How business finances the crimes of the Myanmar military: MEHL files

September 10, 2020

Myanma Economic Holdings Limited (MEHL) is a vast and secretive military conglomerate, with business interests spanning the Myanmar economy; from banking, trade, logistics, construction and mining to tourism, agriculture, tobacco, food and beverage.

Justice for Myanmar has published significant data on the ownership structure of MEHL, obtained from MEHL’s confidential 2010-11 shareholder report. It includes comprehensive lists of shareholders and data on profit distribution from 1990 to 2011. It also gives insight into the internal operations of MEHL, including rules governing share purchases and the freezing of dividend payments to members of the military who do not toe the line.

MEHL’s shareholder data show that profits are systematically distributed institutionally throughout Myanmar military regiments and units and the military leadership, including those responsible for committing genocide, war crimes and crimes against humanity that have been extensively documented by the UN Fact-Finding Mission. Despite condemnation from the international community, the military has continued to commit international crimes with impunity.

The data also reveals how MEHL distributes profits to the military leadership, creating a systemic and criminal conflict of interest.

Our Evidence

Justice For Myanmar has obtained a copy of MEHL’s 2010-11 shareholder document, “Report on the Status of Share and Dividends of Directorate Offices, and the Military Units under respective Regional Military Commands for the fiscal year 2010-2011”, published internally by MEHL on 3rd June 2011. Data has been transported into Excel for usability, in its original Burmese. Justice For Myanmar has also translated the data into English so as to be accessible to an international audience.

Data from an additional 2019 shareholder document, “List of Original Shareholder Registry (50) Persons, Myanma Economic Holdings Limited, until (30-8-2019)” published by MEHL, has also been transported into Excel for usability, in its original Burmese. Justice For Myanmar has translated this document into English so as to be accessible to an international audience. The original 2019 file is available on Myanmar's Directorate of Investment and Company Administration (DICA) website.


Oct 29, 2020 Update: The original 2019 file has been removed from the DICA website. Justice For Myanmar has made it available here + alternative download link.

Feb 24, 2021 Update: Justice For Myanmar has made the original 2010-11 MEHL shareholder report available here.

MEHL 2011 Report on the Status of Share and Dividends Data
English MEHL 2011 Report - Alternative Download Link
Burmese MEHL 2011 Report - Alternative Download Link

MEHL 2019 Shareholder Registry (50) Data
English 2019 Shareholder Registry (50) - Alternative Download Link
Burmese 2019 Shareholder Registry (50) - Alternative Download Link

Justice For Myanmar provided MEHL’s 2010-11 shareholder report to Amnesty International, as evidence for its report, Military LTD: The Company Financing Human Rights Abuses in Myanmar. Amnesty International has reviewed and analysed the shareholder documents filed by MEHL, and conducted additional research into MEHL and its links to human rights violations in Myanmar.

MEHL share data proves that business deals and investments are financing the military’s international crimes and feeding systemic corruption. This must stop. All military businesses must be dismantled and those responsible for crimes must be held accountable. It is untenable for domestic and international companies to continue to do business with the Myanmar military. They must cut ties.

Read the full Amnesty International Report — Military LTD: The Company Financing Human Rights Abuses in Myanmar

As of 2019, MEHL has 1,793 institutional shareholders, which include regional military commands and their subordinate battalions, divisions, platoons, squadrons and border guard forces. Shares are distributed across the armed forces, creating secret slush funds that support military operations.

MEHL profits are distributed to the regiments and units that are responsible for genocide, war crimes and crimes against humanity. In 2019, the United Nations General Assembly condemned human rights abuses against Myanmar’s Rohingya Muslims and other minorities and called for immediate cessation of violence.

Sources: MEHL 2011 Report on the Status of Share and Dividends Data — (P14) Regiments-Units Shares; UN Fact-Finding Mission; UN Special Rapporteur on the situation of human rights in Myanmar; Amnesty International; Human Rights Watch; Shan Human Rights Foundation; Karen Human Rights Group; Andrew Selth, Myanmar’s Intelligence State (Sep.24, 2018), Griffith Asia Insights.

State leaders and members of government are highlighted as a category of shareholder in MEHL’s 2010-11 report, evidence of the military’s state capture.

In 2011, MEHL shareholders formed Myanmar’s first government as part of the military’s democratic reforms, with many leaving the military to become “civilians”. The merging of the military government and the "civilian" USDP in this cartel-like structure created a shocking conflict of interest that calls into question key USDP decisions. This conflict of interest continues today. MEHL shareholders hold key ministries and are distributed throughout the public service.

Source: MEHL 2011 Report on the Status of Share and Dividends Data - (P9) Senior-Retired Shares

MEHL’s share purchase rules limit the number of shares individuals can buy.

Individuals that are loyal and rise through the ranks can buy a higher number of shares and enjoy more profits. Shares are sold at the artificially low-price of 1000 kyat per share, unchanged since MEHL was established, despite the conglomerate’s exponential growth.

Source: MEHL 2011 Report on the Status of Share and Dividends Data - (P77) Restrictions

MEHL withholds payments to shareholders who step out of line in the military. 

The 2010-11 shareholder report lists dividends withheld to Major Aung Lin Htut, a high-profile defector, as well as deserters and those who are dismissed. MEHL is therefore part of the military’s control structure, punishing dissent and disloyalty.

Source: MEHL 2011 Report on the Status of Share and Dividends Data - (P83) Ineligible For Dividends

The Myanmar military’s Border Guard Force (BGF) program incorporated ethnic armed groups into the Myanmar military, placing them under military command while providing them with limited autonomy, including to pursue business.

Border Guard Force battalions are connected to a range of human rights violations and crimes, including land-grabbing, extortion, forced relocation, arbitrary arrest, money laundering and illegal gambling. 

There are 23 BGF battalions. All are MEHL shareholders, incorporated into the Myanmar military's business, which are incentives to toe the line.

Source: MEHL 2011 Report on the Status of Share and Dividends Data - (P18) Border Guard Forces, John Buchanan, Militias in Myanmar (Jun. 2016), The Asia Foundation, Karen Human Rights Group and Karen Peace Support Network.

Justice For Myanmar

Our goal is for international businesses to divest from the military and for the military to withdraw from the economy and operate under democratic control, governed by justice and accountability and with true civilian oversight.  

The Myanmar military has built immense wealth through partnerships with domestic and international businesses. This wealth fuels war crimes and crimes against humanity. The Myanmar military cartel is a threat to peace and security not only in Myanmar but globally.

The military cartel must be dismantled. This can only succeed through a global network of activists exerting local pressure. Here's how it works:

1. Expose international businesses with financial ties to Myanmar’s military with the release of sourced evidence.

2. Dismantle the military cartel through campaigns for boycotts, divestment and targeted sanctions.

3. Build pressure for action through continued investigation and sourcing of new evidence.