Myanmar Station 2
What is the United States of America's interest in Myanmar, Bangladesh and the Bay of Bengal?
Sustaining Funding for Myanmar’s Spring Revolution • Stimson Center
As the National Unity Government (NUG) is embattled in the third year of their struggle to defeat Myanmar’s military junta that came to power on 1 February 2021 in an illegal coup d’état, resources continue to be a considerable challenge. Although the U.S. government froze $1.1 billion in Myanmar assets immediately following the military’s seizure of power, it has neither transferred that money to the opposition nor offered them a line of credit against it. Despite some diplomatic support, no one in the international community is providing the NUG with any meaningful material support, though there are limited amounts of humanitarian assistance.
I wrote about the innovative ways and means that the NUG was raising money,1 while the International Crisis Group made their own analysis and concluded that the military was not going to defeat a revolution that was effectively crowdsourced.2 But in what could be a make-or-break year, it is important to look at how NUG funding is progressing and evolving, and at the same time analyze how effectively the revenue denial strategy of the State Administrative Council (SAC), as the junta is formally known, is working.
The NUG continues to be an innovative, tech-savvy actor that has creatively funded their revolution through patriotic appeals, a keen knowledge of fintech, and a sense of playfulness. Their funding and banking system has only grown in sophistication. Most importantly, they have funded themselves licitly as though they are the state.
The State of Things
The NUG has outperformed by every measure and now claims that, along with its ethnic resistance organization (ERO) allies, it has effective control over roughly 50 percent of the country.3 Min Aung Hlaing has conceded that only 198 of the 330 townships are “100 percent stable,” while the remainder required “security attention.”4 Leaked minutes of a December 2022 Ministry of Home Affairs meeting warned of losing control and predicted escalating attacks.5 The Free Burma Rangers produced maps highlighting the government’s loss of effective control in April 2023.6 “Areas of authority” – i.e., where the army “controls the population and infrastructure without serious competition” – have clearly diminished since the coup.
In some liberated zones, the NUG is providing very basic social services. Twenty-three of the 330 townships in the country have a NUG prosecutor’s office and 118 judges have been appointed to administer justice. The NUG claims to have established 154 township governments, providing some degree of education in 95 townships and health services in 198.7 But the military has stepped up their attacks on the NUG’s nascent provision of social services, including attacks on 35 health clinics and 20 schools between November 2022 and April 2023.8
But more than 80 percent of the $100 million dollars the NUG claims to have raised by the end of 2022 has gone into its war efforts.
The NUG has the active support of five key EROs, the Kachin Independence Organization, Karen National Union, Karenni National Progressive Party, the Chin National Front, and the All Students Democratic Front. Together they represent 31 percent of all ERO manpower.9 The NUG has increasingly more than the tacit support of the Three Brotherhood Alliance members (the Arakan Army, the Ta’ang National Liberation Army, and the Myanmar National Democratic Alliance Army) that are not just arming and training the NUG’s PDFs but are increasingly engaged in their own military – usually defensive – operations against the Myanmar military.10
Ethnic Resistance Organizations
We should not underestimate the unprecedented degree of cooperation among the NUG and the EROs.11 While it has a long way to go, and is not irreversible due to the considerable historical mistrust, the cooperation is as good as it has ever been.
That said, the Chinese government is increasing pressure on these EROs to conclude a ceasefire agreement with the SAC. China’s special envoy to Myanmar, Deng Xijun, met with representatives from the UWSA, TNLA, KIA, NDAA, SSPP, and AA in Kunming, a week after meeting them in Pangsang in March 2023.12 With key BRI projects stalled, including the railway to the port of Kyaukphu, China is increasing pressure for them to halt offensive operations and their active support for the NUG.13
The NUG has over 300 affiliated People’s Defense Forces (PDFs) throughout the country in some part of its chain of command. There are roughly 200 Local Defense Forces that are also fighting the military, but which are outside of NUG control. Unfortunately, they are disparate groups that are unable or unwilling to cooperate with one another and achieve a unity of force. The NUG lacks secure communications to help tie these PDFs into a more coherent fighting force. Often an ERO cannot communicate with a neighboring PDF.
Nonetheless, they have bogged down the Tatmadaw, as the Myanmar military is known, in a multi-front war, with now long and vulnerable supply lines that must be defended through the once-secure Bamar heartland. It is there where the military has retaliated with particular ferocity and brutality.14 The UN Development Programme, using ACLED data, has painted a clear picture of the top 10 percent of violence mostly in villages in the Bamar heartland of Magway and Sagaing.15
The military is increasingly reliant on long-range artillery strikes and air assaults. The use of planes and helicopters is increasing, with new jets and rotary wing aircraft imported from both Russia and China.16 There were at least 600 air attacks by the military between February 2021 and January 2023, a tacit acknowledgment that the Tatmadaw is unable to deploy forces in large parts of the country. 17 While the SAC has staved off mass defections,18 19 That said, they have used their intelligence capabilities to weaken the NUG’s urban operations.20
The military has employed its traditional “four cuts” strategy, a counterinsurgency doctrine that is based not on winning hearts and minds but instead on terrorizing the population into submission.21 forced conscription as porters, beheadings,22 summary execution, and the systemic use of rape and sexual violence. The military routinely attacks houses of worship and strikes civilian targets with artillery and air assets.
The military has admitted to losing control in 132 of the 330 townships, 42 percent.23 As a sign of their tenuous control,24 the military has declared martial law now in 47 townships, 14 percent of the total.25 As NUG Foreign Minister Zin Mar Aung said, “That is their confession that they lost control.”26 The SAC extended the period of emergency rule by an additional six months on 31 January 2023. There are signs that it will not hold elections until 2024 or 2025.27
The SAC has arrested the freefall in the economy. The World Bank is predicting up to 3 percent growth in 2023 with inflation around 8 percent.28 But the economy is still woefully mismanaged, with over half of the 30 ministries headed by uniformed military personnel and even more at the deputy minister level.29 There are ever-changing rules and regulations, especially on the issue of currency controls, that impact the banking system and traders.30 Over half the population is living in poverty.
Arming the NUG
The NUG has had to purchase its arms and ammunition on the black market, which has significantly increased the prices. Automatic rifles that once cost $1,000 are now selling for between $3,00 and 4,000. Money does not go far in war.
The NUG has begun its own weapons production, including 60mm and 90mm mortars, and has even dabbled in 3D printed guns.31 It has used commercial quadcopter drones to drop mortar shells.32 Longer-range modified and armed drones cost between $1,000-1,500. But many of their homemade weapons are crudely fashioned rocket launchers and mortars, which have killed their users.
The NUG acknowledges that it costs $1 million to arm a battalion and that to arm all the existing battalions would cost over $100 million. That does not include sustainment and new inflows of ammunition.33 And of course there are costly battlefield losses.34
Already, many PDFs complain that they have not received support. As one NUG Ministry of Defense senior official put it:
It is possible that we could not provide as many as they want. We are trying to deliver the arms we have promised. But there are delays due to logistical hurdles, financial constraints, and other factors. We request understanding from the people and resistance forces. There are also delays because we are trying to systematize the supply chains.
In addition, the NUG has shared resources with its allied EROs, which have provided training, arms, and ammunition for its PDFs.
As Acting President Duwa Lashi La summed up, “If we supply enough guns and raise enough funds, our revolution will be over quickly.”35 But he acknowledged, “The trouble in the revolution, though, is that guns are hard to obtain. We also don’t have a weapons factory.”
Even with $100 million, the resources are dwarfed by the Myanmar military, whose official budget for FY2023-24 increased by 51 percent to $2.7 billion at official rates, accounting for 30 percent of government spending.36 Given that revenue remains flat, the increase in the military’s expenditures is coming at the expense of everything else.
The military has considerable off-budget sources of funding through two military-owned conglomerates, Myanma Economic Holdings Ltd. (MEHL) and Myanmar Economic Corporation (MEC), that together have some 130 subsidiaries and joint ventures.37 Its foreign reserves are estimated at $5-6 billion, now that the kyat has stabilized.
As one senior NUG official told me, “The $100 million is gone already.”
So how is the NUG raising funds?
The NUG has always stated that it intends to raise money as a state would lawfully raise money: through the sale of bonds, rents from natural resources and sale of assets, lotteries, taxes, and donations. The NUG has foresworn the production, trade, or taxation of illicit narcotics – one of the first major anti-state actors in Myanmar to do so – even as the production of methamphetamine soars to record levels and the cultivation of opium poppy went up by 33 percent in 2022.38
Bonds
The sale of bonds online continues since its initial offering in November 2021, which raised $6.3 million on its first day.39 The sales and revenue generated continue to go through accounts in the Czech Republic.40 The bonds have been targeted largely at the diaspora community. In December 2021, the NUG, after figuring out how people could purchase the bonds safely from within Myanmar through the KIO’s remittance system, began to sell them domestically.41
These bonds are zero interest, meaning that people are buying them out of patriotic duty, not as an investment.42 The money is put into Tether, a “stablecoin”, i.e., a digital currency that is pegged to the U.S. dollar, which is the NUG’s official currency.43 The bonds are denominated in $100, $500, $1,000, and $5,000 denominations. The NUG still has not translated the website into English or other languages to broaden its market.
Of the $100 million that the NUG had raised by the end of 2022, 45 percent came from the sale of bonds.44 To date nearly $50 million has been raised through bonds.45
The NUG continues to issue bonds in conjunction with partner EROs and shares the proceeds of these designated debt instruments with them. Bond sales have slowed, but the NUG argues it is because there are other assets for sale. Note: Personal communication with MOPFI staff, 10 April 2023.
Real Estate
Perhaps the most important source of revenue is the sale of military-owned real estate, either directly military-owned or illegally appropriated property held by senior officers.
The first sale was lighthearted and meant to needle the SAC’s leadership: The NUG auctioned a large lakeside villa “owned” by Min Aung Hlaing. The 14 Inya Lake property was a military guest house, but illegally appropriated by Min Aung Hlaing.46 The 5 May 2022 auction of $100 shares in Min Aung Hlaing’s misappropriated villa netted the NUG $5 million. A second leadership home was auctioned.
Afterwards, the NUG’s Ministry of Planning, Finance, and Investment (MOPFI) identified 60 separate plots in Yangon that the NUG intended to confiscate and sell. The first auction raised $42 million.47 Identified military land includes 10 acres that is home to the military’s archive and 30 acres that was the home of the Defense Forces Academy.48
In January 2023, MOPFI sold 770 condominium units (not yet constructed) on land owned by the military in a prime downtown Yangon location. Within 18 hours 96 percent of the units had been sold raising $10.1 million.49 In February 2023, MOPFI held another auction and sold 6,500 units in one day on three separate parcels of military-owned land in Yangon. The units, which went for $4,400 to $11,400, were so popular that the MOPFI put another 3,500 up for sale.50
For the buyers, it’s a leap of faith that the Spring Revolution will succeed and the real estate will be built as promised. For all the properties, purchasers must put down 30 percent deposit, the remainder to be paid after the NUG assumes power.
Unlike the bonds which require an official government-issued identification card, MOPFI has no such requirements for its sale of real estate, in the hopes that more citizens within Myanmar will participate.
MOPFI has conducted a similar auction in Mandalay. In November 2022, it launched the Spring Rose Real Estate Project that sold 20 plots for $240,000 each; One person bought 10 plots as a show of support.51
Auctions of land sales in other cities are being planned, and the NUG is currently in discussions with two different state and local governments to finalize the properties, scale of the development, and revenue sharing.52 Another condominium project in Yangon is expected in mid-2023.
Mining Rights
Building on their success with real estate, the Minister of Planning, Finance, and Investment U Tin Tun Naing began to auction off mining rights throughout the mineral-rich country.
This strategy entails far greater risk for any mines outside of the NUG’s immediate control. For those within its direct control, MOPFI seeks participation from the NUG’s Environment Ministry to make an impact statement and engage the local community. “While we aim to raise funds for the revolution, we also want to systematize the mining of natural resources,” as the minister for electricity and energy noted. As in many other aspects, the NUG is trying to lay out a more technocratic and deliberative policy process that they will implement upon assuming control.53
In February 2023, MOPFI signed its first major agreement: a $5 million lease for mining in Mogok Township, outside of Mandalay near Shan State. The agreement, a 51-49 joint venture between the NUG and the firm, will go into operation following the defeat of the SAC.54 The mine is currently located in a contested space, in an area increasingly controlled by the TNLA and an NUG PDF.55 Late 2022 saw a significant increase in violence in the region when the military attacked TNLA positions, according to ACLED data.56
The MOPFI has identified 44 additional mining sites that it will auction off.57 This, of course, has real risks. While the people who win the development rights are kept confidential, the location of the sites are publicized.58
The people who win the rights are not only betting on the fact that the NUG will win, but more importantly that the SAC is not immediately going to go out and try to seize that territory and exploit those finite resources in the meantime. If the Tatmadaw knows some of those 45 sites are in areas that the NUG does not have full control over, the SAC has every incentive to hold and exploit those resources as a deterrent to future mining rights auctions.
Taxation
The NUG has increased its revenue collection in the territories that it controls. By the end of 2022, the NUG had implemented tax collection in 38 of the country’s 330 townships and collected 3 billion kyat ($1.43 million) in tax revenue.59
Taxation creates a right-duty bond between the citizen and the state. In return for revenue, the NUG is trying to improve service delivery. But for the NUG it is a very fine line.
First, the population is suffering from two years of economic decline, high rates of inflation, declining crop yields, and overall economic mismanagement. Moreover, it cannot tax in contested areas where the military government is also collecting taxes, and that is most of the country.
The NUG has offered digital receipts to individuals and companies that pay taxes.
It’s also important to note that not everything goes through NUG channels. Many PDFs rely on “local contributions” (some would say taxes) that are increasingly less voluntary. The local population may be able to provide them with food, but the days of people running out to donate their jewelry and cash are coming to an end, especially as the military has retaliated with a scorched earth campaign that has left 65,000 homes burned to the ground.
PDFs and Local Defense Forces outside of the NUG chain of command have established their own toll booths and extortion rackets, things that will not endear them to the community over the long-term.
Donations
While the NUG doesn’t want to depend on donations, as they are unreliable, it certainly takes them from private individuals, corporations, or foreign governments or multilateral lending institutions. In one famous example, a group of coders made an online video game, War of Heroes, that they sold for $0.99, and they have donated the proceeds to the NUG.60 The single largest contributor to the NUG donated $6 million.61 Diaspora groups and EROs engage in constant fundraisers and direct appeals.62
The NUG is not alone. The Karreni Nationalities Defense Forces began 2023 with a patriotic crowdfunding challenge to pay for three M16s in 15 days (each gun cost around 12 million kyat, or $5,700).63
The NUG’s “Project Dragonfly” raised some $2.2 million in direct appeals by April 2023 from both domestic and international supporters.64
Likewise, urban guerrillas, who long complained that the NUG has not supported them sufficiently, have crowdfunded their own operations. Urban operations have dwindled due to a lack of resources and a concerted counterinsurgency campaign.
Lawfare
A new potential revenue stream for the NUG is lawfare.
On 20 March 2023, the NUG sent a letter to PTT Exploration and Production Public Company (PTTEP), a subsidiary of Thailand’s state-owned energy conglomerate, demanding that they stop paying rents from the Yadana gas field to the SAC’s Ministry of Oil and Gas Enterprise (MOGE).65 There are estimates that MOGE earns between $80 and 100 million in rents monthly and that the entire sector earns $1.4 billion annually for the government.66 NUG officials have calculated it to be $1.1 billion, including taxes.67
MOPFI also demanded provide a full accounting of rents to MOGE. PTTEP is the sole foreign investor in the Yadana field following the 2022 withdrawal by TotalEnergies and Chevron.68
MOPFI is prepared to press the case at the Singapore International Arbitration Center, and claims that it has approached donors to fund the lawsuit.69 But it seems highly unlikely that the NUG would fare well in the regional business hub, which has a vested interest in deterring activist suits.
While the NUG is right to consider lawfare, both as a potential revenue stream as well as a means to deny the SAC income, it needs to better consider the legal jurisdictions.
A pro-opposition activist group, Justice for Myanmar, has been advocating for those multinational corporations still invested in Myanmar to put their taxes in escrow or make additional direct payments to the NUG. The firms, in this case three international brewers, have not responded and continue to make their tax payments to the state.70
Privatization
While the NUG has successfully auctioned off military land, so far they have not preemptively auctioned off the Tatmadaw’s vast corporate assets. A 2019 UN Human Rights Council report identified 106 corporations owned by the two military-owned conglomerates, 45 owned by MEHL and MEC 61 by MEC. The UN identified 27 other firms that were “closely affiliated” with the conglomerates.71
The NUG has plans to commence the gradual privatization of MEC and MEHL-owned companies “through shares offered to the general public” in June 2023. The NUG has already identified the “most attractive assets,” though they have not been made public.72
Again, this assumes that the NUG, once defeating the SAC, will be able to take over the assets, many of which have foreign investors, through eminent domain, and that they can enforce the new ownership structure. It’s a creative source of revenue, but a risky investment.
Converting Revenue into Usable Funds
Another concern for the NUG has been moving money across international borders in a post-9/11 financial system that applies far greater scrutiny to sub-state actors, and turning digital currencies into usable funds that can be exchanged for weapons and ammunition. Even PayPal accounts have been blocked by the SAC.
As mentioned above, the NUG is using Tether, a digital currency, to move funds from overseas.
In June 2022, the NUG established the Digital Myanmar Kyat (DMMK), a digital currency that is run through the open-source blockchain Stellar network73 and is used through its digital wallet app, called NUGPay, which is still in beta.74 People can buy digital kyat using their local currency, foreign currency, or Tether, through a network of authorized agents on the app. By January 2023, there were over 20,000 users with 7 billion DMMK issued, which at their current rate of roughly 2,700 to the $1 is roughly $2.4 million.
According to the MOPFI, as of April 2023 there was DMMK 15 billion ($5.3 million) in circulation. 75 There are authorized agents in Thailand, Singapore, South Korea, Australia, the UK, and the US, as well as Myanmar.76
But as a detailed Frontier Myanmar report noted, it remains more of a vehicle to donate than an actual traded currency.77 It has real vulnerabilities because it requires agents, and there is a tedious process of moving funds to it from the formal banking system in Myanmar and keeping ledgers. And it remains vulnerable to internet shutdowns that are commonplace in large swaths of the country. Users have lamented that it is too slow and cumbersome to be used in daily business transactions.78
As the NUG Deputy Minister for Planning, Finance and Investment, Min Zayar Oo, explained, NUGPay “was implemented as the first step in making the financial mechanism of the revolution work. We have plans to go national in the future.”79
The NUG acknowledges that it’s not really using NUGPay for running day-to-day government operations, but that it’s “becoming an important funding supply line for private donors directly to our various recipients such as PDF forces, IDP camps, and humanitarian purpose donations.”80
The next step is the establishment of a bank. The Spring Development Bank will accept fixed deposits from wire transfers and crypto deposits. The blockchain-enabled online bank will use a newly minted digital coin.81
Spring Development Bank is finalizing its detailed business and operation plan, while the NUG government is preparing its licensing, with hopes of a May or June launch. According to a MOPFI official,
The bank system will be run on the blockchain/web3. The bank will use self-issued stablecoins (i.e. USD, SGD, THB, MMK, initially) to back the transactions on the blockchain technically. However, these crypto/coins will be made public. Account holders will only see MMK, USD, SGD, THB in their accounts. Note: Personal correspondence, MOPFI official, 10 April 2023.
But one of the key selling points of the Spring Development Bank is the range of financial services that it will offer its customers, including foreign exchange, remittances, fixed deposit, gold savings plans, and online payments via Visa and Mastercard. It will also have options within the app to purchase NUG products, including land, apartments, and bonds. The bank will allow the NUG to revive its e-lottery, providing another source of income. Note: Personal correspondence, MOPFI official, 10 April 2023.
What is so fascinating is that the bank’s assets will be backed by the $1.1 billion in funds that the U.S. Government froze from the Myanmar Central Bank.
The SAC Takes Notice
For all the creativity and technological prowess that the NUG has displayed in raising funds to support the Spring Revolution over the past two years, there are limits. And increasingly the regime knows that this is a real vulnerability that it needs to exploit.
As poorly as the SAC has managed the economy, it’s now growing at between 2 to 3 percent according to the World Bank and has between $2 to $3 billion in defense expenditures annually, including its off-budget funding. The SAC has every logical incentive to draw the war out, terrorize the population into submission, engage in a scorched earth campaign, and increase their use of long-range artillery and multiple launch rocket systems and aerial assaults, knowing that the NUG has both limited revenue and logistical support, little international support, and that their alliance structure could collapse under the weight of historical mistrust.
Countering the NUG’s sources of funding has become a far more pressing concern for the SAC in the past several months. In August 2022, the junta issued a directive that ordered banks to increase their surveillance of clients – both physical and digital – and requiring additional personal information, including photographs, when opening or changing their accounts. Note: 82 In December 2022, the Minister for Home Affairs, Lieutenant-General Soe Htut, held a day-long emergency meeting of the Central Committee for Counter-Terrorism with some 50 senior leaders in attendance. These included the deputy ministers for home affairs, defense, and border affairs; senior police officers; and military intelligence officials, from the federal and state levels. The minutes from the meeting, which were leaked, identified countering NUG funding as a top priority.83
The SAC may not be able to prevent people from purchasing bonds or shares in real estate. That is simply beyond their reach and technical prowess at present. But the regime would love to make examples out of purchasers of those assets, and they can try to intercept that money as it makes its way back to Myanmar. So the SAC has focused their efforts on what they can reach out and touch.
When the NUG launched their first Spring Lottery in early 2022, they raised a lot of money very quickly, taking advantage of the lottery’s important cultural position. Importantly, they also deprived the government of their own lottery revenue, as people boycotted the official lottery.84 The first lottery alone raised 100 million kyat ($61,000).
But for the lottery to work, the NUG was dependent on the formal banking sector, which the junta quickly shut down. The Spring Lottery was quickly abandoned.
While banking has been reopened, it is heavily policed and regulated. The SAC has inserted uniformed personnel in all banks, both public and private, to monitor both domestic and international transfers. At the very top, the SAC installed a dedicated loyalist as the head of the Central Bank of Myanmar,85 Than Than Swe, who survived an April 2022 assassination attempt after the botched implementation of currency controls.86 In July 2022, the SAC dispatched six lieutenant colonels to monitor transactions fulltime at the Central Bank.87
After the December Central Committee for Counter-Terrorism meeting, the Central Bank of Myanmar announced that it would investigate any transfer of more than 100,000 kyat,88 roughly $45 at official exchange rates, and significantly less on the black market. In the first 18 months following the coup, the Central Bank froze over 18,000 accounts, according to a police brigadier-general at the meeting.89
Immediately after the coup, the junta imposed restrictions on mobile payment services in a bid to stem the flow of donations to the civil disobedience movement and resistance forces. But the mobile banking sector was simply too large and important for the overall functioning of the economy, especially with cash runs at banks. The Central Bank was forced to relent.90
Today there are seven mobile payment firms that are under much greater oversight and pressure to self-report. There are three mobile wallets run by telecom companies, including Telenor’s Wave Money, Ooredoo’s M-Pitesan, and MPT Pay, and four run by banks, including KBZPay, CB Pay, AYA Pay, and OnePay. Wave and KBZPay dominate the market.
The military has pressured all seven of these mobile banking platforms, demanding that they keep a complete record of transfers and all the personal identification, including their government identification number, name, address, and photograph, for all mobile wallet customers.91
The Ministry of Home Affairs’ December 2022 meeting singled out KBZPay and Wave, while calling on all platforms to suspend the accounts of people found to have transferred money to the NUG or their PDFs or suspected fronts.92
In 2022, the government started to make all citizens register their SIM cards. Only a SIM card that is linked to the user’s national ID card can be used for the registration of a mobile payment platform.93 The Central Bank has ordered any account that is not linked to a registered SIM card be frozen. KBZ Bank alone fields some 300 “requests” daily from the Central Bank to freeze accounts. The amount of money that can now be transferred by mobile payment platforms is restricted by the user’s “level”; each level requires additional bank vetting and more personal information.
At KBZ Bank, the Central Bank has an additional tool to surveil its customers: the online payments platform is a joint venture with Huawei, which owns and administers the mobile payment platform. Even if the Bank tries to push back against onerous reporting requirements, the regime can rely on Huawei to provide information on all account transfers.94
The military is using its control over all telecommunications providers to send messages to all 46 million active SIM cards warning them not to support the NUG or CDM.95
The regime has new tools to use to punish and deter supporters of the NUG and PDFs. Immediately following the coup, the SAC relied on incitement charges (Article 505(a) of the Penal Code), which carries up to two years in prison, to jail its opponents. On 1 August 2021, the SAC’s rubber stamp parliament amended the 2014 Counter-Terrorism Law to increase the sentence for funding a “terrorist organization” to a maximum life sentence. Beginning in March 2022, amid escalating violence, the SAC stepped up their use of Article 50(j) of the Counter-Terrorism Law to charge supporters of the opposition.
The SAC has tried to send a clear message to deter support. In March 2022, a military court sentenced a 19-year-old woman to 10 years in prison with hard labor for transferring 13,500 kyat ($7) to a local PDF under the Counter-Terrorism Law for financing terrorism.96 Other students were sentenced to prison terms for donating even less to charities to care for internally displaced people. The Central Bank shut down the accounts of NGOs and charities that it believed were fronts for the Civil Disobedience Movement (CDM) and the NUG.97 By April 2022, 200 people had been sentenced for providing financial support to the CDM, NUG, and its PDFs.98 In April 2023, a military court sentenced four people to life for supporting PDFs in Sagaing.99
Yet it’s been large donors who the SAC has really tried to punish as a warning to others, especially local businesses and businessmen in the cities, many of whom are both sympathetic and hedging their bets. Sometimes the military makes an example by arresting a major figure, like the August 2022 arrest of one of the largest Burmese gem dealers for providing funds to the NUG, the KIA, and the CNA. They seized his home, all corporate assets, and stocks of gems.100
On 1 March 2023, the SAC amended 20 chapters and 120 articles of its already draconian Counter-Terrorism Law to give itself sweeping new powers to conduct surveillance, seize assets, and target both unarmed and armed opposition.101 The surveillance provisions are also geared to monitoring the flow of digital payments, and the government can demand that internet service providers provide consumer data.102
The diaspora community remains the single largest source of funding for the NUG. While that is heartwarming, it poses real limitations. After two years, they are feeling tapped out. If a global recession occurs, their donations could dry up. They too rely on the formal banking sector to move money back home, though increasingly they are turning to traditional and informal networks, known as Hundi, the local version of Hawala. NUGPay has too many limitations at present.
Another problem with the diaspora is that the junta is trying to limit their numbers. In January 2023, the SAC suspended the processing of most passport applications.103 The reprocessing resumed on 24 February, but the government is now cross-referencing known or suspected members or supporters of the CDM to prevent them from acquiring passports or working abroad.
As the war drags on, the ability of PDFs to self-fund through local donations is going to be harder and harder. The effects of two years of economic contraction, a decline in rural exports, limited rural credit, and overall macroeconomic instability caused by ineptitude will negatively impact the ability of rural communities to sustain the NUG over a long period of time.
Some of what the regime has done to counter NUG funding is very unsophisticated. For example, now soldiers routinely look for the NUGPay app in people’s phones. That is enough to get people imprisoned or at least significantly fined. While the app is convenient, the NUG should have had an online URL so that people could quickly erase their search history.
The regime has likewise criminalized the playing of the aforementioned PDF video game that is sold on app stores, whose proceeds are donated to the PDFs.
If the NUG can get a genuine digital currency up and running with their own online bank, then they can easily return to their weekly digital lottery, which will be a stable source of funds.
But the amended counter-terrorism law has increased the SAC legal purview and ability to conduct cyber surveillance, the reporting requirements of firms, and criminal penalties. Funding is going to get much harder for the NUG as the war enters a stalemate, with neither side able to achieve a decisive victory.
Conclusion
The NUG has an array of innovative fundraising mechanisms that take advantage of their fintech savvy; it’s another way that they have distinguished themselves from the ossified military leadership, which continues to drive the economy into the ground.
Yet the Tatmadaw is aware of the NUG’s limited resources, reliance on black markets, and lack of meaningful international support. The SAC benefits from an international system that favors states. And while the Financial Action Task Force sanctions hurt the regime, they also make it harder for the NUG to move funds. The most important thing about war is logistics, and here, even a poorly run state has an advantage.
Zachary Abuza is a professor at the National War College in Washington and an adjunct at Georgetown University. The views expressed here are the author’s own and do not reflect the opinions of the National War College, US Department of Defense, Georgetown University, or Stimson. The author would like to thank a number of people within the National Unity Government for their time in answering detailed questions. Taeko Shiota assisted in some research.
