Myanmar’s New Anti-Money Laundering Law: Not Just a Banking Problem

Most of the commentary on Myanmar’s new Anti-Money Laundering Law has been written for banks. That is where the money is, so it is a reasonable place to start. But it misses the part of the Law that will surprise people.

The Law reaches law firms, accountants, company secretaries, estate agents and gem dealers. For some of them it requires notification to the supervisory authority before they may trade at all. A good number are already trading without it.

The basics

The Anti-Money Laundering Law 2026 (Law No. 16/2026) was enacted on 11 March 2026 by the National Defence and Security Council under section 427 of the Constitution. It runs to 17 chapters and 88 sections. Section 88 repeals the 2014 Law outright.

Section 2 sets the jurisdictional reach, and it is wide. The Law applies to conduct in Myanmar, to conduct aboard vessels and aircraft registered under Myanmar law, and to conduct abroad by Myanmar citizens, by permanent residents, and by foreign nationals holding permanent residency.

Who is caught

Section 3(f) names three groups: banks and financial institutions; designated non-financial businesses and professions; and anyone else the Central Body designates by notification. That third group has no edges. The perimeter can be widened without returning to the legislature, and firms should plan on the assumption that it will be.

The DNFBP list in section 3(g) has seven entries: casinos, estate agents, dealers in precious metals and gemstones, lawyers and accountants, trust and company service providers, trustees, and nominee shareholders.

For the professions, what matters is not the letterhead but the work. A law firm does not become a DNFBP by practising law. It becomes one when it handles a sale of immovable property, manages client money or a client account, organises contributions for the formation or management of a company, or provides a registered office or business address. Plenty of firms in Yangon do at least one of those things as a matter of routine, without ever having thought of it as a separate line of business.

What Chapter 9 requires

Chapter 9 contains the operative duties. Four of them will absorb most of the initial effort.

Section 26 requires a written risk assessment covering money laundering, terrorist financing and proliferation financing, kept current and produced to the authorities on request. An assessment that exists only in the managing partner’s head does not satisfy the section.

Section 27 governs customer due diligence. It is risk-sensitive rather than uniform, it specifies when CDD must be done and what it must cover, including beneficial ownership and control structure, and it says what happens when you cannot complete it. You decline the work or terminate the relationship, and you report the circumstances to the Financial Intelligence Unit. Walking away quietly is not an option the section leaves open.

Section 36(b) requires an implementation officer at senior management level. The seniority is not decorative. Section 37 gives that officer the right to demand records, registers, accounts and explanations from any employee, and the appointment is worth little if the person holding it cannot use those powers.

Section 39 deals with suspicious transaction reports, and two features of it catch people out. The duty covers attempted transactions as well as completed ones. And the section states expressly that the amount involved is not to be taken into account. There is no de minimis.

Lawyers and accountants: sections 41 and 42

These two sections have to be read together, and the drafting rewards care.

Section 41 relieves lawyers, notaries public and independent legal professionals of any duty to report information concerning matters in which they are determining a client’s legal position, including advice on whether to bring proceedings or how to avoid them.

Section 42 then requires those same professionals, and accountants, to report where they carry out a financial transaction for a client or on a client’s behalf.

So the protection attaches to the advice, not to the execution. A firm advising on the structure of a share sale sits within section 41. The same firm holding the consideration in its client account sits within section 42. The practical difficulty is that both happen in the same matter, often in the same week, and nothing on the file announces the moment the line was crossed. Firms should decide now where that line falls in their own work, and record the reasoning, rather than reconstruct it under examination.

Section 57, which almost nobody is discussing

No person, company or organization may carry on any of the activities listed in section 3(g) without first notifying the supervisory authority. Not report afterwards. Notify beforehand.

Section 63(a) supplies the penalty: six months to two years’ imprisonment, or a fine of up to MMK 300 million, or both, rising to MMK 500 million where the offender is a company or organization.

This bites on the firm that has been quietly providing registered office services for the past decade just as much as on the one opening next month. If your practice touches section 3(g), this is the obligation to check first, because it is the one you may already be breaching.

Penalties

The change most likely to alter behaviour is that the Law reaches named individuals, not only the institutions they work for.

Section 78 completes the picture, and it is the provision defence lawyers will find hardest. In proceedings connected to money laundering, the burden of proving that property is not the proceeds of crime rests on the accused.

Four questions

Are you within section 3(f) or 3(g)? For a bank the answer takes a moment. For a professional firm it means working through the section 3(g) activities against what the firm actually does, engagement by engagement.

If any of those activities are being carried on, has the section 57 notification been made? Fix this before anything else.

Does a written risk assessment exist under section 26, and has anyone read it this year?

Has the section 36(b) appointment been made, at the right level, with the section 37 powers granted in fact rather than assumed?

None of this is difficult work. It is simply work that has to be done, and the penalties for leaving it undone now fall on individuals.

Section references are to the Myanmar text of Law No. 16/2026 published by the Financial Regulatory Department. Sub-sections are cited in Latin letters following the order of the Myanmar original.

This note is general information and not legal advice. ILPC advises banks, financial institutions, professional firms, investors and development partners on regulatory and compliance matters in Myanmar, and can provide a full section-by-section briefing on request. Contact info@ilpcmm.com.