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29 Gen 2024

Myanmar: Banks allegedly hold correspondent accounts in financial institutions under military's control; incl. responses

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.

Company Responses

Standard Chartered View Response
Deutsche Bank View Response
Toronto-Dominion Bank (TD Bank) View Response
Mizuho Financial Group View Response
ANZ Bank View Response
E Sun Commercial Bank View Response
Crédit Agricole View Response
Groupe BPCE View Response
Maybank View Response
Bank of Thailand

No Response

Bank of America

No Response

Bank of China

No Response

Barclays

No Response

BIDV

No Response

BNP Paribas View Response
HSBC

No Response

Industrial & Commercial Bank of China (ICBC)

No Response

Kasikornbank

No Response

Mega International Commercial Bank Co. Ltd

No Response

Morgan Stanley

No Response

OCBC Bank

No Response

Royal Bank of Canada

No Response

Shinhan Bank

No Response

Siam Commercial Bank

No Response

State Bank of India

No Response

Sumitomo Mitsui Banking (part of Sumitomo Mitsui Financial Group)

No Response

UOB (United Overseas Bank)

No Response

Mitsubishi UFJ Financial Group

No Response

DBS Bank

No Response

DZ BANK

No Response

Société Générale

No Response

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