The Sky Aviator arms broker network appears to be using a nominee structure to acquire a significant stake in Advanced Connection Corporation Public Company Limited (ACC), a Stock Exchange of Thailand (SET) listed company, raising serious money laundering concerns.

The investment is being made via a private placement through two recently established Thai shell companies, Sky Avia Trading Company Limited and Heli Asia Trading Company Limited, whose Singapore parent entities were fully owned and directed by Kyaw Min Oo until he, on paper, transferred the shares to his longtime nominee director in 2022.

The private placement sells a combined 23.25% stake to the Sky Aviator network companies for 300 million baht (US$9.3 million), as part of a 350 million baht (US$10.8 million) total placement that also includes a Thai individual investor, Wichai Wanavit.

The private placement was approved at an ACC shareholder meeting on April 27, 2026, against the advice of the company’s financial advisor and despite scrutiny over the transaction from Thailand’s Securities and Exchange Commission (SEC). The private placement resolutions passed with 87.16% in favour and 12.84% opposed.

A week before the meeting, on April 20, the SEC instructed ACC to provide further details on the rationale, investor selection process, strategic fit, board assessment and risk management of the private placement under Section 58(1) of the Securities and Exchange Act. The SEC warned that if ACC fails to make the disclosures, the private placement would be deemed not to have been approved. ACC responded on April 23, naming Kyaw Min Oo and disclosing that Audit Committee Chairman Weerachai Amornrat had abstained from the board vote authorising the transaction citing concerns over financial controls and verification of beneficial ownership of the proposed investors. ACC has failed to resolve the questions over beneficial ownership of Sky Avia Trading and Heli Asia Trading.

It is now the responsibility of Thai authorities to act and prevent the Sky Aviator arms broker network from completing the transaction and becoming the biggest shareholder bloc in ACC, and to protect the integrity of the Thai financial system.

The Sky Aviator network and the business of war crimes

Kyaw Min Oo is one of the key arms brokers used by the Myanmar military, including to supply parts needed to maintain their fleet of Russian Yak-130, Mi-24, Mi-35 and Su-30 aircraft. As a result, he is sanctioned by the USA, UK, EU and Canada, with additional sanctions in place against some of his businesses.

The Sky Aviator network consists of at least four Myanmar companies: Sky Aviator Co. Ltd., H N C K Co. Ltd., Sky Royal Hero Co. Ltd. and Heli Eagle Co. Ltd. Leaked corporate records from 2024 list Kyaw Min Oo as a director and shareholder of Sky Aviator alongside Ye Lin Htet. Kyaw Min Oo’s mother, Aye Aye Yi, and his business associate, Wai Sar Tun, are listed as directors. 2022 corporate records show that Wai Sar Tun is also a director of Heli Eagle with Zaw Lwin and Kyaw Min Oo’s brother, Lieutenant-Colonel Myo Min Oo. Myo Min Oo is a former squadron commander of a Myanmar Air Force helicopter unit, a role he stepped down from nearly a decade ago to focus on his private business activities, according to Justice For Myanmar sources. 2022 corporate records also show Aye Aye Yi as a director of H N C K alongside Kyaw Min Oo’s wife, Yu Theingi Aye, who was a former director of Sky Aviator. It is likely that multiple other nominee arrangements have been created across the Sky Aviator network. For instance, recently leaked records for Sky Royal Hero show that it was restructured in the last year with Than Kyaw now listed as the sole director and shareholder.

According to reporting by the UN Special Rapporteur on Myanmar, within six weeks of UK sanctions on Kyaw Min Oo, payments from the Myanmar army’s Directorate of Procurement for Sky Aviator contracts began to be re-routed through Heli Eagle Co. Ltd. The UN Special Rapporteur also identified that Sky Royal Hero was acting as a supplier to Sky Aviator. Shipment records obtained by Justice For Myanmar confirms that Sky Royal Hero received a shipment of helicopter parts for Mi-35 helicopters in January 2024.

The ongoing material support provided by Kyaw Min Oo and the Sky Aviator network enables the Myanmar Air Force to conduct airstrikes at unprecedented rates with total impunity. The Myanmar Air Force-operated aircraft that Kyaw Min Oo and his business network have supplied parts for have been widely linked to indiscriminate airstrikes that amount to war crimes. For instance, the junta used Yak-130 combat aircraft and Mi-35 attack helicopters in an airstrike on a civilian gathering in Pa Zi Gyi, Sagaing, in April 2023, killing at least 165 people, men, women and children. In June 2025, MiG-29 combat aircraft were allegedly used in a junta airstrike targeting a school in Yin Ngat Kone village in Sagaing. The junta was also likely to have usedSu-30 fighter jets in its bombing of a concert in Hpakant in Kachin State in October 2022 that killed more than 60 people.

As a sign of the importance of Sky Aviator’s brokering for the Myanmar military, in November 2025, Kyaw Min Oo was personally awarded an honour by the military junta for “Excellent Performance in Social Field (Third Class)”, alongside other cronies. This award came after Kyaw Min Oo was convicted in Singapore in December 2023 for attempting to move SG$508,925 in undeclared funds out of the country, together with Wai Sar Tun and another business associate, Win Myint.

Kyaw Min Oo now appears to be using his network to acquire a substantial stake in a Thai-listed company without disclosing his ownership.

The Thai companies used in the arrangement, Sky Avia Trading Co. Ltd. and Heli Asia Trading Co. Ltd. are subsidiaries of Singapore entities bearing the same names: Sky Avia Trading Pte. Ltd. and Heli Asia Trading Pte. Ltd., registered at 10 Anson Road, International Plaza, Singapore, and described by ACC as “trading in helicopter and aircraft spare parts”. Both Singapore entities were founded in October 2015 by Kyaw Min Oo, who was the director and sole shareholder from the date of incorporation until April 2022.

From October 2015 to April 2022, Sky Avia Trading Pte. Ltd. and Heli Asia Trading Pte. Ltd. operated with a separated governance structure in which Singaporean national, Wee Lee Lian, served as Kyaw Min Oo’s nominee director without holding any shares. About seven months after Justice For Myanmar first exposedSky Aviator’s arms brokering, Kyaw Min Oo stepped down as director of Sky Avia Trading and Heli Asia Trading, transferring his entire shareholding to Wee Lee Lian. Corporate secretarial services are provided by Yeo Chee Seng (Yang Zhicheng), who is registered at the same 10 Anson Road address as the companies and is linked to more than 3,000 Singapore companies, according to Singapore corporate records on file with Justice For Myanmar.

Sky Avia Trading Pte. Ltd. and Heli Asia Trading Pte. Ltd. are two of five known aviation-related service companies established by Kyaw Min Oo in Singapore between 2014 and 2017 using the same nominee structure in which Wee Lee Lian is first appointed as a nominee director in each business and then as sole shareholder through the 2022 restructure. The other Sky Aviator Singapore companies, Asia Aviation Trading, Heli White Trading and Sky Union Trading, were struck off between November 2024 and May 2025.

Justice For Myanmar sources have indicated that Wee Lee Lian is under the effective influence of Kyaw Min Oo, who appears to continue to exercise de facto control over the Sky Aviator network, which includes Sky Avia Trading and Heli Asia Trading. A source with direct knowledge of Sky Aviator told Justice For Myanmar that transferring company control to nominee directors, typically Singaporean individuals with no decision-making authority, is a standard practice when faced with scrutiny.

Wee Lee Lian has no documented history in aviation procurement, wholesale trade, or international commerce. Singaporean registry records show that her corporate existence outside beauty and hospitality businesses consisted almost exclusively of nominee roles in Sky Aviator companies.

As a result of the nominee structure, Wee Lee Lian on paper now holds 100% of the two Sky Aviator Singapore companies and 95% of the two Thai companies. The remaining 5% of the two Thai companies is held by a Singaporean national identified by ACC as “Mr. Max Indren”. This name is consistent with Singapore registry data on Max Indran V Mahetheran, a tax consultant affiliated with 164 companies in Singapore, a profile typical of a nominee shareholder.

After Kyaw Min Oo restructured his Singapore business, it has continued to serve the Myanmar military alongside Sky Aviator in Myanmar.

Shipment records obtained by Justice For Myanmar confirm that Motor Sich, a major Ukrainian turboprop engine manufacturer, shipped engines and parts to Sky Aviator in Myanmar across four shipments between January and May 2022. In June 2023, approximately 14 months after Kyaw Min Oo transferred Sky Avia Trading Pte. Ltd. to Wee Lee Lian, Motor Sich supplied it with a turboprop engine worth more than US$2.2 million. At the time, Sky Avia Trading was purportedly under Wee Lee Lian’s directorship. These turboprop engine shipments from Motor Sich, both to Sky Aviator in Myanmar and Sky Avia Trading in Singapore, share the same HS code, 8411222000. The engine imported by Sky Avia Trading Pte. Ltd. was likely shipped onwards to Myanmar for use with aircraft operated by the Myanmar Air Force.

The continuation of the same established supplier relationship with the same specific engine class and HS code before and after the creation of the nominee structure provides further indication that Sky Avia Trading Pte. Ltd. continues to operate as part of Kyaw Min Oo’s military procurement network. There is no plausible reason a major Ukrainian aircraft engine manufacturer would sell a US$2.2 million turboprop engine to a company owned by Wee Lee Lian, whose background outside of the Sky Aviator network consisted of owning a massage parlour, beauty salons and a café.

The ACC deal

ACC is a publicly listed Thai company active across a wide range of sectors, including renewable energy, lending, construction contracting, real estate and distribution. The company has a history of regulatory breaches. In 2013, ACC’s Managing Director Vichien Uasanguankul was suspended by the SEC because of his failure to properly perform due diligence for a company applying for an initial public offering. He is the signatory of ACC disclosures regarding the company’s deal with Sky Avia Trading and Heli Asia Trading.

ACC has proceeded to raise funds in the private placement after consecutive financial losses. ACC reported a net loss of 378 million baht in 2025, with losses of 88 million baht in 2024 and 82 million baht in 2023. In its April 10, 2026 opinion to shareholders, ACC’s Board stated that it had been “unsuccessful” in obtaining loans from financial institutions because of the company’s financial difficulties, thereby necessitating capital raising from the Sky Aviator companies.

ACC first announced it would sell a significant number of shares to Sky Avia Trading Co. Ltd. and Heli Asia Trading Co. Ltd. in October 2025, just over a year after the two companies were established. ACC has publicly claimed the investment would fund the installation of solar energy systems. The company argued that Sky Avia Trading Co. Ltd. was a suitable investor because it had “the capability to support businesses related to the aviation industry and/or related services, which may facilitate business expansion and the development of strategic partnerships”, despite this being unrelated to solar energy. According to records filed with Thailand’s corporate registry, on file with Justice For Myanmar, Sky Avia Co. Ltd. was established with the objective of “wholesale of machinery and equipment for civil engineering mining and construct work” and Heli Asia with the objective of “wholesale of industrial machinery for remuneration or under contract.” Neither is consistent with solar energy investment.Both Sky Aviator Thai companies changed their registered business objective to “investing in solar power generation projects and selling electricity to government agencies, private companies or individuals” in August 2025, weeks before ACC’s public announcement of the private placement. At the same time, they also adopted company seals. A comparison of the Sky Avia Trading and Heli Asia Trading seals filed with the Thai corporate registry, and Sky Aviator’s seal from a leaked 2024 internal document, shows they are identical.

ACC’s own audited financial disclosures confirm that the two Thai entities had zero business activities between their incorporation and December 2024, a period of approximately four months. Sky Avia Trading Co. Ltd. reported total revenue of 2.25 baht and a net loss of 33,572 baht (US$940). Heli Asia Trading Co. Ltd. reported identical revenue and a near-identical loss of 33,523 baht. Each company's total assets of approximately 250,000 baht (US$7,200) consist almost entirely of paid-up capital. Of those assets, approximately 230,000 baht has been lent back to a director of the companies. According to the auditor's notes, those loans carry no interest, are not documented in any written agreement, are not secured by collateral, and are repayable on demand. The sole director of both companies, and therefore the recipient of the loans, is Wee Lee Lian. This means the Thai companies hold nearly all their capital as loan receivables from the very person who, on paper, controls them, an unusual structure for companies established to make a 300 million baht investment in ACC.

Under the current arrangement, Sky Avia Trading Co. Ltd. will receive 80 million shares (3.10%) and Heli Asia Trading Co. Ltd. will receive 520 million shares (20.15%) to form a concert party holding of 23.25%, making the Sky Aviator network the largest shareholding bloc in ACC. The bloc’s 23.25% falls just below the 25% threshold that triggers a mandatory public tender offer, which would require disclosure of ultimate beneficial ownership and an offer to all remaining shareholders of ACC. This followed the initial October 2025 proposal in which Sky Avia Trading Co. Ltd. and Heli Asia Trading would purchase a total of 27.02% of ACC’s shares with a request for a waiver for the mandatory public tender offer requirement.

ACC has acknowledged that Sky Avia Trading Co. Ltd. and Heli Asia Trading Co. Ltd. are concert parties under Section 258 of Thailand’s Securities and Exchange Act. In the revised private placement that keeps the Sky Aviator network below the 25% threshold, a third investor, Wichai Wanavit, was added, taking a proposed 3.88%. By restructuring the stake below that threshold, ACC avoided the disclosure obligations that a mandatory tender offer would have entailed, including heightened regulatory scrutiny over the identity of the ultimate beneficial owners.

In a December disclosure, ACC reported that on September 23, 2025, the Sky Aviator companies transferred 348 million baht (more than US$10 million) into ACC's bank account without shareholder or SEC approval. ACC characterised the transfer, equivalent to the original subscription amount under the Share Subscription Agreement, as a "misunderstanding" by the Sky Aviator investors. ACC wrote that the funds originated from Heli Asia Trading Pte. Ltd. and Sky Avia Trading Pte. Ltd., in Singapore, and later disclosed that they were personal "loan transfers" from Wee Lee Lian, without explaining her source of funds. ACC retained the fundsfor nearly three months before transferring them, via Bahtnet, to a Thai escrow account for Sky Avia at Krung Thai Bank. ACC has not publicly explained why the funds were retained for so long before being transferred to the escrow account.

ACC also revealed in the December disclosure that the original Share Subscription Agreement came with a Share Buyback Agreement between Sky Avia Trading Co. Ltd., Heli Asia Trading Co. Ltd. and ACC's Managing Director Vichien Uasanguankul. Under that agreement, Vichien Uasanguankul personally committed to repurchase all of the newly issued shares from the Sky Aviator investors after a one-year holding period. The agreement also transferred the investors’ voting rights to Vichien Uasanguankul personally during that period. If Vichien Uasanguankul failed to repurchase the shares, the only stated consequence was that he would have to resign from his positions at ACC but would not face any financial penalties. According to the disclosure, the SEC questioned that structure, which it described as resembling "a short-term loan with a high rate of return of up to 26 percent per annum, with the private placement shares serving as collateral". The buyback agreement was removed after SEC scrutiny. The SEC also questioned whether Vichien Uasanguankul and the Sky Aviator investors are themselves "acting in concert" under Thai securities law, given the voting-rights transfer and the personal repurchase obligation. The SEC warned that ACC’s request for a waiver from making a mandatory tender offer may not be in compliance with SEC rules.

Justice For Myanmar wrote to ACC on February 10, 2026 and again on February 18, 2026, and reported concerns over the private placement to the SEC, SET and Anti-Money Laundering Office. In a public disclosure to the SET, ACC claimed that it could not verify the sender’s identity of the February 10 letter, despite Justice For Myanmar being a publicly known activist group that has appeared in Thai media. ACC later characterised Justice For Myanmar as “political activists” and accused without evidence that an alleged ACC website breach detected on February 19, 2026 was linked to Justice For Myanmar. ACC stated that they “filed a complaint with the relevant authorities to pursue legal action against the said group of activists.” Justice For Myanmar considers these claims to be a deflection from the substance of the concerns raised regarding the Sky Aviator network investment, rather than responding to the facts on their merits.

On March 23, 2026, the SEC instructed ACC to clarify investor selection criteria and its verification of the source of funds, ultimate beneficial ownership and adequacy of the board’s assessment. ACC replied on April 2 claiming that it had vetted the Singapore entities and stated that “there are reasonable grounds to conclude that the current shareholders are the ultimate beneficial owners”. This conclusion was largely based on documents that a nominee arrangement would, by design, not reveal. Nominee agreements are private, not filed in the Singapore corporate registry and not made publicly available. A review of Singapore company registry records cannot, on its own, rule out a nominee arrangement. ACC’s own independent financial advisor, Welcap Advisory, acknowledged difficulties in making a conclusion on the nominee arrangement.

In its April 1, 2026 report to shareholders, Welcap Advisory concluded that shareholders “should consider not approving” the transaction. Welcap Advisory found “uncertainty regarding the source of funds and the ultimate beneficial owners” of the investors and warned that the “presence of risk factors relating to the qualifications of the [private placement] investors, specifically, concerns regarding whether they may be acting as representatives for other parties, poses a material uncertainty.” Welcap warned of “a possibility that authorities may subsequently investigate the source of funds used for the subscription” which would adversely affect ACC and its shareholders, concluding that “proceeding with the transaction is not appropriate”. Yet, ACC’s Board resolved to recommend approval anyway.

Despite the multiple red flags, after multiple postponements, ACC announced it would hold its annual general meeting on April 27 and put the private placement to a vote. At the meeting, shareholders approved the capital increase and the offering of 700 million new shares to Sky Avia Trading, Heli Asia Trading and Wichai Wanavit, clearing the voting threshold. Voters representing 55% of shares held attended the meeting. The shareholder resolutions also delegated authority to Vichien Uasanguankul personally to “amend, revise, or supplement any wording, conditions, figures, and/or other relevant details” related to the private placement “in order to comply with the orders, recommendations, or opinions of the Department of Business Development, the Securities and Exchange Commission, the Stock Exchange of Thailand, and other relevant authorities until the process is completed.”

Thai and Singapore authorities should intervene

As ACC has noted, the private placement needs to be approved by Thai authorities who have already raised concerns about the deal with the Sky Aviator network. Justice For Myanmar calls on the Thai SEC to deem the private placement not approved, as it has warned. Justice For Myanmar also calls on the Thai Anti-Money Laundering Office to investigate whether the investment constitutes money laundering under the Anti-Money Laundering Act, including as potential proceeds of arms dealing, sanctions evasion and transnational organised crime, and to freeze the 348 million baht held in escrow at Krung Thai Bank pending seizure. The Department of Business Development, which must register the capital increase, should refuse to do so given the serious concerns about the source of funds and beneficial ownership of the investors.

Wee Lee Lian’s role in the US$2.2 million turboprop engine shipment from Motor Sich to Sky Avia Trading Pte. Ltd., under Lian’s directorship, should be investigated by Singapore authorities as a breach of the Strategic Goods (Control) Act and as potential money laundering. Justice For Myanmar has reported this to Singapore authorities.

Justice For Myanmar notes significant gaps in current international sanctions on the Sky Aviator network, which has enabled the suspected attempt to launder funds. While the USA, Canada, UK and EU have sanctioned Sky Aviator and Kyaw Min Oo, no jurisdiction has sanctioned Wee Lee Lian or the Singapore and Thai companies Sky Avia Trading and Heli Asia Trading. The US and Canada have sanctioned the Sky Aviator network company, Sky Royal Hero, while Canada has also sanctioned Heli Eagle and Myo Min Oo. Australia has not sanctioned any Sky Aviator companies or individuals. These gaps are currently being exploited by the network.

Justice For Myanmar calls on the US, UK, EU, Canada and Australia to urgently close these gaps by imposing coordinated network sanctions on the full Sky Aviator network of companies and individuals.