Myanmar: A Total Ban, a Civil War, and Two Competing Digital Currencies

Cryptocurrency is comprehensively illegal in Myanmar, and the country remains in active civil war with a collapsed formal banking sector — but both the junta and the opposition NUG are separately running their own digital currencies to fund their sides of the conflict.

● Red

Cryptocurrency is comprehensively illegal in Myanmar. The junta-controlled Central Bank of Myanmar (CBM) first declared digital currencies non-legal-tender in May 2019, formalised an outright prohibition on buying, selling, or exchanging cryptocurrency under Directive 9/2020, and has repeatedly reaffirmed this ban since, most recently in a public notice on 16 November 2025 explicitly citing money laundering, scams, and international enforcement actions (including the record-setting US seizure of roughly USD 14 billion in Bitcoin tied to forced-labour scam operations) as justification.^1,2 No confirmed crypto ATM exists anywhere in Myanmar; the only listings this article could find were speculative "coming soon" placeholders from a single international operator, not documented working machines.³ This legal picture cannot be separated from Myanmar's broader situation: the country has been in active civil war since the military's February 2021 coup, with resistance forces and allied ethnic armed organisations controlling an estimated 42% of the country against the junta's 21% as of recent tracking, over 100,000 people killed, and 5.2 million displaced.⁴ In a genuinely unusual twist, both sides of this conflict have turned to digital currency for their own financing: the CBM has been developing a state-controlled central bank digital currency, while the opposition National Unity Government (NUG) has since 2022 issued its own crypto-based Digital Kyat (DMMK, built on the Stellar blockchain) and a stablecoin equivalent (nUSDT) to fund resistance operations and bypass junta-controlled banking channels — reportedly financing over USD 11.5 million in donations to the opposition.⁵ There is no advantage to weigh against the obstacle here: the obstacle is total. As in most markets on our legislation map, General Bytes as a hardware and software vendor is not itself performing a licensable activity — but in Myanmar, there is no licensable activity available to any operator at all. For GENERAL BYTES, Myanmar is not a market to research further; it is one to exclude entirely until both the legal ban and the underlying civil war are resolved.

Last updated: August 2026

Regulatory Framework and Its Evolution

Myanmar's crypto ban predates the 2021 coup and has only hardened since. Directive 9/2020 explicitly forbids the sale, purchase, or exchange of digital currencies including Bitcoin, Ethereum, and Tether, and the CBM has stated no financial institution in Myanmar is authorised to deal with digital currencies in any capacity.² Enforcement runs through the Anti-Money Laundering Law and the Financial Institutions Law, with violations exposing individuals to account freezes and legal action, though the practical reach of this enforcement has weakened considerably since the coup: Myanmar's formal banking sector nearly collapsed as bank employees joined the civil disobedience movement against military rule, and by 2025-2026 estimates put Tether usage as a genuinely dominant informal medium of exchange, alongside a de facto dual monetary system running formal kyat alongside informal USDT.

The parallel-currency dynamic is genuinely unique among the markets covered in this series: the NUG, Myanmar's parallel civilian government operating both underground domestically and in exile, declared USDT an official currency for certain government transactions, fundraising, and civil-servant salary payments as early as December 2021, and its own Digital Kyat token, distributed through a wallet app called NUGPay, functions as a pegged, donation-financed parallel currency specifically designed to route around junta-controlled banking.⁵ The CBM, for its part, launched its own Central Committee for Central Bank Digital Currency in June 2025 and announced a formal digital-currency initiative in mid-2025, positioning its own CBDC as a tool of monetary control rather than resistance financing.

Getting Licensed: Not Applicable

There is no licence to describe here. Crypto-asset services of any kind, including a cash-to-crypto ATM, are flatly illegal under Directive 9/2020, with no registration, sandbox, or pilot pathway comparable to markets elsewhere in this series. As with the rest of our legislation map, whatever authorisation might theoretically exist would sit with the in-country operator of the machines, not with General Bytes as hardware and software vendor — but in Myanmar's case, this is a purely hypothetical statement, since no such authorisation is available to anyone.

AML, KYC, and Banking

These categories are not meaningfully separable from the security and political situation in Myanmar right now. The formal banking system has been severely disrupted since 2021, foreign currency reserves have fallen to roughly half their pre-coup level, and the kyat has lost the large majority of its value against the US dollar.⁶ Any AML/KYC framework that might theoretically apply to a licensed crypto business simply does not exist in practice, given that the underlying activity itself remains banned and the formal financial system is operating under wartime conditions across large parts of the country.

The Next 24 Months: Watch the War, Not the Regulation

Myanmar's civil war shows no sign of resolving in a way that would make this market relevant to GENERAL BYTES in the near term. A staged election in early 2026 installed junta leader Min Aung Hlaing as president under what independent observers widely describe as a facade for continued military rule, and fighting has intensified rather than de-escalated, with more than 450 civilians killed in the first half of 2026 alone and analysts describing 2026 as a potential "tipping point" year for the conflict, not a resolution.^7,8 The CBM's crypto ban is one of the most stable elements of an otherwise deeply unstable situation, and there is no indication whatsoever that either the junta or the NUG intends to legalise commercial, third-party crypto ATM services, since both sides are currently using digital currency as a tool of state or resistance financing, not as a retail product to regulate and open to private operators.

For GENERAL BYTES, the honest and complete recommendation is straightforward: Myanmar should not appear in near-term market-entry planning at all. This is simultaneously a total legal ban, an active civil war affecting well over half the country, and a collapsed formal banking sector — any one of these would be sufficient reason to exclude a market from consideration in this series, and Myanmar has all three simultaneously. This entry should be revisited only if the political and security situation changes fundamentally, not on any near-term regulatory timeline.

Sources and references

1. CBM's 16 November 2025 renewed warning, citing Bitcoin seizure and Chen Zhi case — eng.mizzima.com
2. Directive 9/2020 full prohibition, AML/Financial Institutions Law enforcement — lightspark.com
3. No confirmed working Bitcoin ATM in Myanmar (speculative listings only) — atm.bitcoin.com
4. Civil war territorial control estimates (42% resistance / 21% junta), casualty and displacement figures — cfr.org
5. NUG's Digital Kyat (DMMK) and nUSDT, Stellar blockchain, $11.5M+ in financed donations — elliptic.co
6. Banking-sector collapse, currency depreciation, reserve decline since 2021 — medium.com
7. April 2026 staged election installing Min Aung Hlaing as president — cfr.org
8. 450+ civilians killed in H1 2026, 2026 as a conflict "tipping point" — theowp.org

Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. Cryptocurrency-related commercial activity is comprehensively illegal in Myanmar, and the country remains in active civil war; always consult specialised legal and security counsel and confirm the current situation directly before considering any activity in this market.