Missed Opportunities

The report argues that sanctions by the US, EU, and UK have been 'scattershot' and lack strategic coordination, failing to target the junta's primary revenue sources and arms networks. While legal authorizations are broad, the authors find that 67% of sanctions are unilateral, and critical entities like the Myanma Oil and Gas Enterprise (MOGE) remain largely unsanctioned by the US and UK. The brief recommends a harmonized strategy to cut off foreign currency, disrupt aviation fuel supplies, and comprehensively sanction all junta leadership members.

• The US, EU, and UK have failed to coordinate their sanctions efforts, with a majority of actions being unilateral. Only 13% of the 165 sanctioned targets are sanctioned by all three jurisdictions, while 67% have been implemented unilaterally.
• Despite having broad legal authorizations that allow for the targeting of almost any entity supporting the junta, the variations in implementation are attributed to differing strategic decisions, a lack of overall strategy, or poor intelligence sharing.
• The US and UK have missed a high-impact opportunity by refusing to sanction the Myanma Oil and Gas Enterprise (MOGE), which is the junta's largest source of foreign currency. Only the EU has sanctioned MOGE, an action that had a demonstrated effect by causing the Bank of China to stop processing certain payments to the entity.
• There are significant gaps in targeting the junta's financial infrastructure and military capabilities, specifically regarding the Myanmar Foreign Trade Bank (MFTB), the Myanmar Investment and Commercial Bank (MICB), and the aviation fuel supply chain.
• Sanctions on the State Administration Council (SAC) lack clarity, which allows the junta to continue earning revenues from state-owned enterprises (SOEs) and maintain international relationships.
• The US, EU, and UK have not systematically targeted the junta's civilian leadership or cabinet ministers. For example, 39% of the military junta's cabinet-level ministers remain unsanctioned.
• The report identifies a failure to use a network-based approach to target arms procurement, noting discrepancies where the UK sanctions entities that the US and EU do not, despite claims of coordination.
• The effectiveness of sanctions is further undermined by the issuance of waivers for non-humanitarian reasons, such as a US waiver allowing a Japanese bank to process transactions for a sanctioned military-owned conglomerate.

APA

Global Witness (2023). Missed Opportunities. https://globalwitness.org/documents/142/Sanctions_Policy_Brief_GW_ERI_Feb_1_vF.pdf

Chicago

Global Witness. Missed Opportunities. 2023. https://globalwitness.org/documents/142/Sanctions_Policy_Brief_GW_ERI_Feb_1_vF.pdf.

Wikipedia

{{cite report |author=Global Witness |title=Missed Opportunities |date=February 2023 |url=https://globalwitness.org/documents/142/Sanctions_Policy_Brief_GW_ERI_Feb_1_vF.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{globalwitness2023missed, author = {{Global Witness}}, title = {{Missed Opportunities}}, institution = {Global Witness}, year = {2023}, month = feb, url = {https://globalwitness.org/documents/142/Sanctions_Policy_Brief_GW_ERI_Feb_1_vF.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }