--- title: "Myanmar gambling licensing, cost and supervision | advennt.io" canonical: https://advennt.io/jurisdictions/myanmar/ source_html: /jurisdictions/mm/index.html description: "Myanmar gambling regulation by game: 1 open · 17 closed · 2 uncertain." generated_at: 2026-10-27T06:55:39Z content_sha256: e5ca61d3992dbb156e377791f97be5faec04ed825044a48ed8dacf435a85dfdd generator: "fe-fleet/md-twin@1.0" --- # Myanmar gambling licensing, cost and supervision | advennt.io [Jurisdictions](/jurisdictions/) › Myanmar # Myanmar National jurisdiction Do not enter — closed prohibition jurisdiction, FATF-blacklisted, sanctions-saturated, no lawful pathway. [1 open · 17 closed · 2 uncertain → 20 classes](#products) Regulator: Ministry of Hotels and Tourism / Myanmar Investment Commission (No a… · Collected 25 Oct 2026 · Published 25 Oct 2026 · Changed 25 Oct 2026 [PDF](report.pdf) [Sign in for PDF](https://advennt.io/auth/) [Compare](/compare/?j=myanmar) ## Can we offer our product? Every product class, in fixed taxonomy order. The band is what you can do; where the recorded legal status says something the band does not, it is shown beside the product. ### Player products - CasinoProhibited · Models agreeXClosed - PokerProhibited · Models agreeXClosed - BingoProhibited · Models agreeXClosed - LotteryState monopoly (sole exception to a general prohibition) · Models agreeXClosed - Sports bettingProhibited · Models agreeXClosed - Other event bettingProhibited · Models agreeXClosed - Horse and greyhound racing bettingProhibited · Models agreeXClosed - Esports bettingProhibited · Models agreeXClosed - Exchange bettingProhibited · Models agreeXClosed - Pool bettingProhibited · Models agreeXClosed - Virtual event bettingProhibited · Models agreeXClosed - Fantasy sportsProhibited · Models agreeXClosed - Skill gamesProhibited · Models agreeXClosed - Prediction marketsGrey zone · Models agree?Uncertain - SweepstakesGrey zone · Models agree?Uncertain - Free playOutside the regulatory perimeter · Models agreeOOpen ### Supply roles - Software / B2BProhibited · Models agreeXClosed - Affiliate marketingProhibited · Models agreeXClosed - Payments for gamblingProhibitedXClosed ### Settlement rail - Crypto gamblingProhibitedXClosed Class-level certainty is graded for 18 of 20 classes. ## Board briefing Myanmar is a closed, FATF-blacklisted, sanctions-saturated jurisdiction with no lawful gambling entry pathway. #### What has changed - FATF reaffirmed Myanmar's blacklist status at the 13 February 2026 Plenary and will consider countermeasures by June 2026; OFAC escalated scam-network designations through 2025 (KNA TCO May 2025, nine Shwe Kokko targets September 2025, DKBA November 2025). #### What to do now - Maintain zero-tolerance for any Myanmar nexus. Screen all flows against OFAC/UK/EU/UN lists. Do not engage with any SAC-issued licence. Treat scam-compound entities as sanctions exposure, not AML risk. #### What to watch - FATF June 2026 Plenary (possible escalation to countermeasures); further OFAC designations expanding the prohibited counterparty universe; any post-junta political transition. ## 11 answers, each dated and graded The weather grades favourability for an operator, not legality: legality is the product table above. The left rule is our confidence: solid confirmed, dashed probable, dotted uncertain. 01 · What kind of market is this? ### Overview Unfavourable Myanmar's gambling-adjacent landscape this period is dominated not by licensed-market activity but by cross-border scam-gambling enforcement. The 2019 Gambling Law's prohibition on citizen gambling, with its narrow foreigner-only casino carve-out, remains the lawful perimeter, unchanged this period.… Full analysis · 127 words Myanmar's gambling-adjacent landscape this period is dominated not by licensed-market activity but by cross-border scam-gambling enforcement. The 2019 Gambling Law's prohibition on citizen gambling, with its narrow foreigner-only casino carve-out, remains the lawful perimeter, unchanged this period. Against that stable backdrop, two new statutes, the Anti-Online Scam Law 2026 and the Anti-Money Laundering Law 2026, have reshaped the criminal and financial-crime environment surrounding unlicensed online scam and gambling compounds concentrated in Myanmar's border regions. China's courts have continued extraterritorial capital prosecutions of Kokang-region syndicate leadership, while Myanmar's own military has conducted raids that reporting suggests are displacing rather than eliminating the underlying operations. The jurisdiction-family disposition is sui generis, reflecting a prohibition regime overlaid with an acute cross-border criminal-enforcement problem rather than a conventional regulated gambling market. - FATF blacklist — counter-measures posture - Post-coup regulatory collapse - Active OFAC/UK/EU/UN sanctions on Myanmar-linked entities - Scam-compound TCO/FTO-adjacent risk - No licensing pathway Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/myanmar/overview/) 02 · Can we get a licence? ### Licensing and regulation Unfavourable The Myanmar Gambling Act 1986 is the primary prohibition statute. Limited casino licences for foreign nationals historically existed under the Ministry of Hotels and Tourism, but are functionally non-operational post-coup. The SAC Cybersecurity Law (2021, amended 2025) nominally targets online gambl… Full analysis · 65 words The Myanmar Gambling Act 1986 is the primary prohibition statute. Limited casino licences for foreign nationals historically existed under the Ministry of Hotels and Tourism, but are functionally non-operational post-coup. The SAC Cybersecurity Law (2021, amended 2025) nominally targets online gambling and VPN use. No licensing pathway exists that a reputable operator could utilise; any licence purportedly issued by SAC-controlled entities carries severe sanctions exposure. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/myanmar/licensing/) 03 · How hard is entry, really? ### Market entry in practice Unfavourable Market entry is not possible. Criminal prohibition, FATF blacklist, collapsed regulatory infrastructure, active sanctions and scam-compound TCO-adjacent risks make Myanmar one of the highest-risk jurisdictions globally. No engagement is possible without severe reputational, AML and legal consequence… Full analysis · 43 words Market entry is not possible. Criminal prohibition, FATF blacklist, collapsed regulatory infrastructure, active sanctions and scam-compound TCO-adjacent risks make Myanmar one of the highest-risk jurisdictions globally. No engagement is possible without severe reputational, AML and legal consequences in home jurisdictions (MGA, UKGC, MAS). Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/myanmar/market-entry/) 04 · What do the licences cost? ### Licence fees Unfavourable Not applicable — no functional licensing market exists. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/myanmar/fees/) 05 · What is the tax take? ### Tax Unfavourable Not applicable — no functional legal gambling tax model. Pre-coup licence revenue has collapsed. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/myanmar/taxes/) 06 · Can we move player money? ### Payments and banking Unfavourable CBM payment infrastructure is severely degraded. KBZPay and AYA Pay remain nominally operational but face FATF counter-measure scrutiny, heavily restricted SWIFT connectivity, and correspondent banking restrictions driven by US/UK sanctions. Crypto (USDT) is widely used in the black economy. No reli… Full analysis · 63 words CBM payment infrastructure is severely degraded. KBZPay and AYA Pay remain nominally operational but face FATF counter-measure scrutiny, heavily restricted SWIFT connectivity, and correspondent banking restrictions driven by US/UK sanctions. Crypto (USDT) is widely used in the black economy. No reliable or safe gambling payment rail exists for legitimate operators; AML risk is severe with mandatory enhanced due diligence on all Myanmar-origin transactions. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/myanmar/payments/) 07 · Can we advertise? ### Marketing Unfavourable All gambling marketing is prohibited. The SAC Cybersecurity Law targets online gambling promotion, and SAC officials have issued anti-gambling statements. No lawful marketing channel exists for any gambling product targeting Myanmar users. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/myanmar/marketing/) 08 · What must the platform meet? ### Technical compliance Unfavourable The Cybersecurity Law No. 1/2025 imposes a licensing threshold on digital platforms with over 100,000 users, and separately on VPN providers, effective from 30 July 2025 under SAC Notification 113/2025. This is a general cross-cutting digital-platform control rather than a gambling-specific technica… Full analysis · 110 words The Cybersecurity Law No. 1/2025 imposes a licensing threshold on digital platforms with over 100,000 users, and separately on VPN providers, effective from 30 July 2025 under SAC Notification 113/2025. This is a general cross-cutting digital-platform control rather than a gambling-specific technical standard; no gambling-specific certification pathway exists in Myanmar for either land-based or online products. The enabling statute carries mixed durability while the bringing-into-force notification itself is fragile, being a State Administration Council executive order. For an operator, the practical implication is that any online-facing infrastructure of scale is drawn into a general platform-licensing regime with no tailored gambling carve-out, compounding rather than clarifying compliance exposure for digital products. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/myanmar/technical/) 09 · Can we ship through apps and platforms? ### Distribution and platforms Unfavourable No Myanmar platform-rule change was located. The material development is a foreign-authority infrastructure action: Thai authorities raided a border village and severed a 48-core fibre-optic cable that had been run illegally 350 metres across the border into Thailand, which was feeding a reported si… Full analysis · 128 words No Myanmar platform-rule change was located. The material development is a foreign-authority infrastructure action: Thai authorities raided a border village and severed a 48-core fibre-optic cable that had been run illegally 350 metres across the border into Thailand, which was feeding a reported six terabytes of data per day to an illegal casino and scam compound located on the Myanmar side of the Three Pagodas Pass. The raid disrupted the connectivity sustaining that compound's operation, but it is a Thai telecoms-regulator and police action targeting cross-border infrastructure, not a change to any Myanmar-issued distribution, platform, app-store, or advertising rule. Myanmar's own distribution and platform baseline for gambling is therefore unaffected and unchanged by this episode, even though the episode illustrates the practical infrastructure dependencies of unlicensed Myanmar-side operations. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/myanmar/distribution/) 10 · How hard does the regulator enforce? ### Enforcement Unfavourable Enforcement this period centres on escalating cross-border and domestic action against scam-gambling compounds. On 13 October 2026, courts in Quanzhou and Nan'an, China, sentenced three leaders of a Wei-clan Kokang syndicate, Wei Huairen, Chen Dawei and Liao Jingfang, to death for operating a networ… Full analysis · 191 words Enforcement this period centres on escalating cross-border and domestic action against scam-gambling compounds. On 13 October 2026, courts in Quanzhou and Nan'an, China, sentenced three leaders of a Wei-clan Kokang syndicate, Wei Huairen, Chen Dawei and Liao Jingfang, to death for operating a network of scam centres and illegal casinos in Myanmar's Kokang region, the third round of Chinese capital prosecutions against Kokang-clan leadership in 2026. Separately, a Malaysian national was reported, as of 19 October 2026, believed trapped at a Thai-border scam centre, with the syndicate reportedly demanding a release payment, illustrating the coercion risk inherent to these compounds and the basis on which Myanmar's Anti-Online Scam Law 2026 would attach liability to those who detain or coerce victims. Independent reporting further indicates that operations displaced by earlier crackdowns at sites such as KK Park and Shwe Kokko have relocated into Myawaddy town on the Thai border, meaning the current enforcement record demonstrates sustained pressure and relocation rather than confirmed elimination of the underlying scam-gambling economy. The governing instruments are the Anti-Online Scam Law 2026, carrying life imprisonment and, where death results, capital punishment, and the pre-existing Gambling Law prohibition. Confirmed AI-generated 22 enforcement events [Read full analysis & tables →](/jurisdictions/myanmar/enforcement/) 11 · What is coming? ### Outlook Unfavourable No liberalisation is conceivable without regime change. The junta has neither the institutional capacity nor political legitimacy to build a credible gambling regulatory framework. The FATF blacklist will persist until structural AML reform or regime change, neither foreseeable in a 5-year horizon. … Full analysis · 56 words No liberalisation is conceivable without regime change. The junta has neither the institutional capacity nor political legitimacy to build a credible gambling regulatory framework. The FATF blacklist will persist until structural AML reform or regime change, neither foreseeable in a 5-year horizon. FATF signalled it will consider countermeasures if no progress is made by June 2026. Confirmed AI-generated [Read full analysis & tables →](/jurisdictions/myanmar/outlook/) Evidential record & source register 2 enforcement · 25 red flags · 12 sources · Expand full record ## Enforcement record What the regulator has actually done, newest first. 2 recorded events. - 8 Sep 2025US OFAC · Nine Shwe Kokko targetsConfirmedSource 4 · T2 - 5 May 2025US OFAC · Karen National Army (KNA)ConfirmedSource 5 · T2 ## What gets operators fined 25 red flags (10 high, 5 medium) and 2 controls that address them. - highKBZPay/AYA Pay rails for gamblingCorrespondent banking restrictions; SWIFT isolation.Source 3 · T2 - highReliance on collapsed domestic enforcementNo predictable legal protection; episodic SAC action.Source 1 · T1 - highAny gambling advertising to MM usersAll marketing banned; platform-level prohibition.Source 1 · T1 - highFunnull-type IP/hosting suppliersOFAC sanctioned bulk IP supplier to scam sites.Source 4 · T2 - highHundi/informal value transferFATF action plan flags unsupervised hundi operators.Source 2 · T1 - highInterpol Red Notice individualsShe Zhijiang Red Notice precedent.Source 4 · T2 - highCard scheme MCC processingVisa/Mastercard effectively withdrawn from MM.Source 3 · T2 - highJune 2026 FATF countermeasure escalationPotential transaction prohibition.Source 2 · T1 - highEU/UK autonomous sanctions on Saw Chit ThuUK 2023 / EU 2024 designations.Source 5 · T2 - highAny local entity formationNo safe corporate vehicle; sanctions screening failure risk.Source 5 · T2 - mediumMedia/OCCRP coverage of MM nexusSevere reputational cascade.Source 7 · T2 - mediumVPN-routed accessVPN use technically criminal under Cybersecurity Law.Source 1 · T1 - mediumSAC 2026 AML law reliancePaper law; no enforcement capacity; does not reduce blacklist risk.Source 8 · T2 - mediumAffiliate traffic from MMProhibited; affiliate carries sanctions/AML exposure.Source 1 · T1 - mediumApp store distribution to MMApple/Google block gambling apps for MM.Source 1 · T1 - criticalAny Myanmar-origin payment flowFATF blacklist counter-measure posture; mandatory enhanced due diligence.Source 2 · T1 - criticalDealing with KNA-controlled Shwe Kokko entitiesOFAC TCO designation; asset freeze and US financial-system exclusion.Source 5 · T2 - criticalDKBA-linked counterpartiesNovember 2025 OFAC designation.Source 6 · T2 - criticalSAC-issued gambling licence offeredNo credible regulator; licence carries sanctions exposure.Source 1 · T1 - criticalUSDT settlement with Myanmar partiesBlack-economy crypto rails feed sanctioned networks.Source 4 · T2 - criticalCompound labour nexusForced labour / human trafficking liability.Source 9 · T2 - criticalHome-regulator exposure (UKGC/MGA/MAS)Zero-tolerance expectation for Myanmar-origin flows.Source 3 · T2 - criticalYatai/She Zhijiang-linked entitiesOFAC E.O. 13818 designations for human rights abuse.Source 4 · T2 - criticalCasino-as-launderette patternCompounds use casino functions to launder scam proceeds.Source 4 · T2 - criticalJunta-linked SOE engagementSAC entities under targeted OFAC sanctions (E.O. 14014).Source 5 · T2 ### Controls - 001Myanmar nexus screeningScreen all counterparties and payment flows for any Myanmar nexus and against OFAC/UK/EU/UN consolidated lists before processing.Source 2 · T1Source 5 · T2 - 002Zero-tolerance MM blockGeo-block and payment-block all Myanmar-origin player activity; document home-regulator zero-tolerance rationale.Source 3 · T2 ## Worked scenarios 5 entry scenarios, each with the move we would make. #### An operator is offered a 'casino licence' by a SAC-affiliated intermediary. No credible regulator exists post-coup; any SAC-issued authorisation carries sanctions exposure given E.O. 14014 designations on SAC entities. Do this: Decline. Treat the offer as an indicator of sanctions-evasion risk. Source 1 · T1 Source 5 · T2 #### A B2B supplier receives a deal request routed through a Shwe Kokko address. Shwe Kokko entities operate under KNA protection and several are OFAC-designated; engagement risks sanctions violation and trafficking nexus. Do this: Reject and file internal SAR-equivalent; preserve records. Source 4 · T2 #### A PSP detects USDT settlement requests with Myanmar counterparties. Crypto is a primary black-economy rail feeding sanctioned scam networks; FATF counter-measure EDD applies. Do this: Block, apply enhanced due diligence, escalate to compliance. Source 4 · T2 Source 2 · T1 #### An affiliate proposes driving Myanmar traffic to a licensed brand. All gambling marketing to MM is prohibited and platform-blocked; the affiliate relationship imports prohibited-market and AML exposure. Do this: Refuse; geo-exclude Myanmar at the affiliate contract level. Source 1 · T1 #### A licensed operator's UKGC/MGA reviewer queries any MM exposure. Home regulators expect zero tolerance for Myanmar-origin flows given the FATF blacklist; any nexus risks home-licence consequences. Do this: Demonstrate complete MM exclusion controls and screening evidence. Source 3 · T2 ## What we looked for and could not find Confirmed absence is a finding of its own. These are the questions we searched and could not answer from a citable source, with the searches we ran. Never behind the paywall. Baseline.fees / baseline.taxes. no functional licensing market exists post-coup, so no fee or tax schedule can be sourced. - searched: Myanmar gambling licence fee schedule - searched: Myanmar casino tax rate Ministry of Hotels Tourism - searched: Myanmar gaming duty GGR rate - checked: fatf-gafi.org Baseline.competitive landscape. no licensed operator register exists; unlicensed market share unquantifiable from credible T1/T2 sources. - searched: Myanmar licensed gambling operators count - searched: Myanmar online gambling market share estimate - searched: Myanmar regulator gambling statistics - checked: bnionline.net ## Source register Every source on a four-step tier scale. A claim is never shown at a stronger tier than the source it cites. 12 sources · 2 tier 1 · 8 tier 2 · 1 tier 3 · 1 tier 4 No. Source Tier Verification 1 MM-GAMBLING-ACT-1986 T1 of 4 Source 1 · Open in drawer → 2 FATF-CALL-FOR-ACTION-2026-02 T1 of 4 Source 2 · Open in drawer → 3 MAS-FATF-STMT-2026-02 T2 of 4 Source 3 · Open in drawer → 4 OFAC-SB0237-2025-09 T2 of 4 Source 4 · Open in drawer → 5 OFAC-SB0129-2025-05 T2 of 4 Source 5 · Open in drawer → 6 OFAC-SB0312-2025-11 T2 of 4 Source 6 · Open in drawer → 7 DIPLOMAT-SCAM-2025-09 T2 of 4 Source 7 · Open in drawer → 8 BNI-FATF-BLACKLIST T2 of 4 Source 8 · Open in drawer → 9 ALJAZEERA-SCAM-2025-09 T2 of 4 Source 9 · Open in drawer → 10 MM-LAW-GAMBLING-2019 T2 of 4 Source 10 · Open in drawer → 11 STUDYAML-PLENARY-2026-02 T3 of 4 Source 11 · Open in drawer → 12 REUTERS-USNEWS-SCAM-2025-09 T4 of 4 Source 12 · Open in drawer → ### Claims with their own provenance Myanmar remains on the FATF call-for-action blacklist as of the 13 February 2026 Plenary, with FATF to consider countermeasures absent progress by June 2026. MM-CP-001 · T1 of 4 · published 13 Feb 2026 · Confirmed Pipeline-sourced · From Advennt research · Rule detail not yet extracted Source 2 · T1 OFAC designated the Karen National Army as a transnational criminal organisation in May 2025 and sanctioned nine Shwe Kokko scam targets in September 2025. MM-CP-002 · T2 of 4 (asserted T1, shown at its source's tier) · published 8 Sep 2025 · Confirmed Pipeline-sourced · From Advennt research · Rule detail not yet extracted Source 4 · T2