On 18 May 2026, the Central Bank of Myanmar (“CBM“) issued new regulations governing offshore remittance business (the “2026 Regulations“), formally repealing the previous regulations, CBM Notification No. 21/2019 dated 15 November 2019 (the “2019 Regulations“). The 2026 Regulations significantly expand and refine the previous framework by introducing enhanced licensing requirements, strengthened AML/CFT compliance obligations, expanded reporting duties, and revised fee structures.
Key Differences from the Previous Framework:
Definition of Agents and Branch Offices: The 2019 Regulations defined agents and branch offices as entities appointed or established overseas. The 2026 Regulations fundamentally reverse this: representatives and branch offices are now defined as those appointed or established within Myanmar.
License Application Requirements: The 2026 Regulations introduce two notable changes.
- First, applicants must now submit upfront evidence that their overseas partner companies or representatives hold valid remittance licenses in their respective countries.
- Second, the threshold for shareholder criminal clearance has been expanded: whereas the 2019 Regulations required clearance only from shareholders holding 10% or more, the 2026 Regulations require clearance from all shareholders without a minimum threshold.
Revolving Fund & Account Limitation: The security deposit requirement remains unchanged at MMK 100 million. However, the 2026 Regulations introduce a new cap on revolving fund accounts, limiting license holders to a maximum of two bank accounts per country, whereas the 2019 Regulations imposed no such limitation.
Transfer Limits & Data Retention: The 2026 Regulations removed the transfer limits under the 2019 Regulations, which previously allowed only up to USD 1,000 per transaction and USD 5,000 per month for each person. Outward remittances must comply with the regulations of the sending country, and inward remittances must comply with CBM directives issued from time to time. All transaction records, regardless of amount, must now be retained for a minimum of five years.
AML/CFT Obligations: License holders must now establish –
- formal written AML/CFT policies, conduct documented risk assessments based on geography, customer type and transaction method, maintain quarterly risk reports, and implement structured staff training programmes.
- Financial institutions must also continue checking customers against the United Nations and Central Bank of Myanmar sanctions lists and must report any suspicious activities or transactions to the Financial Intelligence Unit.
- License holders must verify and retain the identity and transaction details of individuals, NGOs, and INGOs, including personal or organizational information, contact details, transfer information, purpose of transfer, and transfer amount, based on original supporting documents.
License Fee Changes:
| Types of Fees | Previous License Fees | Updated License Fees |
|---|---|---|
| Initial License | MMK 1,000,000 | MMK 3,000,000 |
| Annual | MMK 100,000 | MMK 300,000 |
| Renewal | MMK 1,000,000 | MMK 1,000,000 (Remain Unchanged) |
- A license is valid for three years.
- A license may be suspended if no business is conducted within three months of issuance or if the license holder fails to renew the license before three months prior to expiration.” into “A license may be suspended if no business is conducted within one year of issuance or if the license holder fails to renew the license before three months prior to expiration.”
- A license may also be revoked if the license holder fails to comply with regulations and directives issued by the Central Bank of Myanmar.
Fines: The 2026 Regulations impose a maximum fine of MMK 10 million, applying specifically to failure to file suspicious activity and transaction reports. General violations remain subject to legal action under applicable laws.
Key Takeaways:
License holders should:
- Review and update their record-keeping systems to ensure that all transaction records, regardless of amount, are properly retained for a period of five years.
- Conduct an audit of their revolving fund bank accounts to ensure compliance with the newly introduced two-account-per-country limitation.
- Review and strengthen their Anti-Money Laundering and Counter Financing of Terrorism policies, risk assessment procedures, and staff training programmes to align with the expanded requirements under the 2026 Regulations.
- Update their Know Your Customer procedures to ensure that full verification is conducted for every transaction.
- Obtain and submit criminal clearance certificates for all shareholders if such documents have not already been filed with the Central Bank of Myanmar.
The information provided here is for information purposes only and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.
