2019 13 June

Myanmar Legal Update: INGOs & NGOs Conducting MFI Activities Must Be Registered as Companies and Re-Apply for Microfinance Business License


On 4 June 2019, the Financial Regulatory Department (“FRD”) issued a letter (“Letter”) directing International Non-Governmental Organizations (“INGOs”) and Non-Governmental Organizations (“NGOs”) which carry out microfinance activities to register as companies and re-apply for Microfinance Business Operation Licenses (“MFBOL”).

The FRD had previously issued MFBOLs to 3 INGO groups, 16 NGO groups, 47 foreign companies, 110 local companies, and 5 partnership firms in accordance with the Microfinance Business Law (“MBL”).

According to the Letter, the FRD requested recommendations and feedback from the Union Attorney-General Office (“UAGO”) and the Ministry of Home Affairs (“MOHA”) regarding whether the licensed INGOs and NGOs should be allowed to engage in microfinance business activities. With respect to this request for recommendation, the UAGO and MOHA clarified that INGOs and NGOs registered as associations in accordance with the Registration of Associations Law (“ROAL”) have no right to carry out microfinance business activities.

The UAGO and MOHA also mentioned that if such licensed NGOs and INGOs wish to carry out such microfinance business activities, they would have to be incorporated as a company in accordance with the Myanmar Companies Law and re-apply for an MFBOL in accordance with the MBL.

The 19 INGOs and NGOs that wish to continue engaging in microfinance activities are thus notified via this Letter of their obligation to re-form and register as companies before re-applying for a MFBOL from the Microfinance Business Supervisory Committee.

DFDL Contacts

William D. Greenlee, Jr.

Partner, Managing Director

DFDL Myanmar


Nishant Choudhary

Deputy Managing Director

Head of Banking & Finance Practice

DFDL 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.

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