On 18 May 2026, the Central Bank of Myanmar (“CBM“) issued new regulations for the offshore remittance business (the 2026 Regulations). This update formally repeals the previous framework, CBM Notification No. 21/2019 (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:
Under the 2019 rules, agents and branch offices were defined as entities established overseas. The 2026 Regulations completely reverse this definition: The new rules define representatives and branch offices as entities operating within Myanmar.
License Application Requirements:
The 2026 Regulations introduce two major changes for applicants:
- First, applicants must now submit upfront evidence that their overseas partner companies or representatives hold valid remittance licenses in their respective countries.
- Second, the CBM expanded the threshold for shareholder criminal clearance: 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. License holders are now limited to a maximum of two bank accounts per country. The 2019 framework imposed no such restriction.
Transfer Limits & Data Retention: The 2026 Regulations completely remove the previous transaction limits. Under the old 2019 rules, individuals could only transfer up to USD 1,000 per transaction and USD 5,000 per month.
The CBM now enforces the following rules: Outward remittances must follow and Inward remittances must comply. Companies must store all transaction records for at least five years, regardless of the transfer amount
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 fully verify and retain the identity of individuals, NGOs, and INGOs based on original supporting documents. You must record:
- Personal or organizational information and contact details.
- Transfer amounts and specific transaction methods.
- The explicit purpose of the transfer.
License Fee Changes:
| Fee Type | Previous License Fees (2019) | Updated License Fees (2026) |
|---|---|---|
| Initial License | MMK 1,000,000 | MMK 3,000,000 |
| Annual Fee | MMK 100,000 | MMK 300,000 |
| Renewal Fee | MMK 1,000,000 | MMK 1,000,000 (Remain Unchanged) |
- A license is valid for three years.
- A license may be suspended if the holder fails to start business within one year of issuance. The Central Bank will also issue a suspension if the holder fails to apply for a renewal three months before 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 introduce a maximum fine of MMK 10 million. This penalty applies specifically to businesses that fail to file suspicious activity and transaction reports. General violations still trigger 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.
- Refine 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 informational purposes only and does not constitute legal advice. Please consult qualified legal counsel for guidance on all specific situations.
