MYANMAR Law and Practice Contributed by: Kana Manabe, Thit Thit Aung, Julian Barendse and Nirmalan Amirthanesan, Myanmar Legal Mori Hamada
pulsorily to convert foreign currency-denominated amounts held by them to kyats. On 1 January 2026, the CBM issued Notification No 2/2026, requiring exporters to convert only 15% of their export earn - ings into kyats (the threshold having previously been reduced from 35% to 25% in August 2024. On 6 December 2023, the CBM also published a letter it had issued to authorised dealer banks in Myanmar, advising that it would not set the exchange rate for the online trading of foreign currencies and that banks were free to undertake foreign exchange transactions at the market rate. The CBM has also taken a number of enforcement actions in relation to these measures. On 30 June 2025, the CBM blacklisted 197 companies for failing to deposit their export earnings; 29 of these compa - nies were removed from the blacklist as of 31 Decem - ber 2025 after depositing the required export earnings in local accounts in Myanmar. Companies operating in Myanmar must remain alert to such regulatory chang - es and the implications for their business. Targeted sanctions by major Western jurisdictions (such as the USA, the EU, the UK, Canada and Aus - tralia) also remain in force in response to a state of emergency declared on 1 February 2021 under Order No 1/2021 of the Office of the President of Myanmar (Pro Tem) – according to which the legislative, execu - tive and judicial powers of the government of Myan - mar were transferred to the Commander-in-Chief (CIC) of the Defence Services. Among those subject to sanctions are senior military and government offi - cials (including the CIC) and institutions (including the SAC) and enterprises, as well as businessmen and companies affiliated with the Myanmar armed forces. As a result of those developments, Myanmar’s M&A market has remained slow throughout the past 12 months, and is expected to remain so in the near future − although Myanmar remains a market with long-term potential for investors. Some high-profile foreign investors have also chosen to exit their invest - ments in Myanmar as a result (see 1.2 Key Trends ). It has become increasingly important for all investors − whether remaining in Myanmar, seeking to exit Myan - mar, or considering new investments − to undertake
a due diligence review of their operations to ensure they are conducting their operations in Myanmar in an ethical and appropriate manner that is in accordance with applicable sanctions. 1.2 Key Trends Corporate activity by existing foreign investors in the past 12 months has continued to include exits from Myanmar. Some such exits have involved a sale to new foreign investors, however. Financing for Myanmar businesses is likely to be reli - ant on domestic Myanmar sources, including banks. The World Bank observed in its latest Myanmar Eco - nomic Monitor (published in December 2025) that Myanmar’s banking sector has shown resilience, with deposits and credit of domestic banks growing stead - ily over the 2024-25 fiscal year and liquidity concerns diminishing. Listing on the Yangon Stock Exchange (YSX) and the Pre-Listing Board (PLB), established by the Securi - ties and Exchange Commission of Myanmar (SECM) under Notification No 1/2022 (dated 1 February 2022) as a precursor to a listing on the YSX, may be viewed by Myanmar businesses as another poten - tial option to obtain financing, even though trading on the YSX remains limited. On 3 July 2023, Myan - mar Agro Exchange Public Co Ltd (MAEX) became the eighth company to list on the YSX. The listing of established companies such as MAEX will also help the YSX (which began operations in December 2015) to develop further as a stock exchange. In relation to the PLB, on 14 August 2024, Myanmar Agricultural & General Development Public Co, Ltd became the first company to list on the PLB and on 17 Decem - ber 2025, G.B.S Agricultural Services Public Co, Ltd (ASPGB) became the second. As mentioned in 1.1 M&A Market , it has become increasingly necessary for all investors to undertake enhanced due diligence in Myanmar. 1.3 Key Industries Statistics from Myanmar’s companies’ registrar, the Directorate of Investment and Company Administra - tion (DICA), show that approved foreign investment remained relatively weak in the current fiscal year (as
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