In October 2023, civil society groups sent a letter to banks and financial institutions allegedly holding correspondent accounts in one or more Myanmar financial institutions now under the control of the military junta, which has engaged in widespread human rights abuses since the attempted coup in 2021. The letter notes that financial services and investments can be a form of complicity in gross human rights abuses that occur in crisis areas and asks banks several questions about their due diligence processes:

• What steps has your institution taken to prevent sanctioned members of the junta and sanctioned entities under the de facto control of the junta from accessing accounts held at your institution?
• What is your institution’s policy with respect to accounts for any unsanctioned individuals or entities known or suspected by your institution to have assisted the junta in sanctions evasion?
• Has your institution implemented safeguards to avoid participating in or facilitating the junta’s efforts to circumvent sanctions? Please note that common junta sanctions evasion tactics include channeling funds through non-sanctioned individuals and entities and converting funds to different currencies.
• What measures has your institution taken to implement the United States’ August 2023 determination that allows for sanctions to be imposed on any foreign individual or entity determined to operate in the jet fuel sector of the Burmese economy?
• How has your institution integrated the United States’ January 2022 business advisory on Burma into its due diligence procedures?
• What measures are being implemented to ensure that humanitarian aid and access is being received in Myanmar and that civilians are able to access banking services and to safeguard against de-risking?

The Business & Human Rights Resource Centre invited the following institutions to respond: Australia and New Zealand (ANZ) Bank, Bank of America, Bank of China, Bank of Thailand, Barclays, Bank for Investment and Development of Vietnam (BIDV), Banque Populaire Caisse d'Epargne (BPCE) Group, Credit Agricole, Development Bank of Singapore (DBS), Deutsche Zentral-Genossenschaftsbank (DZ) Bank, E Sun Commercial Bank, Hongkong and Shanghai Banking Corporation (HSBC), Industrial & Commercial Bank of China, Kasikornbank, Krungthai Bank, Maybank, Mega International, Commercial Bank Co., Ltd., Mitsubishi UFJ Financial Group (MUFG), Mizuho Financial Group/Mizuho Bank Ltd., Morgan Stanley, Oversea-Chinese Banking Corp. (OCBC), Royal Bank Of Canada, Shinhan Bank, Siam Commercial Bank, Société Générale, State Bank of India, Sumitomo Mitsui Banking Corporation, Union Bank of Switzerland (UBS), and United Overseas Bank.

ANZ, BPCE, Credit Agricole, E Sun Commercial, Maybank, Mizuho Financial Group, and UBS (including Credit Suisse) responded to the Resource Centre and BNP Paribas, Deutsche Bank, Standard Chartered Bank, and Toronto-Dominion Bank responded directly to the No Business with Genocide coalition (see all responses below). The other institutions did not send responses.