The Sentry calls for coordinated sanctions and enforcement following a Justice For Myanmar investigation and Reuters reporting on the junta’s aviation fuel network and its ties to Iran

A new Justice For Myanmar investigation alleges the Myanmar military junta and associated companies have used trade fraud and proxy companies to sustain aviation fuel imports despite international sanctions and scrutiny of the junta’s deadly air campaign. Reuters’ independent reporting confirms Justice For Myanmar’s findings that these networks combine false commodity and origin declarations with opaque financial and shipping arrangements.

Justice For Myanmar identified records for six authorized aviation fuel imports worth $109.5 million between December 2024 and November 2025, in which fuel was described as high-speed diesel and proxy companies were used to obscure the true buyers, sellers, and sources of funds. 

Most significantly, documents identified by Justice For Myanmar show that the junta’s Foreign Exchange Supervisory Committee (FESC) explicitly authorized aviation fuel to be imported under a diesel description and transactions to be routed through a proxy company acting on behalf of National Energy Prime Aviation Services Company Limited (NEPAS), a central actor in Myanmar’s aviation fuel supply chain.

Reuters separately found that trade data contradicted the purported South African origin of diesel listed in documentation for one of the shipments, while satellite imagery, shipping records, and maritime analysis traced the actual aviation fuel from Bandar Abbas, Iran, to Myanmar. Reuters also independently matched delivery dates and quantities in documents obtained by Justice For Myanmar with Iranian aviation fuel shipment records.

The findings appear to point to an organized, state-directed system of sanctions evasion and trade fraud involving corporate structures and financial channels across Myanmar, Thailand, Singapore, the United Arab Emirates, and Iran.

Justyna Gudzowska, Executive Director at The Sentry, said:

“Justice For Myanmar’s findings appear to show how the junta is adapting its trade and financial networks to evade scrutiny and keep aviation fuel flowing for the airstrikes that continue to massacre civilians across Myanmar. 

Governments cannot respond by targeting one company or one junta official at a time. They need to target the junta’s entire aviation fuel procurement networks, including the institutions and enterprises and associated companies, financiers, and intermediaries that enable these transactions. They should also coordinate sanctions on key entities identified in the report and adopt comprehensive restrictions on fuel exports to Myanmar.

Aviation fuel remains essential to the junta’s escalating use of air power against civilians and civilian infrastructure. Existing sanctions have increased the risks and costs of supplying the junta, but significant gaps remain, and enforcement has not kept pace with the network’s evolving methods.”

Reuters’ independent reporting further shows how these networks combine false commodity and origin declarations with opaque financial and shipping arrangements. Sanctions enforcement needs to follow the entire transaction—from the source of the fuel and the vessels carrying it to the intermediaries, banks, and companies handling the payments.

According to Reuters, the junta’s aviation fuel network is not only evading scrutiny in Myanmar; it is connecting sanctioned and high-risk networks across borders. Iranian aviation fuel was disguised through false documentation and routed through commercial and financial intermediaries before reaching Myanmar. The transactions sit at the intersection of two US sanctions regimes: measures targeting Myanmar’s aviation fuel sector and broad sanctions on Iranian petroleum products, including aviation fuel.

In response to JFM’s and Reuters’ findings, The Sentry calls for three immediate steps:

1) Expand and coordinate sanctions.
The US, EU, UK, Canada, and Australia should target the junta, its leaders, and its full aviation fuel procurement network, including key junta-controlled entities and individuals such as the FESC Chair Nyo Saw, NEPAS and its junta shareholder, Myanma Petrochemical Enterprise, intermediaries, and related individuals and entities. They should also consider designating Myanmar targets under Iran sanctions regimes. 

2) Investigate the trade and financial networks.
Authorities in Thailand, Singapore, and the United Arab Emirates should investigate the companies, banking channels, commodity declarations, and other transactions identified by Justice For Myanmar and take enforcement action where domestic laws or regulations have been violated.

3) Strengthen private-sector due diligence.
Banks, fuel suppliers, terminals, insurers, and shipping companies should look beyond sanctions lists and scrutinize beneficial ownership, proxy companies, unusual payment routing, commodity misclassification, technical specifications, pricing anomalies, and vessel movements and inconsistencies in AIS or destination data in Myanmar-linked fuel transactions. They should also take into account the reputational costs of enabling mass atrocities against civilians, whether directly or indirectly.

The junta’s aviation fuel network is evolving to evade sanctions. The international response must evolve with it. Coordinated sanctions, stronger enforcement, and enhanced financial and trade due diligence are needed to disrupt the supply chains enabling the junta’s continuing airstrikes.

Media Contact: Kria Sakakeeny, [email protected]