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The Myanmar junta and companies associated with it have intentionally misdescribed and misclassified aviation fuel as high-speed diesel and used proxy companies to conceal imports of the deadly fuel to Myanmar, a new Justice For Myanmar investigation has revealed.
The investigation found a pattern of trade fraud in documentation for the import of six cargoes of over 843,000 barrels, with a total value of US$109.5 million between December 2024 and November 2025.
During this period, which coincided with the lead-up to the junta’s sham election, the junta significantly intensified airstrikes, killing civilians and causing mass displacement.
The UN Human Rights Office recorded a more than 50% rise in civilian deaths from junta airstrikes in 2025 compared to the year before. In 2025, the junta killed at least 982 civilians in airstrikes, including 232 children, more children than were killed in junta airstrikes in the previous four years combined.
The continued supply of aviation fuel sustains the junta’s intensifying aerial campaign of terror, in which it routinely kills civilians and attacks schools, hospitals, places of worship and civilian homes with total impunity.
Justice For Myanmar’s trade fraud findings are based on an examination of import permits, confidential letters from the junta’s Foreign Exchange Supervisory Committee (FESC), company contracts, invoices and corporate extracts from a junta commerce ministry data leak, and an analysis of the junta’s aviation fuel supply network, fuel price and density.
The listed importers in the documents are two Myanmar companies: Dynamic Wave and PP Petroleum. However, the actual buyer behind the imports was found to be National Energy Prime Aviation Services Company Limited (NEPAS).
NEPAS is a joint venture between the state-owned Myanma Petrochemical Enterprise (MPE), which is illegally controlled by the junta, and its private partner, Asia Sun group (also known as Myan Oil and Shoon).
Despite the well-documented role of NEPAS and MPE in supplying aviation fuel to the Myanmar military, neither has been targeted for sanctions. Sanctions imposed by the USA, UK, EU, Canada and Australia have focussed on a limited number of Asia Sun group companies and individuals.
Asia Sun group is a network of companies that dominates the aviation fuel supply chain with MPE. The network has been expanding since it was first exposed in 2022 and has established many proxy and shell companies as a likely response to sanctions and public scrutiny. PP Petroleum is part of Asia Sun group.
The aviation fuel sellers exposed include a previously exposed Thai company, Tawan-Oil Trading, and a UAE company, NEC Trading, for fuel declared as originating from South Africa and Singapore, according to contracts. Justice For Myanmar assesses that Tawan-Oil Trading and NEC Trading are also controlled by Asia Sun group.
Documents from the data leak show that the junta oversaw the trade fraud scheme at a high level.
In one FESC decision from November 2025, the committee approved the issuance of an import permit in the name of Dynamic Wave, “on behalf of” NEPAS, under the product description “diesel (HSD)” instead of “aviation fuel”.
The FESC consists of six high-level junta members: a junta vice-president; the three junta ministers responsible for investment, finance and commerce; the junta auditor general; and the chair of the junta-controlled central bank.
Since May 2024, the FESC has been chaired by Nyo Saw, the junta’s “vice-president-1” and a former army quartermaster general who has played a central role in overseeing the military’s expansive business interests.
Despite his notoriety, Nyo Saw has only been sanctioned by the EU and Canada. The junta’s commerce minister, Tun Ohn, whose ministry issued the import permits, has not been sanctioned in any jurisdiction.
Governments must urgently strengthen sanctions, close loopholes, end impunity and block the junta’s ability to source aviation fuel on the global market.
Justice For Myanmar calls on the USA, UK, EU, Canada and Australia to update and expand sanctions to ensure the junta and its members remain designated after rebranding, to extend sanctions to MPE, NEPAS and the whole aviation fuel supply chain, and to ban exports of aviation fuel to Myanmar, which only Canada has done.
Singapore and Thai authorities should investigate customs fraud by the junta, Asia Sun group and its partners, and any associated breaches of domestic laws.
Singapore and Thailand have a heightened responsibility to ensure companies and individuals in their territory are complying with domestic and international law and end the use of their territory and banks in the supply of aviation fuel to the junta.
Justice For Myanmar calls on South African authorities to ensure that no aviation fuel is supplied from South Africa to Myanmar and investigate whether South Africa is being falsely named as its origin, and on the UAE government to strengthen measures to protect its territory and banks from actors undermining its regulatory, financial and trade systems.
Governments must stop granting the junta false legitimacy, which only prolongs the crisis and emboldens the junta to continue its criminal conduct.
Justice For Myanmar spokesperson Yadanar Maung says: "The illegal Myanmar junta is a criminal cartel that commits international crimes and transnational crimes with total impunity.
"The junta relies on aviation fuel to wage its widening campaign of terror against the people of Myanmar. Aviation fuel is a deadly weapon for the junta that kills children in their classrooms, obliterates hospitals and wipes out communities.
"The fact that the junta is resorting to methods of trade fraud to import aviation fuel shows that sanctions and public pressure are biting, but governments must keep up to stop this deadly trade.
"The existing sanctions are clearly not enough. The USA, UK, EU, Canada and Australia must impose coordinated sanctions on the junta’s complete aviation fuel supply chain network, and governments need to follow Canada’s lead and impose an export ban on aviation fuel.
"Thailand and Singapore must do more, block Asia Sun group from operating in its territory and investigate the junta’s trade fraud.
“Governments must act to stop the junta’s slaughter of civilians, stop rewarding the illegal junta with false legitimacy and pursue real accountability."
More information:
Read Justice For Myanmar’s investigation into how the junta committed trade fraud by authorising the import of aviation fuel here
