Episode #381: Unfrozen Assets
RELEASE DATE: August 19, 2025
Vicky Bowman, former UK Ambassador to Myanmar and past director of the Myanmar Centre for Responsible Business (MCRB), joins the podcast to discuss how sanctions are designed, how targets are chosen, and Myanmar’s present business environment. She explains what sanctions are intended to achieve and how they are applied, and reflects on what she calls Myanmar’s “messy information ecosystem” — an opaque, poor, and often incomplete flow of information that shapes who gets listed and who is delisted, with serious consequences for perceptions of fairness and effectiveness.
Bowman explains how she derives her understanding from three vantage points: her diplomatic years in Myanmar, first in the early 1990s and then as Ambassador from 2002–2006; a decade of hands-on work with responsible business from 2013–2023; and the post-coup environment.
First reflecting on her return as Ambassador in 2002, she notes that the EU had already begun imposing measures on regime figures. She recalls how policymakers in Brussels faced an “information opaque” environment-- there was little reliable or up-to-date data-- so a small group of EU embassies in Yangon worked to compile names for a sanctions list from whatever could be found. Not all the players were known, business ownership was murky, and many companies avoided embassy contact for fear of military intelligence scrutiny. As a result, diplomats sometimes resorted to public clues-- such as pagoda donation plaques or state media photos of “good works”-- to infer who might be benefiting financially from the regime’s policies.
Bowman says the haphazard approach could sometimes be farcical. She recalls one case where a deceased military officer was added to the EU sanctions list three months after his death. And after sectors like metals, gems, and timber were added to the sanctions list in 2008-- by which time she had left-- she says the embassy resorted to searching the Yangon Yellow Pages for small businesses in furniture and jewelry, a practice she considered “completely wrong” and “frankly kind of crazy.”
Concerning the practice of sanctioning family members of regime figures, especially children, Bowman argues that it mirrors collective punishment practices used by the Nazis, known as Sippenhaft, and questions whether Western democracies should “sink to the same level.” Instead, she urges taking the “when they go low, we go high” approach of Michelle Obama, warning that the deep anger driving some activists to target relatives can be self-destructive. She advises those advocating for change to release that anger, noting that hatred, once entrenched, often harms those who hold it more than those it targets.
A key question regarding sanctions is what they are meant to accomplish, and here Bowman describes two categories. One targets weapons and other technologies, so for example, arms embargoes and “dual-use restrictions” (goods and technologies that can be used for both civilian and military purposes); the other targets individuals through asset freezes and visa bans. Asset freezes are somewhat problematic, she says, especially in a country where many share the same names, and innocent people may be mistakenly affected as a result. Bowman gives examples of Myanmar nationals abroad who struggle to open accounts, students and refugees sometimes treated as high risk by banks, and even family members with common names facing problems at borders. Visa policies can be more precisely targeted when administered well, she notes, but they, too, are vulnerable to poor information.
Then Bowman goes on to describe the different kinds of “spillover” effects that sanctions can have. At the macro level, she notes how they can restrict international financing for projects in Myanmar, so large-scale development loans or grants from foreign institutions or governments become harder— or even impossible— to secure. She also points to sector-specific restrictions, like sanctions on surveillance equipment, that can cause foreign companies to withdraw entirely from Myanmar’s market. Although these macro-level restrictions are aimed at preventing abuse, she describes how they can lead to complex and sometimes unintended consequences for companies trying to operate responsibly.
But she emphasizes that it’s at the micro level where the spillover effect of sanctions really hits the hardest, as it’s ordinary, innocent people who are negatively affected. Employees of large companies owned by sanctioned individuals or entities may lose their jobs or see their livelihoods threatened if those companies are crippled. For example, if a bank closes due to sanctions, it is not only the owner who suffers, but also all the workers, customers, and the wider community that depends on its services. For this reason, Bowman urges restraint and precision in designing sanctions. The priority, she argues, should be to target military-owned conglomerates and arms procurement networks rather than imposing broad measures that shut down legitimate businesses and push more of Myanmar’s economy into the shadows.
Next, Bowman adds the insights she gained through her business-related lens. She describes Myanmar’s business environment as “a web of compulsion,” meaning that businesses are caught between a rock and a hard place: they have a choice, to either voluntarily collude with the regime, or be forced into colluding. Since all businesses want to survive, she urges policymakers to recognize that sanctions need to distinguish involuntary survival behaviors— for example, facilitation payments to petty officials or coerced attendance at regime meetings— from voluntary collaboration, such as arranging weapons purchases.
Turning to the issue of the July delistings of four Buremse individuals who allegedly have ties to the military, Bowman defends the rights of due process and the lawyer who represented the two delisted individuals. Due process is a human right, she stresses; petitioners can— and certainly should be able to— prevail if evidence is weak or circumstances change. She adds that the appeals process also ensures that sanctions don’t automatically become a “forever” thing. In unpacking this particular delistings decision, she notes that importantly, while the two individuals in question were originally listed by the U.S. for their alleged ties to MEHL (Myanma Economic Holdings Limited, one of the two giant, military-owned conglomerates in Myanmar), they had never been sanctioned by the EU or UK. To Bowman, that suggests that these entities had been unconvinced by the original evidentiary claims that had landed those entities on the US list in the first place, and so feels that reconsideration of the case and subsequent delisting decision were completely warranted.
Related to this, Bowman notes that governments now strive more than before the coup to align their listings to iron out any inconsistencies. The reality is that being on one reputable list often functions like being on many, because the automated KYC (Know Your Customer) and AML (Anti-Money Laundering) systems that companies use globally to evaluate potential business partners treat any listing as high risk, whether it is on all countries’ sanctions lists, or just one. She stresses, again, that evidence, appeals, and periodic review—which may result in delisting—are so important to keeping sanctions regimes credible.
Returning to the situation in Myanmar, Bowman explains how some attempts were made during the transition years to create a more open and responsive business environment. She notes that some prominent business families tried to turn the page, future leaders of the younger generation returned from overseas studies, corporate governance standards rose, and a public policy climate supportive of transparency allowed firms to show their work. However, the coup reversed almost all of that progress. Addressing the “good, the bad, and the ugly” about the present circumstances, Bowman begins with a clear positive: sanctioning the military’s two giant conglomerates—MEHL and MEC—has “made them pretty much untouchable,” and that, she thinks, is exactly right. Militaries “should not run beer factories or banks” because their economic arms distort markets, cloak corruption, and entrench authoritarian power. Sanctions, she notes, have also nudged some individuals to reform their practices.
But her “bad and ugly” list is longer. She highlights a backsliding of transparency as firms and registries retreat, afraid that disclosure will only paint targets on their backs. Companies have reverted to hiding data again; the country’s EITI reporting (the Extractive Industries Transparency Initiative, a global standard that promotes open and accountable management of natural resources like oil, gas, and minerals) has stopped; and the climate of fear discourages disclosure, because firms worry that any public information could be weaponized into sanctions. The information ecosystem has degraded to the point that rumor masquerades as reporting, rivals plant stories to get competitors listed, and attempts to correct falsehoods meet demands for advertising or “donations.”
Looking at post-coup Myanmar, Bowman believes that sanctions should stay targeted, grounded in clear and reviewable evidence, and used sparingly-- the goal is to prevent future wrongdoing and incentivize change, not to create permanent pariah lists. Also, the ability to appeal needs to be honored. While acknowledging the emotional reality of Myanmar communities who see delistings as betrayals, she holds firm on the need to uphold legal rights and remedies, warning that collapsing due process corrodes the very norms that distinguish democracies from the regimes they oppose.
Bowman elaborates on the work of the Myanmar Centre for Responsible Business, which was set up to promote responsible business practices in Myanmar. It provided guidance, advice and tools to companies on how to operate responsibly in sectors like extractives, telecommunications, and manufacturing, both in-country and internationally, while encouraging transparency. It acted as a bridge between the private sector, civil society, and policymakers to create a business environment that supported sustainable development and human rights. Though its work is winding down now, its decade of guidance will remain online for any future transition that wants to rebuild Myanmar’s economic rules.
In the end, Bowman believes that if there is a path forward, it runs through legislation and institutions: transparent procurement (to block the next generation of cronies), functioning courts and anti-corruption bodies at the union and subnational levels (to make federalism work without spawning local fiefdoms), and human-rights-based data and cybersecurity laws (so telecoms aren’t forced to choose between illegal compliance and exit). “Sanctions are not a substitute for the absence of functioning legislation, independent courts, institutions that protect rights, enforce contracts, protect shareholders, and so on. Without those, sanctions can only do so much.”