fiscal year and fall to K44 billion in FY2023-24.⁵³ Even if those predictions are too dire, it has been a significant decrease in revenue.

In June 2023, the military regime launched its own online lottery application⁵⁴ with technical assistance from Mytel.⁵⁵ The SAC had announced their intentions of setting up the digital lottery in February 2022,⁵⁶ so it clearly had stumbling blocks in bringing it online. Now, the lottery is up and running. The military regime has also increased their payout and lowered the price of their tickets to compete with the NUG. Since the start of the regime’s digital lottery in June, lottery revenue has increased, forcing the NUG to innovate.⁵⁷

With the advent of the NUG’s Spring Development Bank (SDB), a new Spring Lottery will commence in October, open to SDB account holders only. The purchase of tickets will be automatically deducted from accounts and, likewise, the winnings automatically deposited. The SDB will offer a range of lottery products including a 2-digit, 3-digit, and a 4-digit lottery for different market segments, based on the Singapore Government’s own lottery. The Spring Lottery is conservatively estimated to have the potential to raise $3 million a month, which will directly support the war effort.⁵⁸

Other ethnic resistance organizations allied to the NUG, including the Karen, Chin, and Ta’ang, have recently adopted their own lotteries as a source of income, further denying revenue flows to the SAC’s own state lottery.⁵⁹

4. The Collection of Corporate Taxes

The issue of foreign investment is complicated for the NUG. Before the coup, foreign investment was an important driver of the economy and led to significant economic growth and poverty reduction. Since the coup, it is feared that FDI only serves to legitimize the regime and provide the junta with income. Therefore, the NUG tries to balance between keeping investors who are willing to protect worker rights, avoid business with proscribed companies, and withhold taxes, while simultaneously applauding firms that withdraw.

For existing investments, the MOPFI promised to “protect their interests in accordance with the rule of law” and uphold any agreements that were in place prior to February 1, 2021.⁶⁰ MOPFI also clarified that investors who made good faith commitments prior to the coup could continue those projects, but that “care must be taken to ensure that further investments neither lend legitimacy to the military junta nor fuel their ability to oppress the people of Myanmar.”⁶¹

However, MOPFI wants to deter any new investment. In its first announcement following its establishment, MOPFI imposed “unconditional suspension on issuance of investment permits and endorsements” from February 1, 2021.⁶²

The NUG issued its “Three Pillar Framework Guiding Responsible Investment and Continued Operations” on July 21, 2021, which stated that the NUG would “neither recognize nor honor new investment, proposals, agreements, or approvals concluded on or after February 1, 2021 with either the military-controlled Ministry of Planning and Finance or any other military-controlled entity, including the Myanmar Investment Commission (MIC).”⁶³

The “Three Pillar Framework” included taking any steps necessary to promote human rights, eliminate business interactions that support and sustain the military junta, and promote employee welfare and safety.⁶⁴

The second pillar required investors to avoid entering or conducting any form of business partnerships, with “restricted entities,” which they define as either “direct or indirect control or ownership by the illegal military council.”⁶⁵ The list of restricted entities includes two military-owned conglomerates, any SAC-controlled state-owned enterprises, and private enterprises that are in business with other restricted entities or new foreign investments that the SAC approved after February 1, 2021.

This includes refraining from renting buildings, land, or other infrastructure owned or operated by the military, which owns key commercial properties in Yangon, including Sule Square that is home to the World Bank⁶⁶ and other multinational corporations.⁶⁷

In August 2021, MOPFI issued a warning to investors and its first list of seven firms in breach, including companies from Japan, China, Thailand, Singapore, British Virgin Islands, and Myanmar.⁶⁸ In July 2022, MOPFI issued its “final warning” and a second list of firms for “unlawful investment activities” including six Singaporean firms (five of which were investing in solar energy), and a Chinese garment manufacturer.⁶⁹

MOPFI called on all investors to conduct regular self-assessments to ensure that they are in compliance with the “Three Pillars” and warned that failure to do so would jeopardize their investments in a future democratic government.

While many companies try to remain in Myanmar, the reputational costs of doing business with sanctioned military-owned corporations is too costly. Australian bank ANZ announced that it would withdraw from the country after its dealings with military-owned Innwa bank were revealed in late 2022.⁷⁰ It was the first foreign financial institution to pull out of the country.

Overall, foreign investment has plummeted. The total amount of foreign investment for the whole of FY2022–23 under the junta was just $100 million more than the $1.5 billion Myanmar received in the first quarter alone in 2020 under the civilian NLD government. In the first quarter of 2023, the SAC regime approved $178 million of FDI, down from $402 million in Q1 2022, which itself was down 50 percent on-year from $908 million in Q1 2021.⁷¹ Despite the significant decreases, Myanmar still received some $1.64 billion in foreign direct investment pledges in FY22–23, according to SAC data.⁷² Some foreign investors are ignoring the NUG’s prohibition on new investment, assuming that the military will prevail and believing it is so desperate that it is willing to cut a very good deal. Again, this is pledged, not realized foreign investment.

While authorizing foreign investors to stay, the “Three Pillar Framework” calls on those investors to “withhold payment of all taxes and other fiscal obligations to military-controlled authorities and instead discharge such payments to an escrow account, until the lawful and legitimate government is restored.”⁷³

In April 2023, the NUG had a well-publicized campaign led by the advocacy group Justice for Myanmar⁷⁴ to get two international brewers, Heineken and Carlsberg, to pay their taxes in escrow, but both publicly refused.⁷⁵

The Spring Development Bank is considering setting up accounts for companies to pay their taxes in escrow.⁷⁶ The reality is that the more the SAC falters and the more the NUG succeeds, companies will hedge their bets.

5. Natural Resource Rents

Beyond corporate taxes, the NUG is trying to encourage firms in the natural resource extractive industries to begin to put their rents into escrow as well, rather than remit them to the SAC government.

The NUG estimates that Ministry of Oil and Gas Enterprise (MOGE) earns between $80–100 million in rents monthly,⁷⁷ and the entire sector was forecasted to earn $1.4 billion in 2022.⁷⁸ In FY2022–23, rents paid to MOGE alone were $1.5 billion, accounting for roughly 10 percent of government revenue.⁷⁹ NUG officials have calculated MOGE to have $1.1 billion in annual revenue.⁸⁰ Oil and gas rents were the only source of revenue that saw a sharp increase since the coup, from K457 billion to K626 billion, a 37 percent increase, according to the SAC’s Internal Revenue Department’s estimates.⁸¹

On March 5, 2021, U Tin Tun Naing wrote to the Thai state-owned energy conglomerate PTT Exploration and Production Public Company (PTTEP) demanding that it both cease business ties with the SAC and “suspend all revenue payments and place such payments into protected accounts” until a democratically elected government is restored.⁸² Myanmar supplies about 15 percent of Thailand’s total gas needs through a monopoly held by PTTEP, which ignored MOPFI’s demand.

Two years later, on March 20, 2023, the NUG sent a second letter to PTTEP, the sole foreign investor in the Yadana field following the 2022 withdrawal by TotalEnergies and Chevron, demanding that they stop paying rents from the Yadana gas field to MOGE.⁸³ In FY 2022–23, Yadana made up 68 percent of the $860 million paid to MOGE.⁸⁴

That letter would not have been enough were it not for the threat to bring PTTEP to international arbitration in Singapore.⁸⁵ While unlikely that the NUG would prevail in arbitration, the threat of the arbitration and the bad optics that it would entail may have been enough. PTTEP has since invited NUG representatives to Bangkok to discuss the arbitration and what rents deposited in escrow would legally entail.⁸⁶

If this is successful, expect the NUG to pursue other investors. Even if the NUG will not be able to use those funds for itself, the simple act of denying those taxes and rents to the SAC would be a key victory. There is some evidence, according to the NUG, that POSCO, the Korean investor in the Shwe gas field, stopped remitting rents to MOGE after the EU and UK sanctions.

The SAC has worked to avoid losing this critical revenue stream. In mid-2023, SAC investigators arrested several officials while searching for a source that threatened MOGE’s revenues by leaking information that MOGE was trying to establish secret bank accounts in Myanmar Economic Bank in order to evade sanctions.⁸⁷

Not all will be susceptible to international naming and shaming; the NUG has been dealing with these in other ways. The NUG has stepped up attacks on three copper mines in Sagaing run by a major Chinese joint venture with the MEHL. In April 2022, the NUG gave warning to Wanbao Mining to cease operations. There are estimates that the firm paid $725 million in rents to the government in 2020–2021 alone.⁸⁸ At the same time, different ethnic resistance organizations have pledged to protect Chinese investment.⁸⁹

In addition to oil and gas rents, the NUG is also targeting the lucrative gems trade. Myanma Gems Enterprise (MGE) is a state-owned corporation with significant autonomy from the military-controlled Ministry of Mines. MGE is responsible for the identification of gemstone blocks, the issuance of permits for mining, the imposition of taxes in the mining sector, the establishment of joint ventures, and the holding of semi-annual wholesale gem sales. MGE also sells illegally-mined gems that have been transferred to it by law enforcement, as well as gems mined by the military or its partners.

While exact data is difficult to come by, a very detailed 2018 report on the MOGE and MGE suggests extremely high profit margins of 28 percent and 52 percent, respectively.⁹⁰ Both SOEs had excessive amounts of cash on hand, making them important cash cows for the regime. Myanmar’s gem exports are estimated to be worth $2 billion a year.⁹¹ The U.S. Government imposed sanctions on three firms involved in gem mining in February 2021,⁹² as well as Myanma Gems Enterprise in April 2021.⁹³ The NUG has lobbied for other states to adopt sanctions on state-owned gem exporters.

Human rights campaigners have also focused on the retail side. For example, the UK Campaign for Burma took credit for getting one large retailer, TJC, to stop the sale of Burmese rubies upon learning about the role gems play in facilitating human rights violations.⁹⁴ A second retailer, John Lewis, followed suit.⁹⁵

These efforts have paid off: revenue from gem sales declined from K100 billion in FY2021 to K17 billion in FY2023, according to Internal Revenue Department estimates,⁹⁶ an 83 percent decline. Other natural resources exported by state-owned corporations,⁹⁷ such as timber, are in the NUG’s sights.

6. Seizing of SAC Funds Held Overseas

Seizing SAC funds overseas is the final way to attack the regime’s revenue streams. Immediately following the coup, the U.S. Government froze $1.1 billion of Central Bank of Myanmar assets that were deposited in the Federal Reserve Bank of New York. No other country followed suit.

As a result of EU and UK sanctions on MOGE, some $504 million was placed in escrow.⁹⁸ Other attempts to freeze MOGE or other government funds have been mixed, despite sanctions by the United States, European Union, and the United Kingdom.

Nonetheless, the sanctions by these jurisdictions have imposed significant costs and made transactions less certain, especially those in the financial sector. Everything has become harder for the SAC as these financial impositions drive up costs.

The NUG has lobbied for a much wider range of sanctions, specifically those targeting the MOGE, and has expressed frustration with the limited extent of international sanctions. Key players such as Japan, South Korea, and ASEAN states have refused to impose sanctions.

The U.S. sanctions regime has been the most robust by far. Yet the United States is still focused on core regime figures, their family members, and business affiliates. To date, the United States has sanctioned 79 individuals, 38 corporations, 12 government entities, and specific military units according to the author’s dataset. While the vast majority of sanctioned corporations are domiciled in Myanmar, they do include several Singaporean holding firms, joint ventures, and three Chinese mining firms.

Sanctions require significant due diligence, and the United States and its European counterparts are always playing catch up with the changes in names, new corporate listings, and other active measures to evade sanctions. For example, the U.S. Treasury Department sanctioned two corporations, Asia Sun Group and Asia Sun Trading Co., for their involvement in the jet fuel trade in March 2023,⁹⁹ but the firms simply registered themselves under new names: Shoon Energy PTE LTD, PEIA PTE LTD, and P.E.I Energy PTE. LTD. In August 2023, Treasury then designated the three firms and their owner and director.¹⁰⁰

MOPFI is quietly trying to track down and seize CBM’s overseas accounts. In August 2023, a leaked report said that the CBM held $6.9 billion in 14 overseas banks, including nine in Singapore that accounted for 67 percent of total reserves.¹⁰¹ This was clearly meant to pressure the Monetary Authority of Singapore to take stringent action, more in line with what Singaporean banks are starting to do with their Myanmar customers.¹⁰² 12 percent of the reserves are held in a Swiss bank, while 1 percent are held in Thai, Malaysia, and Hong Kong banks. The remainder is frozen in the United States.

It is uncertain whether the NUG will succeed in seizing CBM’s funds, but MOPFI has very detailed information and is doggedly pressing their case. Should they succeed, it would be the revenue denial strategy’s coup de grâce.

Conclusion

The NUG is not going to win the war on military grounds alone. Although it has done an admirable job, its resources are simply too limited. Militarily, they must focus on targeting the regime’s ability to wage war, its logistics network, and defense industries. They must also focus on the pillars of the weakened economy.

Not only is the NUG hollowing out the military as a fighting force, but they are also putting additional pressure on an incompetent regime that diminished its economy and revenue streams. The SAC’s mismanagement of the economy is their greatest vulnerability, which makes revenue denial even more consequential. Cutting off the regime’s revenue and waging an economic war against the junta is more strategic than operating solely on military or diplomatic fronts.

Can this strategy succeed? Without a doubt, if they could get the CBM’s $6.8 billion in foreign reserves or even a significant portion of it frozen. Short of that, the strategy can still impact the military’s ability to wage war. The SAC is desperate to defeat the NUG and gave themselves a 51 percent budget increase in FY23 to that end. Given flat revenue, low growth, and soaring inflation, this increase is not sustainable.

Min Aung Hlaing and other senior leaders, including Maung Maung Win, the deputy minister of Planning and Investment, and Than Than Swe, the Central Bank Governor, have railed against the weaponization of the dollar, acknowledging the chokehold that the financial sanctions have had on the economy.¹⁰³

The way the war ends is if enough of the leadership at the operational level comes to the conclusion that the war is unwinnable and seeks a negotiated off-ramp. Key to this is depleting the military regime’s resources. This is not going to be fast or easy. The SAC is still the governing body for a $65 billion economy. Its military budget dwarfs that of the NUG.

The revenue denial strategy has a few other benefits beyond providing the NUG a pathway to ending the war. It presents a non-violent path of resistance that the international community is more likely to support. Additionally, while it is sometimes hard to gauge progress in a multi-front guerrilla war, the military regime’s economic collapse is there for all to see. The SAC has already inflicted far more damage on itself through its own mismanagement of the economy. The NUG’s revenue denial strategy may be just enough to force them to the table.

The views expressed here are the author’s alone and do not reflect the opinions of the National War College or the U.S. Department of Defense. The author would like to thank Victor P. for his help conducting research, Nick and Calvin for their insights, Sean Turnell for his encouragement, and the Stimson Center’s Yun Sun, Sydney Tucker, Pamela Kennedy and Sarah Godek for their help with the publication of this report.

Notes

1
Zachary Abuza, “Sustaining Funding for Myanmar’s Spring Revolution,” The Stimson Center, May 17, 2023, https://www.stimson.org/2023/sustaining-funding-for-myanmars-spring-revolution/.
2
Zachary Abuza, “Springing into action: Myanmar’s opposition NUG launches crypto bank,” Radio Free Asia, 22 July 2023, https://www.rfa.org/english/commentaries/myanmar-nug-bank-07222023100436.html.
3
National Unity Government, Ministry of Planning, Finance, and Investment, “Three Pillar Framework Guiding Responsible Investment and Continued Operations,” July 21, 2021, https://assets-mopfi.nugmyanmar.org/images/2021/07/NUGs-Investment-Guidance.pdf.
4
Special Advisory Council-Myanmar, “Briefing Paper: Effective Control in Myanmar,” September 5, 2022, https://specialadvisorycouncil.org/2022/09/statement-briefing-effective-control-myanmar/.
5
Free Burma Rangers, “Situation Maps: The Burma Army’s Authority Deteriorates as it Struggles to Maintain Control within the Country,” April 24, 2023, https://www.freeburmarangers.org/2023/04/24/situation-maps-the-burma-armys-authority-deteriorates-as-it-struggles-to-maintain-control-within-the-country/.
6
U Min Zayar Oo, Deputy Minister of Planning, Finance and Investment, Spring Development Bank Press Conference, July 20, 2023.
7
“Military budget boost will lead to more civilian deaths in Myanmar: Observers,” Radio Free Asia, April 12, 2023, https://www.rfa.org/english/news/myanmar/budget-04122023161634.html.
8
The World Bank, “Myanmar Economic Monitor June 2023: A fragile recovery. Key Findings,” June 27, 2023, https://www.worldbank.org/en/country/myanmar/publication/myanmar-economic-monitor-june-2023-a-fragile-recovery-key-findings#?cid=SHR_SitesShareTT_EN_EXT.
9
Directorate of Investment and Company Administration of Myanmar, “Foreign Investment by Country,” https://www.dica.gov.mm/en/data-and-statistics. See May 2021 and July 2023 foreign investment of existing projects, grant totals.
10
Note: Hein Htoo Zan, “H&M’s Forced Exit Leaves 42,000 Myanmar Workers Asking How They Will Eat,” The Irrawaddy, August 19, 2023, https://www.irrawaddy.com/news/burma/hms-forced-exit-leaves-42000-myanmar-workers-asking-how-they-will-eat.html.
11
The World Bank, “Myanmar’s economic recovery slowed by high prices and shortages,” June 27, 2023, https://www.worldbank.org/en/news/press-release/2023/06/25/myanmar-s-economic-recovery-slowed-by-high-prices-and-shortages.
12
Hein Htoo Zan, “Myanmar Junta to Form Task Force to Tackle Soaring Exchange Rates, Gold Prices,” The Irrawaddy, August 22, 2023, https://www.irrawaddy.com/business/myanmar-junta-to-form-task-force-to-tackle-soaring-exchange-rates-gold-prices.html.
13
United States Department of the Treasury, “Treasury Sanctions Burma’s Ministry of Defense and Regime-Controlled Financial Institutions,” June 21, 2023, https://home.treasury.gov/news/press-releases/jy1555, and “US places sanctions on Myanmar’s defence ministry, banks,” Reuters, June 21, 2023, https://www.reuters.com/world/asia-pacific/us-slap-new-sanctions-myanmar-state-owned-banks-sources-2023-06-21/.
14
Reyad Hossein, “Bangladesh bank freezes accounts of US-sanctioned Myanmar banks,” Benar News, August 16, 2023, https://www.benarnews.org/english/news/bengali/bank-freezes-us-sanctioned-myanmar-bank-accounts-08162023112409.html.
15
Gwen Robinson, “Key Singapore bank UOB moves to cut off Myanmar,” Nikkei Asia, 9 August 2023, https://asia.nikkei.com/Spotlight/Myanmar-Crisis/Key-Singapore-bank-UOB-moves-to-cut-off-Myanmar.
16
“Myanmar Junta Bans Dollars for Border Trade with China,” The Irrawaddy, June 8, 2023, https://www.irrawaddy.com/news/burma/myanmar-junta-bans-dollars-for-border-trade-with-china.html
17
“Myanmar junta struggles to repay $400 million Chinese bank loan due to jump in dollar price,” Mizzima News, August 13, 2023, https://www.mizzima.com/article/myanmar-junta-struggles-repay-400-million-chinese-bank-loan-due-jump-dollar-price.
18
The 2019 estimates come from Republic of the Union of Myanmar, Internal Revenue Department, Ministry of Planning and Finance, “2019 Union Taxation Law,” September 24, 2019, https://www.ird.gov.mm/sites/default/files/2019_UTL.pdf (in Burmese). The 2023 estimates come from the “2023 Union Taxation Law,” which can be found here: https://www.ird.gov.mm/sites/default/files/UTL_2023%28english%20version%29.pdf.
19
The 2019 estimates come from Republic of the Union of Myanmar, Internal Revenue Department, Ministry of Planning and Finance, “2019 Union Taxation Law,” September 24, 2019, https://www.ird.gov.mm/sites/default/files/2019_UTL.pdf (in Burmese). The 2023 estimates come from the “2023 Union Taxation Law,” which can be found here: https://www.ird.gov.mm/sites/default/files/UTL_2023%28english%20version%29.pdf.
20
“Junta Watch: Cash-Starved Regime Rewards Tax Informants; Min Aung Hlaing Harangues Law Enforcers; and More,” The Irrawaddy, August 12, 2023, https://www.irrawaddy.com/specials/junta-watch/junta-watch-cash-starved-regime-rewards-tax-informants-min-aung-hlaing-harangues-law-enforcers-and-more.html
21
The World Bank, “Myanmar Economic Monitor June 2023: A fragile recovery. Key Findings,” June 27, 2023, https://www.worldbank.org/en/country/myanmar/publication/myanmar-economic-monitor-june-2023-a-fragile-recovery-key-findings#?cid=SHR_SitesShareTT_EN_EXT.
22
Htoo Aung, “Min Aung Hlaing sells Myanmar’s state-owned factories, following in Than Shwe’s footsteps,” Myanmar Now, January 30, 2023, https://myanmar-now.org/en/news/min-aung-hlaing-sells-myanmars-state-owned-factories-following-in-than-shwes-footsteps/.
23
National Unity Government Ministry of Planning, Finance, and Investment official, personal correspondence, August 16, 2023.
24
“Myanmar Junta’s Central Bank Had $6.8 Bn in Reserves at 14 Int’l Banks in March,” The Irrawaddy, August 21, 2023, https://www.irrawaddy.com/news/myanmars-crisis-the-world/myanmar-juntas-central-bank-had-6-8-bn-in-reserves-at-14-intl-banks-in-march.html.
25
“Junta Boss Advisor Faces ‘Hopeless’ Task: Solving Myanmar’s Economic Crisis,” The Irrawaddy, August 10, 2023, https://www.irrawaddy.com/news/burma/junta-boss-advisor-faces-hopeless-task-solving-myanmars-economic-crisis.html.
26
Htein Htoo Zan, “Myanmar Junta to Form Task Force to Tackle Soaring Exchange Rates, Gold Prices,” The Irrawaddy, August 22, 2023, https://www.irrawaddy.com/business/myanmar-junta-to-form-task-force-to-tackle-soaring-exchange-rates-gold-prices.html.
27
UN Human Rights Council, Independent International Fact-Finding Mission on Myanmar, “The Economic Interests of the Myanmar Military,” August 5, 2019, https://www.ohchr.org/sites/default/files/Documents/HRBodies/HRCouncil/FFM-Myanmar/EconomicInterestsMyanmarMilitary/A_HRC_42_CRP_3.pdf.
28
National Unity Government, Ministry of Planning, Finance, and Investment, “Boycott List,” as of August 2023, https://mopfi.nugmyanmar.org/boycott-list/.
29
“Taiwan Shipping Giant Evergreen Stops Using Myanmar Junta Linked Port,” The Star, February 11, 2022, https://www.thestar.com.my/aseanplus/aseanplus-news/2022/02/11/taiwan-shipping-giant-evergreen-stops-using-myanmar-junta-linked-port.
30
Burma Campaign UK, “Transworld Removed From ‘Dirty List’ – Will No Longer Use Military Ports,” February 23, 2021, https://burmacampaign.org.uk/transworld-removed-from-dirty-list-will-no-longer-use-military-ports/.
31
“Top Largest Telecommunications Companies in Vietnam,” Vietnam Credit, September 22, 2022, https://vietnamcredit.com.vn/news/top-largest-telecommunications-companies-in-vietnam_14827
32
Sann Oo, “Military-linked telecoms operator Mytel launches network,” Frontier Myanmar, June 10, 2023, https://www.frontiermyanmar.net/en/military-linked-telecoms-operator-mytel-launches-network/.
33
Esther J, “Anti-coup movement cost junta-owned telecoms company $25m, activists say,” Myanmar Now, November 6, 2021, https://myanmar-now.org/en/news/anti-coup-movement-cost-junta-owned-telecoms-company-25m-activists-say?page=4&width=500&height=500&inline=true.
34
Business and Human Rights Resource Center, “Coda Pay removed from “Dirty List”,” March 2, 2021, https://www.business-humanrights.org/en/latest-news/coda-pay-removed-from-dirty-list/.
35
“Mytel loses millions of dollars and subscribers since coup,” Mizzima News, November 7, 2021, https://mizzima.com/article/mytel-loses-millions-dollars-and-subscribers-coup.
36
“Myanmar junta restricts access to corporate registry database,” Myanmar Now, September 28, 2023, https://myanmar-now.org/en/news/myanmar-junta-restricts-access-to-corporate-registry-database?page=1.
37
Htoo Aung, “Myanmar’s junta-owned companies maintain international economic ties despite sanctions,” Myanmar Now, February 24, 2023, https://myanmar-now.org/en/news/myanmars-junta-owned-companies-maintain-international-economic-ties-despite-sanctions/.
38
National Unity Government Ministry of Planning, Finance, and Investment official, personal correspondence, June 26, 2023.
39
National Unity Government Ministry of Planning, Finance, and Investment senior official, interview, August 12, 2023.
40
National Unity Government Ministry of Planning, Finance, and Investment official, personal correspondence, August 12, 2023.
41
U Tin Tun Naing, quoted in the Spring Development Bank private launch press conference, July 22, 2023.
42
Aung Naing, “Junta fills coffers with private bank magnates’ bond purchases,” Myanmar Now, August 17, 2023, https://myanmar-now.org/en/news/junta-fills-coffers-with private-bank-magnates-bond-purchases/.
43
Aung Naing, “Junta fills coffers with private bank magnates’ bond purchases,” Myanmar Now, August 17, 2023, https://myanmar-now.org/en/news/junta-fills-coffers-with-private-bank-magnates-bond-purchases/.
44
National Unity Government, Ministry of Planning, Finance, and Investment, “Announcement (1/2023): Announcement Regarding Illegal Issuance, Sale and Distribution of Government Securities,” June 23, 2023, https://mopfi.nugmyanmar.org/announcement-1-2023/.
45
U Tin Tun Naing, quoted in the Spring Development Bank private launch press conference, July 22, 2023.
46
“Myanmar Junta is Clueless on Inflation: Academic,” The Irrawaddy, August 22, 2023, https://www.irrawaddy.com/in-person/interview/myanmar-junta-is-clueless-on-inflation-academic.html.
47
“Myanmar junta’s new banknote causes gold prices, currency value to fluctuate,” Radio Free Asia, July 25, 2023, https://www.rfa.org/english/news/myanmar/new-banknote-07252023174642.html.
48
The World Bank, “Myanmar’s economic recovery slowed by high prices and shortages,” June 27, 2023, https://www.worldbank.org/en/news/press-release/2023/06/25/myanmar-s-economic-recovery-slowed-by-high-prices-and-shortages.
49
“Lottery-Mad Myanmar Public Turns Back on State Sweepstakes Under Junta,” The Irrawaddy, August 19, 2021, https://www.irrawaddy.com/news/burma/lottery-mad-myanmar-public-turns-back-on-state-sweepstakes-under-junta.html.
50
National Unity Government, Ministry of Planning, Finance, and Investment, “Relaunching of Spring Lottery with Better Plan,” September 7, 2022, https://mopfi.nugmyanmar.org/relaunching-of-spring-lottery-with-better-plan/.
51
“Anti-junta groups try their luck with lottery schemes,” Frontier Myanmar, July 7, 2023, https://www.frontiermyanmar.net/en/anti-junta-groups-try-their-luck-with-lottery-schemes/.
52
Kay Khine, “Junta awards tender for online lottery system to military-owned Mytel,” Myanmar Now, June 12, 2023, https://myanmar-now.org/en/news/junta-awards-tender-for-online-lottery-system-to-military-owned-mytel/.
53
The 2021 estimates come from Republic of the Union of Myanmar, Internal Revenue Department, Ministry of Planning and Finance, “2021 Union Taxation Law,” September 30, 2021, https://www.ird.gov.mm/sites/default/files/UTL_ 2021(Eng_version).pdf. The 2023 estimates come from the “2023 Union Taxation Law,” which can be found here (Burmese): https://www.mopf.gov.mm/sites/default/files/2023_Union_Taxation_Law.pdf.
54
Republic of the Union of Myanmar, Ministry of Information, “People will have easy access to buying lottery tickets and sending payments for lottery tickets through the Aungbarlay online lottery application: Senior General,” June 9, 2023, https://myanmar.gov.mm/news-media/news/-/asset_publisher/9ZewUq5mfR5F/content/people-will-have-easy-access-to-buying-lottery-tickets-and-sending-payments-for-lottery-tickets-through-the-aungbarlay-online-lottery-application-seni?_com_liferay_asset_publisher_web_portlet_AssetPublisherPortlet_INSTANCE_9ZewUq5mfR5F_redirect=https://myanmar.gov.mm/news-media/news?p_p_id=com_liferay_asset_publisher_web_portlet_AssetPublisherPortlet_INSTANCE_9ZewUq5mfR5F&p_p_lifecycle=0&p_p_state=normal&p_p_mode=view&_com_liferay_asset_publisher_web_portlet_AssetPublisherPortlet_INSTANCE_9ZewUq5mfR5F_cur=0&p_r_p_resetCur=false&_com_liferay_asset_publisher_web_portlet_AssetPublisherPortlet_INSTANCE_9ZewUq5mfR5F_assetEntryId=187318563.
55
Kay Khine, “Junta awards tender for online lottery system to military-owned Mytel,” Myanmar Now, June 12, 2023, https://myanmar-now.org/en/news/junta-awards-tender-for-online-lottery-system-to-military-owned-mytel/.
56
Khine Lin Kyaw, “Myanmar Junta Plans Digital Lottery to Shore Up State Revenue,” Bloomberg, February 17, 2022, https://www.bloomberg.com/news/articles/2022-02-18/myanmar-junta-plans-digital-lottery-to-shore-up-state-revenue#xj4y7vzkg.
57
“Anti-junta groups try their luck with lottery schemes,” Frontier Myanmar, July 7, 2023, at https://www.frontiermyanmar.net/en/anti-junta-groups-try-their-luck-with-lottery-schemes/.
58
Spring Development Bank private launch press conference, July 22, 2023.
59
“Anti-junta groups try their luck with lottery schemes,” Frontier Myanmar, July 7, 2023, https://www.frontiermyanmar.net/en/anti-junta-groups-try-their-luck-with-lottery-schemes/.
60
National Unity Government, Ministry of Planning, Finance, and Investment, “Three Pillar Framework Guiding Responsible Investment and Continued Operations,” July 21, 2021, https://assets-mopfi.nugmyanmar.org/images/2021/07/NUGs-Investment-Guidance.pdf.
61
National Unity Government, Ministry of Planning, Finance, and Investment, “Three Pillar Framework Guiding Responsible Investment and Continued Operations,” July 21, 2021, https://assets-mopfi.nugmyanmar.org/images/2021/07/NUGs-Investment-Guidance.pdf.
62
National Unity Government, Ministry of Planning, Finance, and Investment, “Announcement (5/2022),” July 21, 2022, https://mopfi.nugmyanmar.org/announcement-5-2022/ and National Unity Government, Ministry of Planning, Finance, and Investment, “Announcement (3/2021),” May 26, 2021, https://mopfi.nugmyanmar.org/announcement-3/.
63
National Unity Government, Ministry of Planning, Finance, and Investment, “Three Pillar Framework Guiding Responsible Investment and Continued Operations,” July 21, 2021, https://assets-mopfi.nugmyanmar.org/images/2021/07/NUGs-Investment-Guidance.pdf.
64
National Unity Government, Ministry of Planning, Finance, and Investment, “Three Pillar Framework Guiding Responsible Investment and Continued Operations,” July 21, 2021, https://assets-mopfi.nugmyanmar.org/images/2021/07/NUGs-Investment-Guidance.pdf.
65
National Unity Government, Ministry of Planning, Finance, and Investment, “Three Pillar Framework Guiding Responsible Investment and Continued Operations,” July 21, 2021, https://assets-mopfi.nugmyanmar.org/images/2021/07/NUGs-Investment-Guidance.pdf.
66
Organized Crome and Corruption Reporting Project, “World Bank Group Stays Mum About Office on Myanmar Military-Owned Land,” Jarred Ferrie, May 6, 2021. https://www.occrp.org/en/daily/14350-world-bank-group-stays-mum-about-office-on-myanmar-military-owned-land.
67
“Global firms leave Myanmar office block with military ties,” Reuters, May 11, 2021, https://www.reuters.com/world/asia-pacific/global-firms-leave-myanmar-office-block-with-military-ties-2021-05-11/.
68
National Unity Government, Ministry of Planning, Finance, and Investment, “Announcement (10/2021),” August 30, 2021, https://progressivevoicemyanmar.org/wp-content/uploads/2021/08/2021-08-30-MOPFI-Announcement-No.10-pio-en.pdf.
69
National Unity Government, Ministry of Planning, Finance, and Investment, “Announcement (5/2022),” July 31, 2022, https://mopfi.nugmyanmar.org/announcement-5-2022/.
70
Hein Htoo Zan, “Australia’s ANZ Bank to Exit Myanmar by Early 2023,” The Irrawaddy, November 23, 2022, https://www.irrawaddy.com/news/burma/australias-anz-bank-to-exit-myanmar-by-early-2023.html.
71
Hein Htoo Zan, “Foreign Investment in Myanmar Plunges 60% on-Year in First Quarter,” The Irrawaddy, June 8, 2023, https://www.irrawaddy.com/business/economy/foreign-investment-in-myanmar-plunges-60-on-year-in-first-quarter.html.
72
Directorate of Investment and Company Administration of Myanmar, “Foreign Investment by Country,” https://www.dica.gov.mm/en/data-and-statistics. See March 2023.
73
National Unity Government, Ministry of Planning, Finance, and Investment, “Three Pillar Framework Guiding Responsible Investment and Continued Operations,” July 21, 2021, https://assets-mopfi.nugmyanmar.org/images/2021/07/NUGs-Investment-Guidance.pdf.
74
Justice for Myanmar, “Heineken, Carlsberg and Thaibev Pay Tens of Millions of Dollars in Tax to Myanmar Junta,” April 19, 2023, https://www.justiceformyanmar.org/stories/heineken-carlsberg-and-thaibev-pay-tens-of-millions-of-dollars-in-tax-to-myanmar-junta.
75
“Tall order? Beer giants told to stop paying regime taxes in Myanmar,” Frontier Myanmar, May 10, 2023, https://www.frontiermyanmar.net/en/tall-order-beer-giants-told-to-stop-paying-regime-taxes-in-myanmar/.
76
National Unity Government Ministry of Planning, Finance, and Investment senior official, interview, August 12, 2023.
77
National Unity Government Ministry of Planning, Finance, and Investment official, personal correspondence, March 23, 2023.
78
“How much money does Myanmar’s military junta earn from oil and gas?” Myanmar Now, June 3, 2021, https://myanmar-now.org/en/news/how-much-money-does-myanmars-military-junta-earn-from-oil-and-gas.
79
National Unity Government Ministry of Planning, Finance, and Investment official, personal correspondence, August 16, 2023.
80
National Unity Government Ministry of Planning, Finance, and Investment official, personal correspondence, March 23, 2023.
81
The 2021 estimates come from Republic of the Union of Myanmar, Internal Revenue Department, Ministry of Planning and Finance, “2021 Union Taxation Law,” September 30, 2021, https://www.ird.gov.mm/sites/default/files/UTL_ 2021(Eng_version).pdf. The 2023 estimates come from the “2023 Union Taxation Law,” which can be found here (Burmese): https://www.mopf.gov.mm/sites/default/files/2023_Union_Taxation_Law.pdf.
82
The letter can be found on the Committee Representing the Pyidaungsu Hluttaw’s Facebook Page, March 16, 2021, https://www.facebook.com/photo/?fbid=135563088569671&set=pcb.135564211902892.
83
National Unity Government, Twitter Post, March 21, 2023, https://twitter.com/NUGMyanmar/status/1638152311171346437?s=20 and “NUG Demands Thai Energy Giant Switches Off Gas Payments to Myanmar Junta,” The Irrawaddy, March 21, 2023, https://www.irrawaddy.com/news/the-world-myanmar/nug-demands-thai-energy-giant-switches-off-gas-payments-to-myanmar-junta.html.
84
National Unity Government Ministry of Planning Finance, and Investment official, personal correspondence, August 16, 2023.
85
Aung Naing, “NUG requests cooperation from Thai oil and gas company, warns of potential legal action,” Myanmar Now, March 22, 2023, https://myanmar-now.org/en/news/nug-requests-cooperation-from-thai-oil-and-gas-company-warns-of-potential-legal-action.
86
National Unity Government Ministry of Planning, Finance, and Investment official, personal correspondence, August 16, 2023.
87
“Myanmar regime opens bogus bank accounts to bypass Western sanctions on MOGE,” Myanmar Now, July 6, 2023, https://myanmar-now.org/en/news/myanmar-regime-opens-bogus-bank-accounts-to-bypass-western-sanctions-on-moge/ and Hein Htoo Zan, “Myanmar Junta Forces Raid State-Owned Oil, Gas Company,” The Irrawaddy, July 7, 2023, https://www.irrawaddy.com/news/burma/myanmar-junta-forces-raid-state-owned-oil-gas-company.html.
88
“Myanmar Resistance Threatens Chinese Mines,” The Irrawaddy, April 22, 2023, https://www.irrawaddy.com/news/burma/myanmar-resistance-threatens-chinese-mines.html.
89
“Rebels vow to protect Chinese investment in Myanmar,” Radio Free Asia, July 17, 2023, https://www.rfa.org/english/news/myanmar/investment-07172023135137.html.
90
Andrew Bauer, Arkar Hein, Khin Saw Htay, Matthew Hamilton, and Paul Shortell, “State-Owned Economic Enterprise Reform in Myanmar: The Case of Natural Resource Enterprises,” Renaissance Institute and Natural Resource Governance Institute, January 2018, https://resourcegovernance.org/sites/default/files/documents/state-owned-economic-enterprise-reform-in-myanmar_0.pdf.
91
Andrew Bauer, Arkar Hein, Khin Saw Htay, Matthew Hamilton, and Paul Shortell, “State-Owned Economic Enterprise Reform in Myanmar: The Case of Natural Resource Enterprises,” Renaissance Institute and Natural Resource Governance Institute, January 2018, https://resourcegovernance.org/sites/default/files/documents/state-owned-economic-enterprise-reform-in-myanmar_0.pdf.
92
United States Department of the Treasury Office of Foreign Assets Control, “United States Targets Leaders of Burma’s Military Coup Under New Executive Order,” February 11, 2021, https://home.treasury.gov/news/press-releases/jy0024.
93
United States Department of the Treasury Office of Foreign Assets Control, “Treasury Sanctions Key Gems Enterprise in Burma,” April 8, 2021, https://home.treasury.gov/news/press-releases/jy0115.
94
UK Campaign for Burma, “TJC Withdraws Burmese Gems from Sale,” June 7, 2023, https://burmacampaign.org.uk/tjc-withdraws-burmese-gems-from-sale/.
95
UK Campaign for Burma, “John Lewis to stop sourcing gems from Burma,” July 26, 2023, https://burmacampaign.org.uk/john-lewis-to-stop-sourcing-gems-from-burma/.
96
The 2021 estimates come from Republic of the Union of Myanmar, Internal Revenue Department, Ministry of Planning and Finance, “2021 Union Taxation Law,” September 30, 2021, https://www.ird.gov.mm/sites/default/files/UTL_ 2021(Eng_version).pdf. The 2023 estimates come from the “2023 Union Taxation Law,” which can be found here (Burmese): https://www.mopf.gov.mm/sites/default/files/2023_Union_Taxation_Law.pdf.
97
“Myanmar Junta’s Timber Enterprise Eyeing Secret Bank Accounts to Bypass Sanctions,” The Irrawaddy, July 18, 2023, https://www.irrawaddy.com/news/burma/myanmar-juntas-timber-enterprise-eyeing-secret-bank-accounts-to-bypass-sanctions.html.
98
National Unity Government Ministry of Planning, Finance, and Investment official, personal correspondence, August 16, 2023.
99
United States Department of the Treasury Office of Foreign Assets Control, “Treasury Sanctions Jet Fuel Suppliers and Military Cronies in Burma Prior to Armed Forces Day,” March 24, 2023, https://home.treasury.gov/news/press-releases/jy1364.
100
United States Department of the Treasury Office of Foreign Assets Control, “Treasury Expands Burma-Related Sanctions and Designates Additional Jet Fuel Suppliers in Burma,” August 23, 2023, https://home.treasury.gov/news/press-releases/jy1701.
101
“Myanmar Junta’s Central Bank Had $6.8 Bn in Reserves at 14 Int’l Banks in March,” The Irrawaddy, August 21, 2023, https://www.irrawaddy.com/news/myanmars-crisis-the-world/myanmar-juntas-central-bank-had-6-8-bn-in-reserves-at-14-intl-banks-in-march.html.
102
Gwen Robinson, “Key Singapore bank UOB moves to cut off Myanmar,” Nikkei Asia, August 9, 2023, https://asia.nikkei.com/Spotlight/Myanmar-Crisis/Key-Singapore-bank-UOB-moves-to-cut-off-Myanmar.
103
“Myanmar junta ‘furious’ over US bank sanctions,” Radio Free Asia, August 24, 2023, https://www.rfa.org/english/news/myanmar/sanctions-08242023140203.html.

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