Banking in Burma: New Frontiers, or a Barren Wasteland?
Sean Turnell
A country’s financial system
provides its means of exchange and is the mechanism through which its resources
are mobilised and allocated. The financial system is the arena in which economic
risk can be managed, government debt can be financed, foreign capital can be
accessed and managed, and it is the vehicle through which monetary policy can
be implemented. According to Larry Summers, the former Secretary of the US
Treasury, a country’s financial system provides the ‘wheels’ for its
development.
Burma has not had a properly functioning financial system for four
decades. The coup that installed the military dictatorship of General Ne Win in
1962 ushered in a program that, under the label of ‘the Burmese way to
socialism’, installed some of the worst excesses of Stalinist economics. In
1963 the financial system was nationalised, and in 1969 all of the nationalised
banks were merged into a collectivised institution that laboured under the name
of ‘The Peoples’ Bank of the Union of Burma’. It shortened its name in 1972 to
the Union of Burma Bank. In 1975 the monolith was broken up five ways: 1) the
Union Bank of Burma was established as the central bank; 2) the Myanma Foreign
Trade Bank was created as a monopoly to deal with all foreign exchange
transactions; 3) the Myanma Economic Bank was formed as the primary
deposit-taking and general banking institution; 4) the Myanma Agricultural Bank
was formed to service agriculture; and 5) insurance services were allocated to
a state monopoly, the Myanmar Insurance Corporation (Pierce 1997, p.441).
The coming to power in 1988 of
the State Law and Order Restoration Council (SLORC), supposedly brought with it
a change in the direction of Burma’s
economic trajectory in which the free market was to be encouraged. To this end,
SLORC passed a series of laws that were ostensibly about ‘liberalising’ the
financial sector. These laws, the most important of which was the Financial
Institutions of Myanmar Law and the Central Bank of Myanmar Law (both 1990),
established the Central Bank of Myanmar (CBM) as the new central bank and gave
it powers to supervise banks and to establish a program of reform.
This program envisaged that liberalisation would proceed in three phases:
Phase 1: Allow domestic private banks and allow foreign banks to open
representative offices.
Phase 2: Allow selected domestic banks to form joint ventures with foreign
banks.
Phase 3: Allow foreign banks to begin operations in their own right.
No timetable
was established for the program. By 1991, however, the first domestic private
banks had been established and the first foreign bank representative offices
had opened.
From this
promising start financial sector reform in Burma,
like reform in every other aspect of the nation’s political economy, has made
very little headway. Though Phase 1 of the program was more or less
successfully implemented in terms of its limited goals, phases 2 and 3 have yet
to be embarked upon. Together with a great many other limitations to the
operation of foreign investors in Burma
(examined below), foreign banks remain restricted to a representative office
role only. Four joint venture proposals along the lines envisaged in the Phase
2 reforms have apparently been mooted, but only one proceeded to the point that
the Central Bank of Myanmar’s approval was sought. This approval was not given (Pierce 1997,
p.445).
The Current Structure of Burma’s
Banking Sector
In terms of
branch networks and access for the great majority of the Burmese people, Burma’s
banking sector continues to be dominated by state-owned institutions. All four
of the state-owned banks that were the successors to the monolithic People’s
Bank survive. To these have been added the Myanma Investment and Commercial
Bank (MICB) in 1989 and the Myanma Small Loans Enterprise (MSLE) in 1993. Both
the MICB and the MSLE were carved out of the Myanma Economic Bank (MEB), the
MICB to provide corporate and investment banking services and the MSLE to act as
a type of state-owned pawn shop.
The four
continuing state-owned banks more or less continue their established roles,
though the Myanma Foreign Trade Bank has lost its foreign exchange monopoly.
The MEB continues to be by far the largest banking operation in Burma in
terms of branches, with around 300 throughout the country.
In 1997, according to Pierce (1997, p.443), the MEB held over 75 percent of
total deposits for all banks, or around 7 times the deposits of all the (then)
private banks put together. As shall be examined below, this is not likely to
be the case today. Burma’s military regime has not released data on the performance of the
state-owned banks for some time, but there appears to be little doubt that
their ‘market share’ has been greatly eroded by the new private banks. This is
likely to be especially true amongst what might rather loosely be described as
the business community in Burma,
the only people with sufficient funds to be of interest to the private banks.
Even at the height of the MEB’s dominance in 1997, however, its deposit base of
70 billion Kyat would amount, at the current market value of the Kyat, to
around $US 100 million – about the size, in short, of a small regional bank in
the US.
There are
currently 20 private domestic banks operating in Burma
(full list in Appendix 1). These have grown dramatically in recent years.
Pierce (1997, p.443) reported that deposits with the private banks in March
1995 totalled 5.9 billion Kyats. As at November 2000, deposits with Burma’s banking
system as a whole totalled 450.7 billion Kyat. Burma’s
monetary authorities do not reveal the respective shares of state and private
banks but one private bank alone, the Asia Wealth Bank, claims deposits of
144.9 billion Kyat.
Most of the 20 private banks are exceedingly small institutions, however, and
apart from the Asia Wealth Bank, four others – Myanmar May Flower Bank, Yoma
Bank, Kanbawza Bank and Myawaddy Bank – appear to dominate. As shall be
revealed later in this study, the apparent dramatic growth of the private
banking sector in Burma masks a less than attractive reality.
As at
September 2001 there were 46 representative offices of foreign banks in Burma
(full list in Appendix 1). This number is subject to some volatility, and since
1991 quite a number of foreign banks have established representative offices,
only to close them again when it became apparent that the promise of banking in
Burma was not matched by the reality. Representative offices are not
permitted to engage in any banking business beyond liaison activities and the
monitoring of loans made offshore. As noted above, no foreign bank that has
established a representative office in Burma has
yet to form a joint-venture bank, or been permitted to establish banking
operations in its own right.
The
state-owned Myanmar Insurance Corporation remains the only entity that is
allowed to engage in insurance business in Burma.
Though rumours have suggested from time to time that this monopoly might be
ended, no alternatives have emerged as yet.
A Functioning Banking System
in Burma?
What appears to have been rapid growth in Burma’s
private banking sector in recent years disguises a financial system that, in
fact, is barely functioning.
The evidence
for this can be found by examining the data that Burma
supplies to the IMF – the only recent data available since the military regime
stopped publication of Burma’s national accounts in 1998.
Using this data, derived primarily from the IMF’s Monetary and Financial Statistics series (as at November 2000), the
following facts become apparent:
·
Total deposits (demand, time,
savings, foreign currency and restricted deposits) in Burma’s
banking system amounted to 450.9 billion Kyat. At the same time total currency
in circulation outside the banks totalled 365.1 billion Kyat. This represents a
cash-to-deposits ratio of 81 percent. This is an important statistic. The
cash-to-deposits ratio essentially measures the extent to which banks are
functioning in the creation of credit, that is, functioning in the way banks
are meant to. In properly functioning banking systems this ratio should be low
since in such systems ‘bank money’ (deposits that are the result of bank
created credit) should be by far the most significant component of the money
supply. In Thailand, a country with its own banking problems but one that represents a
model for what at least Burma could be economically, the cash-to-deposits ratio is 8 percent.
Thai banks, in other words, create credit at more than ten times the rate of
their Burmese equivalents.
Burma’s banks are not fulfilling the normal role of banks in
creating credit, but the country’s abnormally high cash-to-deposits ratio is
also indicative that; a) they are not trusted by the broad populace; and/or b) the returns on savings that they offer
(as noted below, far less than inflation) are not sufficient to attract
deposits. Either way, the ratio is indicative of a system that is scarcely
functioning.
Of course, to some extent the issue of Burma’s
excess of cash reflects the broader problem that the regime funds much of its
spending through the simple, but highly destructive, means of printing the Kyat
in whatever volumes it requires. From 1995 to 2000, currency circulating
outside banks in Burma increased by 306 percent. In Thailand
the relevant increase over this period (a period which included the Asian
financial crisis) was 30 percent.
·
Instead of creating credit
through lending to the public, Burma’s
banks have instead been lending to the government. Total domestic credit
outstanding in Burma in November 2000 was 791 billion Kyat. Of this, 61 percent was in
the form of claims on the central government. A further 7.5 percent was in
advances to non-financial public enterprises. The remainder then, 31.5 percent,
was all that the banking system made available to the private sector. Once
more, a reasonable interpretation of the facts of Burma’s
banking system is that it is not functioning in a way that would support the
country’s development.
·
Using what little information is provided by
some of Burma’s private banks confirms the story of a banking sector that
functions in large measure as a financing arm of the state. The Asia Wealth
Bank, which claims to be Burma’s
largest bank, reports assets as at 30 April 2001 of
around 160 billion Kyat. Though this particular bank is more active than most
in lending to the private sector, 73.4 billion Kyat (46 percent) of its assets
are in the form of government-issued treasury bonds.
·
Notwithstanding that the
cash-to-deposits ratio remains low for all of the reasons above, the actual
level of deposits with Burma’s banks has grown extraordinarily rapidly in recent years. In 1995,
for example, the total of all deposit categories in Burma’s
banks was 67.7 billion Kyat – a figure that had grown to 450.9 billion Kyat by
November 2000. This is an increase of 566 percent. Of course, some of the
increase in raw Kyat terms can be explained by inflation (Burma
does not publish reliable inflation numbers, but it is likely that the major
part of this increase is inflation induced). However, the fact that there has
been any increase in the real level of deposits at all is remarkable. With the
current inflation rate in Burma
approaching 50 percent according to the US State Department, depositors in Burma’s
banks (who receive no more than 9.5 percent interest) are actually losing
money. That there has been any growth at all in lending by Burma’s
banks (maximum lending rate: 15 percent), or that they are willing to buy
treasury bonds (yield: 9 percent) is also remarkable – since clearly these are
also certain loss-making activities.
Why growth? The laundering of the substantial funds that flow to Burma
from the trade in narcotics is at least one answer. This issue is examined
below.
Supporting statistical
analyses that suggest Burma’s banking system is dysfunctional are the host of
commentaries, news items and other immediate sources of information that leak
out of Burma and appear on various websites, in newspapers, and so on. For an
interesting first hand account of Burma’s banking system
from objective external observer, however, see the account of Professor Lynne
Doti at http://sbe.chapman.edu/asbe.nsf/pages/burma.
Professor Doti was in Burma in June 2001 as
a lecturer and specialist in banking and democracy on behalf of the US State
Department.
Regulatory Constraints
The absence of a properly
functioning banking and financial system in Burma is just one
example of a failed political economy in which questions of resource allocation
are decided by military fiat rather then through the signals of the market.
This broader institutional failure in Burma is manifested in
many ways that impact upon banking and finance, but not least in the way that
arbitrary and often contradictory regulation inhibits the development of the
sector. In the following section, some of these contradictions are examined,
highlighting in particular those that render Burma a most
unattractive destination for overseas
financial sector investment.
Prudential
Regulation
At first
glance the regulation of banks in Burma
appears rational and consistent with international norms.
The CBM applies, for example, the criteria of the Basle Capital Adequacy Accord
for banks. The Basle Accord, formulated in 1988, established the benchmark for
international best practice in prudential regulation. It prescribed that banks
maintain a minimum ratio of capital to risk-adjusted assets (8 percent), set
risk-weighting categories of various asset types (ranging from zero to 100
percent, depending on the credit risk of the borrower), and outlined limits to
credit exposures to any one borrower. To all of these the CBM adheres. Under
Article 31 of the Financial Institutions of Myanmar Law, the CBM dictates that
banks maintain a capital adequacy ratio of 10 percent (higher that the Basle
benchmark of 8 percent, but not inappropriate for a country with an undeveloped
financial system), whilst under Article 32 of the Law banks are not allowed to
lend in excess of 20 percent of their capital to any single individual or
enterprise. The CBM also applies, in a rough and ready way, the same risk
weighting categories determined under the Basle framework.
So far so
good, but on top of the Basle criteria the CBM imposes other regulations on
banks that tip the balance of its approach from standard international practice
– and into methodologies that can only be described as eccentric. These
regulations are derived from what the regime refers to as the ‘pre-reform’
period, and are to modern eyes redundant and self-defeating procedures of an
earlier age. Thus, for example, the CBM maintains minimum reserve requirements
on banks (10 percent of demand deposits and 5 percent of time deposits – 75
percent of which must be deposited with the CBM, 25 percent to be maintained in
cash), retains powers to issue ‘directives’ on lending to certain sectors of
the economy, compels banks to maintain a liquidity ratio (liquid assets against
liabilities) of 20 percent, and requires that banks set aside 25 percent of
annual net profit up to the point in which a ‘general reserve’ is established
equal to a bank’s capital. Of course, similar regulations were imposed by many
countries post-World War Two, but these were what the Basle framework was meant to
replace rather than augment.
In addition to
these remnants of obsolete prudential regulations are laws, deriving from
ancient concerns regarding usury and the domination of lending by certain
ethnic groups in Burma, that restrict lending by banks in other ways.
Uppermost of these is the Money Lenders Act (1945, but still in place) that not
only disallows compound interest, but prohibits total interest payments from
exceeding the amount of principal of a loan. As with so much else, it is
difficult to imagine a modern banking system functioning against such
fundamental prohibitions.
The CBM also
continues to cap interest rates in Burma. On
the deposit side, minimum interest rates payable on savings and time deposits
must not be less than 3 percent below the Central Bank rate, while maximum
interest rates chargeable on loans must not be more than 6 percent above the
Central Bank rate. These restrictions yield a current deposit rate of 9.5
percent, and a lending rate of 15 percent. The absurdity of these limits, and
what they must imply for the proper functioning of the banks, is readily
apparent when one reflects upon the fact that inflation in Burma has not
(truly) been below 20 percent a year for a decade.
Joint Venture Regulations
As noted
above, Burma’s much vaunted Phase 1 reforms that allow for the establishment of
foreign/Burmese joint venture banks has been a great failure. Restrictions such
as those noted above (and the foreign exchange problems noted below) are sufficient
in themselves to suggest that there is not likely to be a rush any time soon to
set up legitimate joint venture banks
in Burma. Specific regulations pertaining to joint ventures, however, have
also almost certainly played a role in the non-appearance of these
institutions.
As the current
laws stand (and those relevant to joint venture banks source authority from the
Foreign Investment Law and the Myanmar Citizens Investment Law (1994), as well
as the Financial Institutions Law, a joint venture bank must be capitalised at
a minimum of 60 million Kyat. The joint venture can only be established between
a foreign bank that has a representative office in Burma,
and a domestic private bank. The foreign bank must have at least a 35 percent
equity in the joint venture to be paid, in Kyat, at the official exchange rate. The official exchange rate presently
stands at around 6.7 Kyat to $US 1.
The domestic partner can contribute its share in domestically sourced Kyat. The
extortion is not hard to see. At the time of writing the market exchange rate is around 900 Kyat/$US 1. Even accepting that
the current exchange rate represents an overselling of the Kyat, and selecting
therefore an exchange rate of around 700 Kyat/$US 1 (a rate to which the Kyat
has settled, off and on, over the last year or so), the joint venture
requirements suggest that a foreign partner will over-pay relative to the
domestic partner at a rate of over 100 to 1. At a minimum the foreign bank must
contribute $US 3.1 million. Yet, if the minimum amount of capital to establish
a joint-venture bank is employed, the domestic partner could (theoretically?)
contribute zero - for a 75 percent
equity share!
It’s hard to
imagine that given such an outcome, and if a joint-venture in normal banking
business is really what is on offer, that Burma’s banking sector could hope to
attract foreign capital.
Exchange Controls
Burma’s
foreign exchange problems, and especially the dual exchange rate regime that
separates the official and market exchange rates, have been very damaging to Burma’s
economic development. Creating opportunities for great corruption, the gulf
that separates the official and market exchange rates distorts prices
throughout the economy and undermines the functioning of markets. The
precipitous fall of the Kyat, to a level that at the present time means that it
is near worthless, makes doing business in Burma a
most difficult proposition for foreign investors. In July 2001, in a
characteristic effort to stem the fall of the Kyat, Burma’s
military regime withdrew the licences of all but six of the private banks to
deal in foreign exchange.
In addition to
these very real and very large difficulties, however, are various exchange
controls that inhibit still further the development of an outward-looking
financial sector in Burma. Burma’s military regime continues to outlaw the conversion of Kyat into
foreign currency. This means that the repatriation of profits from Kyat
denominated income is difficult. The creation of a parallel currency in the
form of Foreign Exchange Certificates (FECs) in 1993 alleviates one aspect of
this difficulty (conversion into foreign currency), but permission is still
required before any repatriation can take place. Even with approval,
repatriation in any one year cannot exceed profits for that year. Of course,
given that the Kyat is not convertible, no formal market exists for the
currency and, as a consequence, legal hedging against its volatile fluctuations
is not possible.
An especially
egregious restriction on foreigners in Burma
comes via the Transfer of Immovable Property (Restrictions) Law, 1987. Under
this law, no foreign individual or foreign owned company is permitted to
acquire land in Burma, or even lease land for a term exceeding one year unless
specifically authorised by the military regime. Of course, this would greatly
inhibit the ability of foreign banks (and joint ventures) to lend since they
would be unable to seek property collateral against loans.
The Shadow of Money
Laundering
Burma
vies with Afghanistan for the title of the world’s largest producer and exporter of opium
and heroin. Currently accounting for 20 percent of global production of these
narcotics, lately this most productive and innovative sector of Burma’s
economy has diversified into the production of methamphetamines (for which it
is now the largest supplier in Southeast
Asia).
The laundering
of the substantial amounts of money that flow into Burma
from the drug trade is itself a substantial industry in the country. According
to the US State Department, in its latest annual report of the global narcotics
trade:
There is reason
to believe that money laundering in Burma and the return
of narcotics profits laundered elsewhere are significant factors in the overall
Burmese economy, although the extent is difficult to measure accurately.
Political and economic constraints on legal capital inflows magnify the
importance of narcotics-derived funds in the economy. An under-regulated
banking system and ineffective money laundering legislation have created a
business and investment environment conducive to the use of drug-related
proceeds in legitimate commerce (US Department of State 2000).
The State
Department’s assessment is shared by other international agencies. In June 2001
the OECD’s Financial Action Task Force on Money Laundering (FATF), identified Burma as
a ‘non-cooperative state’ in the fight against money laundering. Specifically
with respect to Burma, the FATF found that:
It lacks a basic
set of anti-money laundering provisions…There are no anti-money laundering
provisions in the Central Bank Regulations for financial institutions. Other
serious deficiencies concern the absence of a legal requirement to maintain
records and to report suspicious or unusual transactions. There are also
significant obstacles to international co-operation by judicial authorities
(OECD 2001).
An inescapable
answer (perhaps the only answer) to the great question of banking in Burma –
how is it that the private banks have grown so rapidly in a moribund economy in
which banks and their customers must lose money through inflation and
irrational government policy – is that money laundering is not so much simply a
feature of banking in Burma, it is
banking in Burma.
As the US
State Department noted above, proving the extent of money laundering in Burma’s
banking system is difficult. Nevertheless there are sufficient enough reports
from enough disparate sources, and over enough time, to lend credibility to the
idea that it is rampant. Most of the private banks already mentioned in this
study are implicated in various degrees in the drugs trade. Accusations to this
end are outlined in Appendix Two.
Conclusion
The
foundations of a proper functioning financial system are transparency,
accountability, governance and the effective transmission of market signals. Burma’s
financial system possesses few of these virtues. Burma’s
banks do not fulfil the role allotted to such institutions in allocating
resources in ways beyond the whims of the military. Worse, they may be little
more than facades for the activity of criminals and a narco-state.
Unfortunately the history of financial sector reform in Burma
does not lend optimism to the hope that this might change without more
fundamental changes in the country. Like so much else in Burma,
the emergence of a viable banking system must await the political reform that
is so long overdue.
Sean Turnell,
2001
(Burma
Economic Watch)
APPENDIX 1:
Non-State Banks in Burma
Private Domestic Banks in Burma
·Asia Wealth Bank
·Asian Yangon International Bank
·C.B. Bank
·Cooperative Farmers Bank
·First Private Bank
·Innwa Bank
·Kanbawza Bank
·Myanma Citizens Bank
·Myanmar Industrial Development Bank
·Myanmar Livestock Breeding &
Fisheries Development Bank
·Myanmar
May Flower Bank
·Myanmar Oriental Bank
·Myanmar
Securities Exchange Centre
·Myanmar Universal Bank
·Myawaddy Bank
·Oriental Leasing Company
·Sibin Tharyar Bank
·Tun Foundation Bank
·Yangon City Bank
·Yoma Bank
Representative Offices of Foreign Banks
APPENDIX 2:
Burma’s Private Banks and Accusations of Money
Laundering
The Asia Wealth Bank, the
largest in Burma, was founded by U Eike Htun, a shadowy figure who emerged in the
early 1990s from Kokang, ‘an area notorious for opium production’ (Maung Maung
Oo 2001a). Eike Htun also heads a leading trading and property business called
the Olympic Group that has been very active in investing large sums in
residential property and hotel developments in Rangoon. Most of
these stand empty. The Asia Wealth Bank reports a return on equity of 54.56
percent for 2000-2001 – substantial profits for a bank whose funds are tied up
in assets in which the returns (as noted above) are less than half the rate of
inflation.
The Asia Wealth Bank does much of its business along the Chinese border, a
prime transit point through which drugs from Burma go
out into the world. It is particularly popular amongst ethnic Chinese business
in Burma generally. Protests were staged in Thailand
in May 2000 when Eike Htun was invited to attend an Asian Development Bank
conference in Chiang Mai.
The Mynamar May Flower Bank, often listed as the third biggest in Burma,
was founded by U Kya Win. Kya Win is accused of being a leading figure in the
drugs trade in Burma. He was an associate of Khun Sa, Burma’s
former leading ‘drug lord’ who ‘surrendered’ to Burma’s
military regime in 1996 (Maung Maung Oo, 2001a). In 2000 Kya Win sold an 80
percent stake in the bank to the United Wa State Army (UWSA). The UWSA’s role
in the drug trade is well known, of course and it has been described by the US
State Department as the ‘world’s largest armed narcotics-trafficking
organisation’.
Kanbawza Bank has grown
extremely rapidly in recent years. Established by U Aung Ko Win in Shan State (in an
area also noted for opium production), the bank is famed for its largesse in
many areas, not least for its sponsorship of Burma’s
national football team.
According to Maung Maung Oo (2001a), Aung Ko Win is believed by business people
in Burma to be ‘the adopted son of [junta Vice-Chairman] General Maung Aye
and that he is laundering the corrupt money of the generals through his bank’.
Myawaddy Bank is owned by
Union of Myanmar Economic Holdings (UMEH). UMEH, Burma’s
largest firm, is to all intents and purposes Burma’s
army itself. Formed in February 1990, UMEH is 40% owned by the Defence
Ministry’s Directorate of Defence Procurement and the remaining 60% by ‘defence
services personnel’. The latter are mostly senior officers, including members
of the State Peace and Development Council (since 1997, the more
acronym-friendly name of the SLORC), current serving members of military
regiments and army veterans (individuals and organisations). UMEH has its
fingers in all manner of pies and enjoys great privilages (including exemption
from profit taxes). UMEH runs monopoly subsidiaries in industries that range
from tourism, mining, trading to textiles. As was reported in the last issue of
BEW, it often gets ‘first pick’ of joint-venture projects and partners.
Myawaddy Bank is located in the old Central Bank of Myanmar Building, a
demonstration of its establishment status. According to Kyee-Mohn U Thaung,
‘when Myawaddy Bank opened on January 4 1991, they declared
that there would be no questioning of the depositors…’.
Myanmar Universal Bank has
been implicated not only in the laundering of drugs money, but in the financing
of amphetamine factories in Burma.
The Bank is believed to be owned by Wei Hsueh-Gang, described by the South
China Morning Post as Burma’s ‘premier trafficker’. Wei is from Shan State and has
been indicted on drugs charges in both the United States and Thailand (Barnes 2001).
Of course, the
above account of some of the allegations regarding the largest banks in Burma is
by no means definitive. But, with similar accusations being levelled at most of
the other (smaller) private banks, it is indicative that there is truly
‘something rotten’ at the core of Burma’s
banking sector.
References
Barnes, W. 2001, ‘Bank guests ‘close to
junta, drug lords’, South China Morning
Post, 17
May 2001.
Brookings Institution (1998), Financial Markets and Development, July 1998,
www.brookings.org/es/commentary/journals/fmd/overview.htm
IMF 2001, International Monetary and Financial Statistics, May 2001, Washington D.C., IMF.
Maung Maung Oo (2001a), ‘Above it all’, The Irrawaddy, February, vol.9, no.2, http://www.irrawaddy.org/February/above%20it%20all.html
Maung Maung Oo (2001b), ‘Burma’s
currency woes continue’, The Irrawaddy, July,
http://www.irrawaddy.org/news/july-8.html
OECD, Financial Action Task Force on
Money Laundering (2001), Review to
Identify Non-Cooperative Countries or Territories, Paris, OECD.
Pierce, J.L. 1997, ‘Developments in Myanmar:
New frontiers for banking’, Journal of
International Banking Law, vol.12, no.11, November, pp.441-445.
US Department of State (2000), Narcotics Control Report 2000, www.state.gov/g/inl/rls/nrcrpt/