On 3 October 2025, the Central Bank of Myanmar (“CBM”) announced new monetary policy measures to absorb excess liquidity in the economy driven by increased digital payments and bank deposits at the CBM.

Key points from the new monetary policy are as follows:
  • Banks are required to maintain with the CBM interest-bearing average excess reserves (IOER) in Myanmar kyat for 28 days.
  • The IOER interest rate is set at the one-month money market average.
Historical Overview of Interest Rate on Average Excess Reserves Regulations

CBM has periodically revised the minimum reserve requirement and related interest measures to manage liquidity, support financial stability, and control inflation. We have listed below some of the key historical developments in that regard:

  • 2012–2015: The minimum reserve requirement was set at 10% of total deposits (21 May 2012) and reduced to 5% following the new Central Bank Law on 17 February 2015.
  • 2020–2021: In response to the COVID-19 pandemic, the requirement was temporarily lowered from 5% to 3.5% in 2020 and further to 3% in 2021 to ease banks’ capital positions.
  • 2021–2023: On 25 November 2021, the CBM introduced a revised formula including banks’ current accounts and cash in hand for calculating the minimum reserve. This formula was extended until 31 March 2023, with a 3% minimum divided into 2.5% deposits with the CBM and 0.5% in cash.
  • 2024: The CBM increased the minimum reserve requirement to 3.75% effective 3 May 2024 (3% at CBM, 0.75% in cash) and raised the interest rate on average excess reserves to 3.8%. Non-compliance attracted administrative actions including restrictions on auctions, branch openings, and lending.
  • 2025: To absorb excess liquidity and stabilize the kyat, the CBM announced that banks must maintain interest-bearing average excess reserves (IOER) in Myanmar kyat for 28 days, with the IOER interest rate set at the one-month money market average.

This overview highlights how the CBM has progressively adjusted reserve requirements and IOER to manage liquidity and maintain financial stability, especially during times of economic challenges.

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.

New SBV Circular raises the bar for compliance and risk management

On 15 September 2025, the State Bank of Vietnam (SBV) issued Circular No. 27/2025/TT-NHNN (“Circular 27”) guiding the implementation of key provisions of the Law on Anti-Money Laundering (the “AML Law”).

Taking effect on 1 November 2025, Circular 27 replaces Circular No. 09/2023/TT-NHNN and marks a major leap forward in Vietnam’s evolving anti-money laundering (AML) regime. The Circular sharpens compliance expectations, enhances the risk-based approach, and reaffirms Vietnam’s commitment to the Financial Action Task Force (FATF) standards on combating money laundering, terrorist financing, and Weapons of Mass Destruction proliferation financing. Reporting entities under Vietnam’s AML regime include financial institutions and certain designated non-financial businesses and professions, such as legal professionals, accountants, property agents, precious metal / gemstone dealers and other corporate services providers.

By addressing persistent implementation gaps under the previous framework, Circular 27 delivers on Action No. 5 of the National Action Plan—a cornerstone in Vietnam’s broader strategy to strengthen financial system integrity and align with global best practices.

Key Changes in Circular 27
  • Risk Assessment: Introduces a unified scoring methodology for identifying and quantifying money laundering risks.
  • Customer Due Diligence (CDD): Establishes clearer risk-based tiers and enhanced verification requirements.
  • Reporting Obligations: Tightens large-value, suspicious, and wire transfer reporting thresholds.
  • Internal Compliance: Expands mandates on AML governance, internal audits, and staff training.
  • Cross-Border Declarations: Introduces new reporting thresholds for cash, gold, and precious assets.
1. Risk Assessment and Scoring Methodology

    Article 3 of Circular 27 introduces a standardized, data-driven approach to AML risk evaluation. Reporting entities must assess risks across:

    • External factors: industry, geography, and sectoral exposure;
    • Operational factors: customer types, products, services, and distribution channels; and
    • Internal factors: the design and effectiveness of internal AML systems.

    Each risk factor is rated on a 1–5 scale, defining low, medium, and high-risk profiles. Foreign branches may adopt parent-company models if they comply with FATF standards.

    All reporting entities must submit their annual AML risk assessment results to the SBV by 31 March of the following year.

    2. Customer Risk Ratings and Due Diligence

    Article 4 of Circular 27 enhances customer due diligence (CDD) by requiring reporting entities to classify customers as low, medium, or high risk—with corresponding measures:

    • Simplified CDD for low-risk clients;
    • Standard CDD for regular clients; and
    • Enhanced CDD for high-risk clients, including:
      • Senior management approval prior to onboarding;
      • Verification of income sources and business activities; and
      • More frequent transaction monitoring and data updates.

    Circular 27 also requires that institutions define clear conditions for providing services before CDD verification is completed, effectively tightening pre-onboarding controls.

    3. Internal AML Policies and Procedures

    Under Article 5, Circular 27 demands greater depth and accountability within internal AML frameworks. Notable provisions include:

    • Conducting CDD when customers without accounts—or with accounts inactive for six months – make transactions of VND 400 million or more per day;
    • Verification of beneficial owners using reliable, independent sources;
    • Expanding KYC requirements to include founders, trustees, beneficiaries, and ultimate controllers of trusts; and
    • Continuous monitoring of customer activities, with priority scrutiny for high-risk profiles.

    These changes elevate the AML function from procedural compliance at the time of onboarding to one of ongoing strategic risk management within financial institutions.

    4. Reporting Obligations

    Articles 6, 7, and 9 refine reporting requirements to ensure faster, more transparent data flows to regulators:

    • Large-Value Transactions: Reporting applies to substantial cash deposits and VND–foreign currency exchanges.
    • Suspicious Transactions (STRs): Must be reported immediately upon suspicion, regardless of transaction amount.
    • Wire Transfers:
      • Domestic transfers ≥ VND 500 million;
      • International transfers ≥ USD 1,000;
        (excluding card payments and interbank settlements).
    5. Cross-Border Cash and Asset Declarations

    Article 11 introduces new rules governing the cross-border movement of cash, precious metals, gemstones, and negotiable instruments.

    • Threshold: Declaration required for amounts valued at VND 400 million or more.
    • Coverage: Gold, silver, platinum, jewelry, diamonds, rubies, sapphires, emeralds, and related alloys.
    • Documentation: Original invoices or lawful origin certificates; compliance with SBV’s existing currency and gold transport regulations is mandatory.

    These measures close long-standing gaps in monitoring high-value physical asset flows.

    6. Key Takeaways for Reporting Entities

    Circular 27 represents a shift from tick-the-box compliance toward dynamic, risk-based governance. The implications are significant for financial institutions, FinTech’s, and designated non-financial businesses and professions. By 1 January 2026, reporting entities should:

    1. Recalibrate AML risk scoring systems and internal controls;
    2. Upgrade CDD and STR reporting tools to capture new thresholds;
    3. Conduct targeted staff training on enhanced verification and monitoring; and
    4. Engage early with regulators to align on compliance expectations.

    For further insights on Circular 27 and AML developments in Vietnam, please contact DFDL.

    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.

    On 13 August 2025, the Ministry of Finance released the draft decree on International Financial Centre Establishment in Vietnam (“Draft Decree”) for public consultation. The Draft Decree has been prepared pursuant to Resolution No. 222/2025/QH15 of the Vietnamese National Assembly dated 27 June 2025 on an International Financial Centre in Vietnam (“Resolution 222”), which sets out policies, mechanisms, and incentives aimed at attracting and meeting the requirements of the international financial community.

    The Draft Decree provides detailed regulations and guidance on the implementation of Articles 8 and 9 of Resolution 222.

    Key highlights of the Draft Decree

    1. Establishment of International Financial Centres

    • Vietnam will establish two International Financial Centres (“IFCs”) located in Ho Chi Minh City and Da Nang City, with clearly defined geographical boundaries determined by the respective People’s Committees.
    • The official names will be:
      – Vietnam International Financial Centre in Ho Chi Minh City; and
      – Vietnam International Financial Centre in Da Nang City.
    • The IFCs are designed to promote sustainable finance, foster the development of green financial products, and mobilize resources for energy transition and green transition projects, thereby contributing to Vietnam’s socio-economic development.

    2. Membership and operation of the new IFCs

    The IFCs will introduce new, specific membership and operational frameworks in Vietnam: 

    • An IFC membership registration dossier must include:
      (i) a business registration certificate;
      (ii) the audited financial statements for the past two years; and
      (iii) a commitment to the implementation plan and operational areas of the IFC. 

    • Termination of membership will occur if an entity fails to comply with Vietnamese laws or its commitments to the IFC. A one-year grace period (until 31 December of the following year) is allowed for rectification of compliance deficits.
       
    • IFC investors will be prioritized for important projects in Vietnam. For infrastructure projects, investors must complete implementation within five years and cannot transfer the project for ten years (except in special Government-approved cases).

    • Governance agencies under Articles 10 – 13 of the Draft Decree:

      (a) Each IFC in HCMC and Da Nang will have its own management agency. These two management agencies will oversee all IFC activities and operate an online membership registration system integrated with the National Business Registration Portal – simplifying procedures.

      (b) Two supervisory agency models are proposed in the Draft Decree for consultation purposes:
      (i) one in which there is an independent supervisory agency headquartered in either HCMC or Da Nang; or
      (ii) another model with two supervisory agencies, one in each city. 

      (c) A Specialized Court will handle investor disputes, with the option for disputes to be referred to an international arbitration center, if agreed by the parties.

    3. Financial arrangements of the IFCs

    • Revenue sources for an IFC will include:
      (i) voluntary contributions and sponsorships;
      (ii) income from service provision and lawful activities; and
      (iii) allocations from the state budget.

    • Funds will be used by an IFC to:
      (i) deliver its designated public services;
      (ii) cover the IFC’s management and operational costs; and
      (iii) provide finance services and related activities.

    4. Recommended actions for stakeholders

    Interested stakeholders should consider the following next steps:

    • Monitor Legislative Progress: Closely track the final amendments to the Draft Decree and any forthcoming guiding circulars to maintain a clear and current understanding of the legal landscape.
    • Conduct a Strategic Review: Undertake a thorough assessment of how the specific provisions—particularly regarding tax, labor, and foreign exchange—will impact your proposed business model and investment structure.
    • Develop an Implementation Plan: Formulate a detailed roadmap for operational readiness and compliance to facilitate a timely and efficient entry into the IFCs upon effectiveness of the decree following 1 September 2025.

    Navigating Vietnam’s evolving regulatory environment requires specialized expertise. Should you require further information or detailed legal assistance regarding the implications of the Draft Decree, please contact DFDL.

    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.

    The Central Bank of Myanmar (“CBM”) has issued new rules on Export Proceeds Requirements for Exporters (“Notification”). These rules impose strict obligations on exporters to repatriate foreign currency earnings, reconcile proceeds with banks, and comply with documentary requirements. Non-compliance can result in blacklisting both companies and their directors, with severe legal and commercial consequences.

    Key Requirements

    1. Export licensing and shipment

      Exporters must obtain export licenses through the Ministry of Commerce’s TradeNet 2.0 system, sign sales contracts with foreign buyers, and secure an Export Declaration (“ED”) from Customs before shipment. The Myanmar Port Authority issues a Bill of Lading (“B/L”) during loading.

      2. Repatriation of proceeds

      The Notification states that the exporters must repatriate foreign currency proceeds within 30 days for exports to ASEAN countries and 60 days for exports to non-ASEAN countries. Failure to comply with this may lead to prosecution under the Foreign Exchange Management Law (“FEML”), punishable by imprisonment of up to one year, fines, or both.

      Please see our ‘Banking Compendium’ discussing the CBM laws and regulations on this aspect in 2023-24 here.

      3. Bank reconciliation

      Exporters must immediately reconcile export proceeds with their Authorized Dealer Banks (“AD Banks”), confirming which ED the proceeds correspond to and providing full supporting documents (ED, sales contract, invoice, B/L).

      The Notification states that if the documentation is incomplete or inconsistent, the proceeds will remain on CBM’s outstanding list.

      4. Monitoring and enforcement

      The CBM will monitor compliance through its Foreign Exchange Management System (FEMS), which will cross-check Customs data with bank reports. AD Banks will notify exporters regarding outstanding proceeds and set deadlines for reconciliation.

      If exporters fail to act, the CBM will escalate the matter to the Ministry of Commerce, which may suspend import-export licenses. Action Task Forces may also contact exporters directly in Yangon, Naypyidaw, and Mandalay to facilitate repayment. Continued non-compliance will result in blacklisting.

      5. Blacklisting and consequences

      The Notification states that companies that fail to repatriate or reconcile proceeds face blacklisting. Additionally, the directors of the company may also be blacklisted.

      Among other things, blacklisting restricts banking and financial services, suspends licenses, prevents directors from entering or leaving Myanmar, and causes reputational and investor confidence losses.

      6. Removal from blacklist

      To lift blacklisting, exporters must repatriate all outstanding proceeds, complete reconciliation, and apply to the CBM with bank confirmation. CBM would then instruct DICA to cross-check the directors’ involvement in other companies and verify that no related company holds outstanding export obligations before recommending removal.

      7. Special circumstances

      If exporters cannot repatriate proceeds due to deterioration of the goods, damage, defects, or re-export requirements, they must submit timely supporting documents to the CBM. The CBM may approve cancellation of such obligations after examination.

      8. Other compliance obligations

      The Notification additionally states the following:

      (i) Exporters must ensure that the ED specifies the correct bank.
      (ii) If the receiving bank differs, exporters must complete a bank name change process, which the CBM processes within one working day.
      (iii) Exporters must request formal amendments through their banks if discrepancies exist between ED data and received proceeds.

      What Exporters Must Do to Comply

      1. Repatriate proceeds on time: Deposit foreign currency proceeds within 30/60 days of export.
      2. Reconcile immediately: Match funds to the correct ED with complete supporting documentation.
      3. Verify ED details: Ensure EDs specify the correct bank; request amendments or bank name changes promptly.
      4. Maintain complete records: Keep accurate contracts, invoices, Bills of Lading, and EDs for all transactions.
      5. Act quickly on discrepancies: Submit amendment requests through banks if mismatches occur.
      6. Engage with banks proactively: Respond promptly to AD bank notifications and deadlines.
      7. Use exception procedures when necessary: Submit documentation for damaged, defective, or re-exported goods without delay.

      Conclusion

      The CBM seems to have adopted a zero-tolerance approach to export proceeds compliance applicable to companies and their related entities. This stems from the fact, and as indicated in the Notification, that, some exporters do not stay updated on regulatory requirements and instead delegate the entire export process to agents or employees. In some cases, such agents or employees use the company’s name while another business actually carries out the exports. Even when export proceeds are received by the bank, exporters often fail to complete the required reconciliation on time, which places both the company and its directors at risk of being blacklisted.

      In line with the requirements under the Notification, exporters must establish internal systems to monitor export payments, reconcile promptly with banks, and maintain accurate records.

      Failure to comply triggers escalating enforcement measures, including blacklisting and prosecution. Additionally, companies and directors must treat these requirements as a compliance priority to safeguard their operations and reputations.

      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.

      If you have not subscribed to our newsletter please do so by clicking here. While you are here, please feel free to read our recent publications covering the automobile sector (here), cybersecurity (here) and labour and employment issues in M&A (here). If you wish to see our services list, please click on ‘Solutions’ on our page here.

      On 30 May 2025, the Non-Bank Financial Services Authority issued Prakas No. 046 on the Issuance of Infrastructure Bonds (“Prakas”), establishing the regulatory framework governing the issuance and post-issuance obligations of infrastructure bonds in Cambodia. The Prakas aims to ensure that such issuances are conducted in an efficient, effective, accountable, and transparent manner.

      Key Highlights of Prakas No. 046

      This Prakas outlines the regulatory framework for infrastructure bond issuance in Cambodia. The key provisions include:

      • Scope of Application
      • Types of infrastructure Bonds
      • Eligible Infrastructure Assets for Bonds Issuance
      • Issuance Requirements
      • Post-Issuance Requirements
      • Penalties

      Should you need any further information or assistance or navigating the regulatory requirements, please reach out to us via the contacts below.

      Click “Download” button to continue reading in detail for each key highlight of this Prakas.

      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.

      On 24 June 2025, the Central Bank of Myanmar (“the CBM”) issued Notification No. 16/2025 (“the Notification”), announcing the formation of the Central Committee for the Issuance of Central Bank Digital Currency (“the Committee”), with prior approval from the State Administration Council dated 1 May 2025. The Committee is tasked with overseeing the research, development, and potential implementation of a digital kyat.

      Chaired by the CBM Governor, it includes high-level officials from the Information Technology and Cyber Security Department, the Ministry of Transport and Communications, the Ministry of Planning and Finance, the Financial Regulation Department, and the Myanmar Banks Association.

      The Notification states that the Committee is responsible for engaging with stakeholders, organizing workshops, reviewing research, and coordinating with local and international experts. It must define procedures, prepare and implement a phased plan for central bank digital currency (“the CBDC”) rollout, and ensure alignment with the approved strategy.

      The Notification further states that the Committee will study global CBDC models, assess their impacts, and evaluate technologies such as ledger systems, databases, and cybersecurity frameworks. Furthermore, the Committee will supervise the development of relevant legal and regulatory frameworks, manage operational aspects including human resources and budgeting, oversee the setup of technical infrastructure, and form and supervise working committees as required.

      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.

      The Accounting and Auditing Regulator (“AAR“), under the Non-Bank Financial Services Authority (“FSA“) Issued Instruction No. 023/25 on May 22, 2025. This instruction outlines the procedures and formalities for enterprises and non-profit organizations to prepare and submit Annual Financial Reports via the Digital Financial Reporting Platform.

      Key Highlights:

      • Platform Use:  In accordance with Prakas No. 039 FSA.P., dated May 20, 2025, on the implementation of the Financial Reporting Reduction Framework and the AAR Digital Financial Reporting Platform, all entities who use the “Digital Financial Reporting Platform” to prepare and submit annual Financial Reports to the AAR must adhere to the formalities and procedures.
      • Account Setup: Entities must register via www.acar.gov.kh, link their E-FILING account, and obtain a Financial Reporting Identification Number (FIN) if needed.
      • Report Preparation: Financial data must be entered using an Excel template or imported from approved accounting systems. A service fee is payable via KHQR.
      • Automated Compliance Verification: The enterprise or organization shall verify the financial reports using the automated compliance verification. The compliance verification includes Genuine Errors (must fix) and Possible Errors (recommended review).
      • Digital Approval: Directors approve reports using a secure 4-digit code sent via email, certifying accuracy of the financial reports.
      • Final Submission: Approved reports are submitted to AAR’s E-FILING system with payment of the annual filing fee via KHQR.

      This initiative aims to streamline reporting, enhance accuracy, and ensure timely compliance. Support is available via QR codes embedded in the instruction.

      Bookkeeping services, required to be undertaken by a licensed firm in Cambodia, are provided by Mekong Accounting Services Co., Ltd, a member of the DFDL group, a corporate member of the Kampuchea Institute of Certified Public Accountants and Auditors and licensed by the Accounting and Auditing Regulator of Cambodia.

      Recent incidents of fraudulent withdrawals from mobile financial service accounts have been reported. In light of these incidents, we wish to draw attention to the previously issued, yet still highly relevant, guidelines under Central Bank of Myanmar Notification No. 22/2023 dated 15 September 2023.

      These guidelines outline key procedures for addressing mobile financial service fraud, including the following:

      • Immediate Reporting by Victims : Fraud victims must promptly report the incident to their bank or mobile wallet operator and the nearest police station, which must open a case without delay and notify the provider via phone, fax, or email.
      • Account Freezes and Reporting: Banks or mobile wallet operators must verify the complaint, and if confirmed, freeze the relevant accounts for 72 hours, share KYC details with authorities, and report transactions to the CBM and Financial Intelligence Unit (FIU) within 24 hours.
      • Police Confirmation and Account Handling: If the police confirm a case, the investigation proceeds; otherwise, account freezes are lifted after 72 hours. Requests to reopen accounts must be referred to the CBM with input from investigators.
      • Interagency Coordination: The CBM, FIU, and Myanmar Police Force will continue to coordinate on legal proceedings, information gathering, and management of temporary account freezes in accordance with the law.

      Be aware as these protections roll out!

      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.

      Data is the new currency — and Thailand’s digital economy is demanding the infrastructure to match.

      As the Kingdom accelerates its digital transformation, data centers are becoming the backbone of Thailand’s AI, cloud, fintech, and broader tech ecosystem. Backed by strong government support and policy momentum, the digital infrastructure landscape is evolving rapidly, and opportunities are growing just as fast.

      This focused, high-impact seminar walks you through the essential pillars of entering and scaling in Thailand’s data center sector. Whether you’re exploring entry or looking to deepen your footprint, this session delivers the frameworks and insights you need to move with agility and impact.

      Core Focus Areas

      • Market Entry and Compliance Strategy: Strategic entry into Thailand’s data center market through regulatory approvals, licensing, and alignment with legal frameworks. 
      • Real Estate and Finance: Evaluation of site viability, zoning restrictions, and structuring of financing options. 
      • Power Infrastructure and Supply: Ensuring stable, high-capacity power sources to meet data center demand, with consideration for grid stability, future scalability, direct PPAs, and green energy availability. 
      • Data Privacy and Governance: Thailand PDPA-driven practices for compliant data management, storage, and cross-border transfers. 

      Walk away with actionable insights, deal frameworks, and regulatory updates that will help you navigate and expand your data center investments in Thailand.

      Who Should Attend?
      Investors, infrastructure developers, data center operators, business executives, general counsels, and digital economy stakeholders looking to tap into Thailand’s fast-growing digital infrastructure sector.

      Special Offering:
      1:1 meeting available upon request.

      Reserve your spot now by clicking “Register Here”.