Financial Access Under Restrictions
Supporting Local Democracy and Human Rights Organisations in Myanmar
Efforts to make international assistance more locally led increasingly emphasise shifting resources and decision-making power towards local actors. Yet operational constraints, including access to formal financial systems, are often cited as barriers to providing direct support. Addressing these constraints is therefore important not only for financial access, but for making localisation possible in practice.
For local democracy and human rights organisations in Myanmar, extensive authoritarian control over legal and financial systems can make conventional institutional arrangements inaccessible or unsafe. Yet international funding systems often rely on requirements such as formal registration and organisational bank accounts as indicators of organisational credibility, financial control, and accountability.
This exposes a wider tension in international assistance. Support intended to address the consequences of weak, captured, or unaccountable institutions can itself be conditioned on local actors being able to use those same systems. Such requirements can reinforce the constraints that international assistance seeks to address. Overcoming this tension ultimately requires political will and approaches that enable credible local actors to demonstrate accountability and access resources safely when conventional institutional arrangements are inaccessible or unsafe.
Key Messages
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Dynamics of Compounded Financial Exclusion
Financial exclusion affecting civil society in Myanmar does not result from a single policy or institution. It emerges from the interaction of authoritarian restrictions, international financial safeguards, and the risk-management decisions of financial institutions and service providers. These systems have different purposes, but their effects can converge on local democracy and human rights organisations that already have limited access to formal financial systems.
Restricting access to resources is part of a wider authoritarian approach to controlling independent civic and democratic actors. In Myanmar, such practices have been reinforced through decades of military rule and can include criminalising legitimate activities and restricting access to financial resources and institutions. Mandatory registration and extensive authoritarian control over formal systems can create political and personal security risks for organisations whose work is considered sensitive. Financial exclusion can therefore become both a consequence of, and a means of reinforcing, restrictions on civic space.
Importantly, the absence of conventional financial infrastructure does not necessarily mean the absence of financial accountability.
A separate layer comes from international sanctions, financial safeguards, and institutional risk management. Measures addressing money laundering, terrorist financing, and other financial risks serve legitimate purposes. International standards, including those promoted by the Financial Action Task Force (FATF), are implemented through national regulatory frameworks and the compliance and risk-management practices of financial institutions and service providers. However, their implementation can also restrict financial access for credible civic actors associated with high-risk jurisdictions, resulting in heightened scrutiny, additional documentation requirements, or restricted access to financial services.
Together, these layers can produce compounded financial exclusion. Authoritarian restrictions can leave local civic actors outside formal financial systems, while international safeguards and institutional risk management can narrow the alternative channels available to them. Importantly, the absence of conventional financial infrastructure does not necessarily mean the absence of financial accountability. Credible organisations may maintain appropriate financial controls and accountability practices while being unable to access the institutional channels normally expected by international funders.
Financial Access and Accountability under Constraints
Local democracy and human rights organisations continue to receive and manage international support despite operating without reliable access to institutional financial systems. When organisational bank accounts are inaccessible or unsafe, they must adapt their financial arrangements to keep activities running and maintain accountability for resources.
These arrangements can include personal accounts, accounts available in other countries, trusted individuals, international financial services, and international organisations or other partners. Different organisations use different arrangements depending on their circumstances, security considerations, available relationships, and funding partners’ requirements.
These practices should not automatically be interpreted as evidence of weak financial management or organisational credibility. They are often practical responses to environments where conventional institutional arrangements are unavailable. Organisations can still maintain internal financial controls, documentation, accounting records that distinguish different funding sources, expenditure records, and other accountability practices even when the financial channel itself is unconventional.
Alternative arrangements nevertheless have limitations. Personal or third-party accounts may carry legal, tax, reporting, or compliance implications depending on the jurisdiction, while international financial services remain subject to regulatory and institutional requirements. Access to particular channels can also change unexpectedly.
The practical challenge for international actors is therefore not simply whether local organisations meet conventional financial requirements, but whether credible organisations can demonstrate that alternative arrangements are sufficiently safe, transparent, and accountable. Context-sensitive due diligence can help recognise such arrangements and maintain access to international support while longer-term pathways to institutional financial access are developed.
Local Leadership Requires Financial Access
Financial access is not simply an operational concern. It affects whether local democracy and human rights organisations can exercise meaningful control over resources, develop direct funding relationships, maintain accountability, and sustain their work.
First, financial access is fundamental to locally led development. Efforts to shift power increasingly emphasise direct and flexible funding, greater local decision-making, and stronger institutional ownership. Yet operational constraints, such as the absence of organisational bank accounts, can make direct support seem difficult or non-viable. Addressing these constraints is therefore part of making localisation possible in practice, rather than allowing limitations in existing systems to determine which local actors can be supported.
Second, limited financial access can constrain funding diversification. Organisations that cannot meet conventional financial requirements may be excluded from otherwise relevant funding opportunities or remain dependent on a limited number of partners willing to accommodate alternative arrangements. Greater financial access can expand their opportunities to develop direct relationships with different funding partners.
Financial access also matters for accountability and safety. Alternative arrangements can maintain accountability, but conventional institutional access can reduce reliance on individuals and provide more stable ways to manage organisational resources.
Finally, the challenge extends beyond Myanmar. Democracy and human rights organisations in other restrictive environments may face similar tensions between political repression, international financial safeguards, and access to formal financial systems. Developing workable approaches can therefore contribute to more sustainable international support for civic actors across restrictive contexts.
From Immediate Responses to Longer-Term Access
Addressing financial exclusion requires both the political will to sustain support under difficult conditions and longer-term efforts to expand local actors’ access to regulated financial systems.
In the short term, international actors should recognise that supporting democracy and human rights organisations in restrictive environments may require approaches that differ from conventional funding arrangements and a greater, but considered, tolerance for risk. Registration, institutional bank accounts, and other formal documentation are commonly used to assess organisational credibility and risk, but their absence may reflect political and security constraints rather than weak governance or accountability. Context-sensitive assessments can instead draw on organisational track records, governance and financial practices, trusted references, and other appropriate verification methods. International actors should consider appropriate and accountable ways to maintain support when conventional requirements cannot be met, while applying safeguards proportionate to actual risks. The objective should not be to eliminate risk, but to avoid transferring disproportionate risks to local actors or allowing risk avoidance to reinforce the restrictions they already face.
While [many existing mechanisms] may enable short-term access, their long-term sustainability remains uncertain in a context where regulatory and political conditions can change rapidly.
The continued functioning of current arrangements should not be taken as evidence that the underlying challenge has been resolved. Many existing mechanisms were developed as emergency responses to immediate constraints. While they may enable short-term access, their long-term sustainability remains uncertain in a context where regulatory and political conditions can change rapidly.
In the longer term, international actors should help build pathways to international financial access. International human rights and democracy-support organisations could work with willing financial institutions and regulated financial-service providers in democratic jurisdictions to explore appropriate services for credible civic actors operating in restrictive environments. Rather than prescribing a particular platform or mechanism, the focus should be on financial technologies and institutional arrangements that provide appropriate security, transparency, accountability, and regulatory safeguards. International organisations could contribute contextual knowledge, build organisational credibility, and help local actors navigate documentation and compliance requirements. Over time, local actors should have greater opportunities to access, hold, transfer, and manage international resources through reliable financial systems.
Enabling Local Actors through Financial Access
Financial exclusion facing local democracy and human rights organisations in Myanmar reflects a wider challenge for international support in restrictive environments. Authoritarian restrictions and international financial safeguards have different purposes, yet their effects can intersect in ways that limit credible civic actors’ access to financial systems.
Addressing this challenge requires political will, context-sensitive approaches, and a considered tolerance for risk. The absence of conventional financial infrastructure should not be treated as the absence of accountability. If international actors are committed to locally led development and sustainable civil society, they should both enable credible local actors to access resources under current constraints and help develop longer-term pathways to reliable international financial access. ●
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