The October 2022 FATF Plenary downgraded Myanmar from the greylist (jurisdictions under increased monitoring) to the blacklist (jurisdictions subject to a call for action). But unlike DPRK and Iran, the two other countries on the blacklist, countermeasures against Myanmar will not be applied for the time being. However, enhanced due diligence measures will be applied. The FATF called on 'its members and other jurisdictions to apply enhanced due diligence measures proportionate to the risk arising from Myanmar'. This was followed by the following caveat: 'When applying enhanced due diligence measures, countries should ensure that flows of funds for humanitarian assistance, legitimate NPO activity and remittances are not disrupted.'

This caveat followed some intense lobbying by Global NPO Coalition members and partners, including this submission by the Coalition on behalf of some of its members, and this one separately by the Norwegian Refugee Council, underlining the already fragile situation of lives and livelihoods in the country, the role of humanitarian and development assistance in alleviating some of that, and the potential impact of the blacklisting on people and communities. 

The Global NPO Coalition and its partners will continue monitoring the situation (especially financial access for NPOs) over the coming months.