Myanmar fuel investigation exposes $109.5m in allegedly disguised imports through proxy companies
Justice For Myanmar says six aviation-fuel imports used proxy buyers and false commodity descriptions, showing why authentic documents still require corroboration.
What happened
On 26 October 2026, Justice For Myanmar published an investigation alleging that the Myanmar military administration and companies connected to its aviation-fuel supply chain used false commodity descriptions and proxy importers to conceal the real nature of six fuel shipments.
The organisation says documents from a Myanmar commerce-ministry data leak covered more than 843,000 barrels of aviation fuel valued at $109.5 million between December 2024 and November 2025. The material included contracts, invoices, corporate extracts, import permits and confidential decisions from the Foreign Exchange Supervisory Committee. In those records, aviation fuel was allegedly described or classified as high-speed diesel.
The documents named Dynamic Wave and PP Petroleum as importers. Justice For Myanmar assessed that National Energy Prime Aviation Services Company Limited, or NEPAS, was the underlying buyer. One Foreign Exchange Supervisory Committee decision authorised an import permit in Dynamic Wave’s name on behalf of NEPAS and approved the product description as diesel rather than aviation fuel. The investigation argues that the proxy structure concealed both the actual buyer and the purpose of the trade.
The network crossed several jurisdictions. The records identified sellers in Thailand and the United Arab Emirates, while contracts described fuel as originating in or moving through South Africa and Singapore. Justice For Myanmar compared those claims with price, fuel-density and port-arrival evidence and concluded that the documented commercial story did not match the underlying cargoes.
Reuters independently corroborated important elements of two shipments. For a December 2025 delivery, it reviewed a contract for purported South African diesel and a regulatory letter authorising the cargo to be labelled as diesel instead of jet fuel. Separate shipment records, trade data and satellite analysis indicated that the tanker Reef had carried Iranian jet fuel to Myanmar. Reuters also examined a May 2025 transaction in which the stated density and price were inconsistent with the diesel described in the invoice, while shipping evidence showed a jet-fuel delivery.
The contracts directed payments to an account held by the Thai seller Tawan-Oil Trading at Siam Commercial Bank. Reuters could not determine whether the bank knew the nature of the seller’s business. The bank had previously said its Myanmar-related transactions were legitimate and that it complies with anti-money-laundering requirements. Dynamic Wave, NEPAS, Tawan-Oil Trading and the relevant Myanmar and Iranian authorities did not respond to Reuters’ questions.
Why it matters for KYB teams
The distinguishing KYB issue is that a document can be authentic without the business activity described inside it being accurate. An official permit, regulator letter or invoice may genuinely have been issued, yet still use a proxy company, misleading commodity description or incorrect origin to conceal the real transaction.
Document verification must therefore extend beyond format, issuer and signs of alteration. Teams need to test whether the commercial facts make sense together: commodity code, product specification, density, price, quantity, declared origin, loading port, vessel movement, payment destination and the customer’s expected business activity. A valid-looking document should not override contradictions elsewhere in the evidence.
Corporate roles also need to remain distinct. The importer of record, contractual buyer, beneficial owner, end user and source of funds may be different parties. Connected data coverage should resolve those relationships across companies, directors, bank accounts, vessels and jurisdictions so that a newly formed proxy is not assessed in isolation from the network it serves.
This is especially important when sanctions affect a sector rather than only named entities. A company that is not itself listed may still be used to continue activity associated with a sanctioned supply chain. Changes in importer, seller, directors, commodity descriptions or shipping routes should therefore influence risk and trigger continuous monitoring.
None of those indicators proves misconduct by itself. The operational requirement is to preserve the discrepancies, record which source supports each conclusion and make the reviewer’s reasoning reconstructable. That allows a team to escalate, request more evidence, restrict activity or decline a relationship without converting an allegation into an unsupported fact.
What teams should review
Teams responsible for KYB, trade finance, sanctions and transaction monitoring should review the following:
- Can the workflow distinguish the importer of record, contractual buyer, beneficial owner, end user and source of funds?
- Are commodity descriptions and tariff codes checked against product specifications, density, price and expected market ranges?
- Are declared origins, loading ports and delivery routes corroborated with independent trade or shipping evidence when risk is elevated?
- Do newly formed or lightly evidenced companies receive enhanced review when they enter a high-risk commodity or sanctions-sensitive supply chain?
- Can teams connect related buyers, sellers, bank accounts, vessels, directors and service providers across jurisdictions?
- Do changes in counterparties, document wording, payment routes or corporate structure trigger reassessment during the relationship?
- Are official documents challenged when their contents conflict with transactional, commercial or external evidence?
- Does the case record preserve each discrepancy, its source, the reviewer’s conclusion and the rationale for escalation or approval?
