Hundreds of millions of dollars from two companies registered in Britain’s overseas territories have flowed to the brutal Myanmar junta since it seized power in 2021, in what legal experts believe could be a breach of UK sanctions.

Finance Uncovered can reveal that two joint venture companies incorporated in Bermuda and the Cayman Islands are transporting gas from some of Myanmar’s largest offshore projects in partnership with the junta-controlled state energy company.

These arrangements help provide the cash-strapped military with a vital source of foreign currency that could be used to import weapons used to commit atrocities.

The role of Britain’s overseas territories in the world of international business and finance has long been a major source of controversy, especially as they officially fall within the remit of the UK Foreign Office.

Yadanar Maung, spokesperson for activist group Justice for Myanmar, which filed legal complaints urging action against the companies last year, said: “It’s deeply concerning that Myanmar junta-linked companies have been allowed to operate in UK overseas territories.

“These companies are bankrolling a junta that is slaughtering children and bombing schools and hospitals with impunity. Authorities need to act now to enforce sanctions and end this dirty business.”

Labour peer Margret Hodge said it was an “outrage” that the Bermuda and the Cayman Islands had seemingly failed to act after being warned that companies registered in their islands may have been evading sanctions.

“This is yet another example of how the secrecy in our overseas territories could be abused by bad actors for evil purposes,” she said.

Conservative MP Andrew Mitchell said UK overseas territories had for too long “twisted and turned like a fish on the line” to avoid introducing reforms that would make their financial systems more transparent.

A Foreign Office spokesperson said Britain’s Overseas Territories are committed to “robust sanctions enforcement". The spokesperson added that the UK government was "supporting the Overseas Territories to investigate and act on any allegations of possible sanction breaches".

Limited disclosure

Two of the companies in the spotlight are pipeline operators that transport Myanmar’s gas to the Thai border. These companies are jointly owned by the junta-controlled Myanma Oil & Gas Enterprise (MOGE) and Thailand’s state energy company, PTT.

Both were set up many years before the 2021 military coup, but have continued to operate since then.

Multinationals often establish companies and joint ventures in jurisdictions like Bermuda and the Caymans because of the ease of doing business, low administration costs and for tax reasons.

Pinpointing precisely how much the junta has made from the companies since the coup is difficult because of limited financial disclosure in Bermuda and the Cayman Islands.

But analysis of leaked financial statements for the two joint operations and figures from PTT’s annual reports indicate they generated hundreds of millions of dollars in revenues.

Activist group Justice for Myanmar filed legal complaints to the governors of Bermuda and the Caymans in April 2024 urging action against alleged breaches of UK sanctions against Myanmar's junta.

Representatives for the two governors said the complaints had been passed on to the government in the Caymans and to unspecified “competent authorities” in Bermuda. But both offices declined to say if any investigations had been launched.

PTT did not respond to repeated requests for comment, including direct emails to its chief executive. MOGE did not respond either.

‘A quagmire of confusion’

As violence spread across Myanmar in the wake of the military coup, the UK was among a number of western governments that targeted the junta for carrying out widespread atrocities against civilians.

In June 2021, the UK sanctioned the State Administration Council (SAC) – used by the generals to control the government and its state-owned enterprises – in a bid to starve the junta of funds.

Sanctions experts, including the UN’s special rapporteur for Myanmar, argued that because the SAC owned, controlled and profited from MOGE, the UK’s restrictions also barred doing business with the state energy company.

But unlike the EU, the UK never directly sanctioned MOGE itself. Legal experts said this created a “quagmire of confusion” around whether the sanctions applied, especially in overseas territories like Bermuda and the Caymans.

“This case is a prime example of us not really knowing what control means to the UK government,” said Felicity Gerry KC, a lawyer with Libertas chambers.

“There appears to be evidence of control that obliges the UK government to investigate and react. The UK can’t just issue sanctions and wait for something to happen — they should have a follow up system of investigating whether sanctions are being breached.”

The situation was complicated further when the junta dissolved the SAC on July 31 and replaced it with a new body, the State Security and Peace Commission (SSPC). Though the SSPC fulfills the same functions and is run by the same people, it’s not clear if the SAC sanctions apply.

Justice For Myanmar said the move by the generals has created a “dangerous loophole” in the international sanctions regime at a time when the junta was intensifying its “campaign of terror” inside Myanmar. They urged western governments to take swift action against the SSPC.

“Sanctions must be enforced to the full extent of the law and the UK should urgently close loopholes by sanctioning SSPC,” said Yadanar Maung.

Despite the confusion, Gerry said the PTT and MOGE joint ventures in Bermuda and the Caymans “still warrant investigation” for the millions of dollars in revenues they had earned for the junta since the 2021 coup.

Finance Uncovered asked the UK Foreign Office if the UK's sanctions against the SAC applied to MOGE, or if there are any plans to sanction the SSPC. A FCDO spokesperson did not answer those questions directly. Instead, the spokesperson emphasised the UK had sanctioned 25 individuals and 39 entities since the 2021 coup, “targeting the Myanmar military regime’s access to finance, arms and equipment”.

Vital revenue

Gas extracted from the Andaman Sea has long been a significant source of government revenue for Myanmar, which remains one of the poorest countries in the world after decades of rule by successive military regimes.

The two pipelines jointly owned by PTT and MOGE transport much of this gas to be sold in Thailand. Bermuda-registered Moattama Gas Transportation Company Limited (MGTC) connects Myanmar’s largest gas field, Yadana, to the border, while the Caymans-based Andaman Transportation Limited (ATL) services the sizeable Zawtika field.

Analysis of leaked financial statements by Finance Uncovered and Justice For Myanmar show the pipeline companies together paid out more than $570 million in dividends and income taxes to Myanmar’s short-lived civilian-led government between 2018 and early 2020.

In the years since the February 2021 military coup, gas production has fallen after international oil companies pulled out of Myanmar. The junta’s earnings from the pipeline companies have likely suffered as a result.

Under international pressure as civilian deaths mounted in Myanmar, MGTC – which at the time had France’s TotalEnergies as its biggest shareholder – suspended dividend payments to its shareholders, including MOGE. Following TotalEnergies withdrawal from Myanmar in 2022, it is unclear if the suspension is still active.

Despite falling production, MOGE remains the top source of foreign currency revenue for the cash-strapped junta as it struggles to finance its military operations in the face of a plunge in the value of Myanmar’s currency and a raft of international sanctions.

Analysis of figures in PTT’s annual reports show MGTC and ATL generated more than $754 million in pipeline fee revenues for PTT and MOGE between 2021 and 2024. This suggests MOGE’s share, as a minority owner, may have been just under $239 million.

While it’s not possible to determine how much corporate income tax the companies paid the junta in those years, an analysis by FU and Justice For Myanmar indicates it too would have run into the hundreds of millions of dollars.

* Main photo: Thabeikkyin Township in Mandalay region after a Myanmar military bombardment in April 2025 (AFP via Getty Images)

* Editing by Nick Mathiason and Ted Jeory