The Karen BGF/KNA is responsible for widespread suffering in the areas it operates. Its abuses are well documented and amount to war crimes. These include the killing of civilians, rape, torture, arbitrary detention, forced portering, the use of human shields, forced conscription, forced labour, forced displacement, extortion and land confiscation. The Karen BGF/KNA is a perpetrator of the Myanmar military’s campaign of terror.

The Karen BGF/KNA is led by San Myint (who uses the pseudonym Saw Chit Thu), a colonel who has built a criminal business network with his family members and associates.

Through collaboration with the Myanmar military, the Karen BGF/KNA gained control of some territory in eastern Myanmar’s Karen State, where it has overseen a proliferation of illegal casinos, online gambling and cyber scam centres run with trafficked labour from across the world who have been subjected to forced criminality, torture and extortion.

In March 2024, the BGF/KNA was rebranded as the KNA in an apparent attempt to distance itself from the Myanmar military. After resistance forces gained control of the junta’s Light Infantry Battalion (LIB) 275 basenear the strategic Thai border town of Myawaddy in April, the KNA played an instrumental role in the junta’s counter offensive in which it retook the base. According to reports, the BGF/KNA is now providing security in Myawaddy town, supporting a contingent of junta troops to occupy institutions that include the two official border crossing bridges with Thailand. In doing so, the Karen BGF/KNA has affirmed control of its criminal business interests in the area, despite a recent notification that foreigners engaged in “online businesses” need to leave  by October 31, 2024.

Using open-source material and corporate data, Justice For Myanmar has investigated the Karen BGF/KNA’s corporate structure and main players in its criminal business network. The investigation utilises corporate records from Myanmar from 2022-3 (before the junta restricted access) and Thailand and Hong Kong from 2024, leaked Myanmar tax and corporate filings, including records released by Distributed Denial of Secrets, social media posts from Karen BGF/KNA members and their associates, social media posts from and about cyber scam victims, company websites, satellite imagery, and civil society and media reporting.

Despite the Karen BGF/KNA’s continued human rights abuses and international criminal law violations and involvement in transnational crime, only the United Kingdom has imposed sanctions on just two BGF/KNA individuals and one of their business associates.

Justice For Myanmar calls on governments to urgently impose coordinated sanctions against the Karen BGF/KNA and its network of companies and individuals, including San Myint and his family.

Governments in the region should take action against their citizens, residents and registered companies who are perpetrating, enabling and benefiting from the transnational crimes and human rights violations committed in Myanmar. Depending on the degree of involvement, this can include denial of licences and permits, deregistration from company registers and stock exchanges, visa bans, administrative penalties, closure of bank accounts and disconnection from utilities, sanctions, and criminal prosecutions.

Family business?

The Karen BGF/KNA is led by San Myint (also known as Saw Chit Thu), a 54-year-old who holds the rank of colonel and is the militia group’s general secretary and “senior advisor”.

San Myint was formerly part of the KNU’s Special Battalion 101 and then became a leading figure in the splinter group, the Democratic Karen Buddhist Army (DKBA), which signed a ceasefire with the then military junta. In 2010, the DKBA was transformed into a “Border Guard Force” under the Myanmar military’s Directorate of People’s Militia and Territorial Forces.

In exchange for integrating into the Myanmar military’s command and providing battlefield support, San Myint, his family members and associates have benefited from material support provided by the Myanmar military and space to build their lucrative criminal businesses. The Myanmar army in return has benefited through revenue from BGF organised crime.

The Karen BGF has also profited from revenue in the systemically corrupt military conglomerate Myanma Economic Holdings Limited (MEHL), with each BGF battalion holding shares, as revealed in a leaked shareholder report from 2010-11 published by Justice For Myanmar.

The Karen BGF consisted of four military regions with a total of 13 battalions, all of which agreed to the KNA rebrand under San Myint’s continued leadership.

San Myint holds shares and directorships in at least five BGF/KNA companies and is able to control key militia enterprises with his family, despite past claims that he is merely a “consultant”.

San Myint has two sons who both hold the rank of major in the Karen BGF/KNA: Saw Htoo Eh Moo, aged 32, and Saw Chit Chit, aged 28. Saw Htoo Eh Moo is heavily engaged in BGF/KNA businesses, holding shares and directorships in nine Karen BGF/KNA companies and joint ventures, including two cyber scam parks. Saw Chit Chit is active in military operations alongside the junta, having commanded Karen BGF/KNA battalions in operations against resistance forces. Saw Chit Chit also holds shares and directorships in at least five Karen BGF/KNA businesses.

San Myint has one daughter, Nan Hnin Nandar Aye, aged 26, who he supported to study at TMC Academy Singapore and the University of Northampton in the United Kingdom, where she graduated from a business and management degree. Nan Hnin Nandar Aye holds shares and directorships in at least four Karen BGF/KNA businesses.

San Myint’s wife, Nan Khin Hla Thu, is involved in some of the family’s business operations, according to her social media posts, although she does not hold shares or directorships in any companies that Justice For Myanmar could identify. She also benefits from the proceeds of Karen BGF/KNA criminal activities.

When shareholdings of San Myint and his three children are combined, the family owns 50% or more of six Karen BGF/KNA businesses, based on 2022 records from the Myanmar corporate registry, before the junta restricted access:

1. Chit Linn Myaing Toyota Company Limited (65%)
2. Chit Linn Myaing Mining & Industry Company Limited (68%)
3. Dawna Thanlwin Company Limited (60%)
4. Htoo Thitsar Aung Company Limited (80%)
5. Htoo Myittar Htoo Company Limited (70%)
6. Shwe Badaythar Myaing Company Limited (50%)

San Myint and his family live a lavish lifestyle financed through their illicit businesses with the support of the Myanmar military.

There are two other key high ranking BGF/KNA members in the militia’s business network.

Saw Min Min Oo is a colonel and former Democratic Karen Buddhist Army battalion commander who plays a management role overseeing key Karen BGF/KNA companies. He serves as director and shareholder of at least seven Karen BGF/KNA businesses, although his ownership is at most 20%. He is reported to have been the managing director of the now defunct Chit Linn Mying Company Limited, although San Myint has also been publicly listedas the managing director of that company. Saw Min Min Oo is the sole Karen BGF/KNA representative on the board of Myanmar Yatai International Holding Group Company Limited, in which the Karen BGF/KNA’s 20% stake is held in his name.

Saw Tin Win is a Karen BGF/KNA major who, with his wife, Nan Myint Myint Win, control the Karen BGF/KNA companies Shwe Myint Thaung Yinn Holdings Limited and Shwe Myint Thaung Yinn Industry & Manufacturing Company Limited.

Shwe Myint Myint Thaung Yinn Industry & Manufacturing Company Limited has been contracted to import power from Thailand, powering scam centres and online casino operations in Myawaddy township (Thailand announced a suspension on the export of power in 2023 to Shwe Kokko and Lay Kay Kaw).

Saw Min Min Oo and Saw Tin Win are both co-founders of the Myanmar Industrial Raw Mineral Producers Association Incorporated, a business group established in 2019 to promote mining, with Saw Min Min Oo serving as the vice chairperson and Saw Tin Win as an executive committee member.

In December 2023, the UK sanctioned San Myint and Saw Min Min Oo, giving the reason that they bear “responsibility for, provided support for or obtained benefit from the trafficking of individuals to Shwe Kokko Special Economic Zone where they were forced to work as scammers and subject to cruel, inhuman and degrading treatment or punishment.” They are the only Karen BGF/KNA members who have been sanctioned so far and no Karen BGF/KNA company has been designated.

Over the past decade, Karen BGF/KNA territory has become a major node in a network of cyber scam centres and illegal online gambling in Southeast Asia in which criminal groups are earning billions of dollars. Karen BGF/KNA leaders profit from transnational crime through the control of land, direct ownership in real estate developments through joint venture companies, taxes, security, smuggling, human trafficking and the sale of utilities.

Cyber Scam Monitor, a project established to document and expose cyber scam operations in Southeast Asia, explains the cyber scam business model: “In some cases, large compounds have been set up to accommodate dozens of companies, in others, hotels and condos have been rented out to operators. Casinos with public facing operations also conceal online activities. In most cases, operations are controlled by gangsters and criminal elements, often with links to local elites, or at least with their tacit approval and protection.”

Yatai New City

Shwe Kokko has developed as a transnational organised crime hub through the Karen BGF/KNA’s partnership with She Zhijiang (also known as Kriang Kai Tang, She Lunkai, and Dylan She, among several other pseudonyms). She Zhijiang is a Chinese businessperson who acquired Cambodian citizenship in 2017 and was arrested in Thailand in 2022 on an international warrant and is awaiting extradition to China to answer charges of running illegal gambling operations. She Zhejiang was also sanctioned by the UK in 2023 for his links to human trafficking at Shwe Kokko.

Yatai’s website claims the project, called “Yatai Smart Industrial New City (Yatai New City) would cover an area of 130,000 acres with investment of US$15 billion and include zones for blockchain, science and technology, trade, leisure and tourism. Although the company has referred to the development as a special economic zone (SEZ), and this is repeated in various reports, it is not legally designated as an SEZ in Myanmar.

The initial agreement for Yatai New City was signed between San Myint and She Zhijiang in 2016. Source: Still from a promotional video.

An initial agreement was signed in December 2016 between San Myint and She Zhijiang, representing Yatai Philippines, followed by a project singing ceremony between the two in September 2017 at a conference of the China Federation of Overseas Entrepreneurs in Yangon. The latter was attended by the economic and commercial counsellor of the Chinese Embassy in Myanmar, Xie Guoxiang. San Myint gave a speech at the conference about Shwe Kokko and offered support for Chinese entrepreneurs to invest in Karen State.

In February 2017, She Zhijiang and the Karen BGF established Myanmar Yatai International Holding Group Company Limited (Myanmar Yatai), a joint venture company to develop the “Yatai New City” project in Shwe Kokko. Saw Min Min Oo is the sole director and shareholder on behalf of the Karen BGF/KNA. In addition to She Zhijian, Myanmar Yatai has two Malaysian directors and minority shareholders: Lim Jun Jie and Chow Tian Yu, both from Sarawak and whose residential address is listed as neighbouring apartments in the luxury DC Residensi condominium, located in an upmarket suburb of Kuala Lumpur.

Yatai describes its business as registered in Hong Kong and headquartered in Bangkok, Thailand. Its Hong Kong company, Yatai International Holding Group Limited, is still registered as of May 9, 2024, with Kriang Kai Tang (the Cambodian name of She Zhijiang) listed as the sole director and shareholder. She Zhijiang’s residential address in Hong Kong corporate filings is in the Huay Khwang district of Bangkok. The Hong Kong company was founded in January 2017 by the Chinese citizen Wang Zihao as the sole director and shareholder, whose listed address was in Hunan, which is also where She Zhijiang is from.

Yatai’s Thai company, Ya Tai International Holding Group Company Limited, was registered in December 2017 and liquidated in December 2023. The company’s sole director in December 2023 was Chalermchai Yookam, a Thai citizen and it lists one Cambodian and two Chinese shareholders. While shareholder names are not publicly available on the Thai corporate registry, it can be assumed that the Cambodian shareholder, who controlled 98% of the company, was She Zhijiang, a naturalised Cambodian citizen. The Thai company was registered at the same Huay Khwang address listed for She Zhijiang in the Hong Kong registry. However Yatai lists a different address on its website, which matches Bizotel Bangkok, a 30-room hotel in Bangkok’s Phaya Thai district. Bizotel did not respond to questions regarding the Yatai office address.

In 2018, Myanmar Yatai received a Myanmar investment Commission permit after an application in the name of She Zhijiang (under his Cambodian name Tang Kriang Kai) and Saw Min Min Oo for a total investment of US$22.5 million for the “construction, operation and leasing of high-end villas”. That year, the Karen Peace Support Network estimated that there were 10,000 people, mostly from abroad, working at the project site.

After criticism from civil society and media scrutiny regarding land confiscations, lack of transparency around the project and reports of illegal activity, the Myanmar government led by the National League for Democracy launched an investigation into the Yatai development in 2020, causing a halt in construction and pressure on the Karen BGF’s smuggling operations. However, the Karen BGF reportedly struck a deal with the Myanmar military weeks before its illegal coup attempt to take the lead in military operations in exchange for being able to continue to do business. Construction then resumed in Shwe Kokko.

Following She Zhijiang’s arrest in Thailand in 2022, Myanmar Yatai issued a statement published in the Bangkok Post and the Nation that denied the company’s involvement in criminal activities and reiterated that the company was conducting “legal real estate development” in Shwe Kokko. As evidence, the statement cited the company’s Myanmar Investment Commission permit, and that in December 2020, the Myanmar government planned to upgrade Shwe Kokko into a city.

In 2023, the UK sanctioned She Zhijiang because he “has been responsible for, provided support for or obtained benefit from the trafficking of individuals to… Shwe Kokko where they were forced to work as scammers targeting English-speaking individuals and were subject to torture, physical abuse and further cruel inhuman and degrading treatment.” Yatai respondedto UK sanctions by again pointing to their Myanmar Investment Commission permit and expressing hope that the UK would send representatives to conduct an on-site investigation into Yatai New City.

Despite She Zhijiang’s arrest and UK sanctions, Yatai continues to occupy a shop selling boxes of tea inside Mae Sot airport in Thailand. Mae Sot airport is managed by the Department of Airports of Thailand’s Ministry of Transport. The Department of Airports did not respond to questions from Justice For Myanmar regarding the Yatai shop.

Yatai shop in Mae Sot airport. Source: Department of Airports website.

Yatai operates a branded high-rise hotel and casino in Shwe Kokko which has remained operational into 2024, based on recruitment posts and a hotel Facebook page. The LinkedIn profile of the front desk supervisor describes it as a 118-room full-service casino hotel that uses the US company Oracle’s hotel management system, OPERA. Justice For Myanmar did not receive a response from Oracle regarding Yatai’s use of its software. In the absence of US sanctions, Yatai is free to purchase software from US companies.

Yatai claims that its group has total assets of around US$3 billion and over 3,500 employees. Yet, available accounts suggest that Myanmar Yatai, which holds the Myanmar Investment Commission Permit for the Shwe Kokko development, could be operating almost entirely off the books. Leaked financial statements from 2019-2022 for Myanmar Yatai show no revenue and negligible expenses that are mostly for salaries. Financial statements from October 1, 2019 to March 31, 2022, filed with the junta controlled Internal Revenue Department in 2022 and signed by Saw Min Min Oo, list minimal operating expenses that are mostly for salaries. Myanmar Yatai reported losses of 13.8 million kyat (US$9,170 based on the company’s listed exchange rate) in the six months to March 31, 2022, 26.8 million kyat (US$17,852) in 2020-21 and 40 million kyat ($US26,676) in 2019-2020. The company’s overall deficit to March 31, 2022 was only 1.07 billion kyat (US$714,944).

In the same period, Myanmar Yatai reported only one bank account in Myanmar, with the crony-owned CB Bank that was barely used. On October 1, 2019, the account, denominated in US dollars, had an opening balance of US$1 million. In that year, US$1.9 million was deposited and US$2.9 million was withdrawn in cash, of which approximately US$2.4 million was paid out as a “director contribution”. That left a balance of US$38,999.9 that remained in the company’s bank account with no further transactions up to March 2022.

There are similarly few transactions listed in Yatai’s Thai company. For instance, figures available on the Thai corporate registry for the 2022 financial year show profits of 975,000 baht (US$28,100) from revenue of 987,000 baht (US$28,500).

The Karen BGF/KNA has talked with Thai banks for financing in Shwe Kokko, although Justice For Myanmar could not confirm if any agreements were reached. In February 2020, representatives of KASIKORNBANK Public Company Limited, Bangkok Bank Public Company Limited, Krungthai Bank Public Company Limited and the state-owned Export–Import Bank of Thailand (EXIM Bank) travelled to Shwe Kokko “to explore the potential financial support for the growing economy”. Photos of the delegation posted on Facebook by Chumroen Benchavitvilai, a Thai associate of the Karen BGF/KNA, show the representatives, one wearing a Kasikorn Bank polo shirt, traveling by boat at an illegal Karen BGF-run border crossing. The same month, Benchavitvilai attended a function for Centara Hotels & Resorts in Hpa-an, where he introduced Saw Htoo Eh Moo to Thai bank representatives and Thailand’s ambassador to Myanmar, Suphatra Srimaitreephithak. Justice For Myanmar wrote to KASIKORN Bank, Bangkok Bank, Krungthai Bank and EXIM Bank regarding their trip to Shwe Kokko and asked whether they have provided financing to the Karen BGF/KNA or their associates. A representative of EXIM Bank responded, “We would like to clarify that the Export-Import Bank of Thailand has no business relationship with the group mentioned and has not provided financing for any projects in Myawaddy Township, Myanmar.” The other banks did not respond.

Thai bank representatives travel to Shwe Kokko via an illegal border crossing to discuss financing. Source: Chumroen Benchavitvilai’s Facebook page, 2020.

Yatai and the BGF/KNA profit from their involvement and support for other businesses in the “New City” development, which include cyber scam and illegal online gambling operations. Over the past few years there has been extensive reporting about the online industry in Shwe Kokko and Myawaddy township more broadly, and thousands of people have been trafficked to the area after being deceived with offers of legitimate work, then essentially imprisoned in compounds and forced to work as scammers. Many report being subject to beatings and extortion. As is the norm in regional online criminal operations, even workers who enter willingly are bound to contracts that they cannot break without paying “fines”. Many women drawn into the industry have been forced into sex work.

According to interviews with two Shwe Kokko cyber scam operation workers by Frontier Myanmar, the companies they work for are managed by Myanmar Yatai. A member of the Civil Disobedience Movement tricked into working in a cyber scam operation in Shwe Kokko told the Irrawaddy, “After you enter Shwe Kokko, you have to do a job interview with Yatai first. Only after you are approved by Yatai can you proceed to apply at online scam centres that are recruiting. No company can recruit without approval from Yatai.” Illicit drugs are reportedly freely available and openly used in the town’s cyber scam centres.

There was reportedly a lull in cyber scam and illegal online gambling operations in Shwe Kokko after the industry came under siege in northern Myanmar in September 2023. Reports indicated that it bounced back in early 2024, and the Karen Information Centre suggested that there was even growth, with operatives relocating to Karen State from Laukkai in the Kokang region. Since then, the BGF/KNA erected signs in May ordering foreigners doing “online business” around Myawaddy to leave the country or face punishment. However, it is uncertain that it will follow through on these threats.

One illegal casino in Shwe Kokko, Golden Winner, was set up and has been run by an Australian, Brian Colwell, for the Hong Kong registered Destiny Global Group/Destiny Gaming Group (DGG Asia Limited). Destiny Gaming, in which Colwell was Chief Operating Officer, describes itself as “Asia’s most comprehensive gaming management group”. Based on his LinkedIn profile, Brian Colwell worked as Chief Operating Officer for Golden Winner Casino in Shwe Kokko from December 2018 to December 2020, during which time he set up and managed the casino. He then did further stints as Chief Operating Officer for Golden Winner Casino from June to November 2022 and again a year ago.

Colwell described Golden Winner as part of the Yatai development and has suggested that the casino deals in cash. Colwell has posted numerous job ads for Golden Winner, including during the Covid-19 pandemic, writing on LinkedIn, “While most casinos are downgrading their staff manning, we are increasing due to expansion”. A job listing for a software developer for Golden Winner’s in-house casino management system that Colwell published on LinkedIn a year ago describes “periodic face to face meetings (in Manila) with stakeholders”. Manila is the residence of Destiny Gaming director and controlling shareholder Yaw Chee Cheow (Eric), who is a Malaysian citizen. In the case of Golden Winner, the involvement of Destiny Gaming helps to hide the owner of the casino. Colwell’s posts identify the developer as Golden Winner Entertainment but Justice For Myanmar could not find a company with that name on the Myanmar, Thai, Hong Kong or Singapore corporate registries. DGG Asia and Colwell did not respond to questions regarding their business in Myanmar and the ownership of Golden Winner.

Golden Winner is just one of many casinos in Karen State’s Myawaddy township. In April, member of the Thai parliament Rangsiman Rome disclosed that there were over 17 casinos in the Myawaddy area with Thai business partners, some with connections to the Thai government. He gave the example of Myawaddy Complex that he alleged is owned by former police major general. This location has also been reported as a site of online scam operations. Through its presence in Myawaddy town, along with the junta, the Karen BGF/KNA can ensure the continued operation of these casinos and a lucrative source of revenue.

A significant revenue stream for the BGF/KNA is taxes on businesses and workers. In Shwe Kokko, the BGF/KNA reportedly levies a 10% tax on businesses, plus a one-time fee of 8,890 Thai Baht on new workers, who are subsequently charged a monthly fee. After its rebranding as the KNA, a Yatai notice posted on Telegram in Chinese announced an increase in the monthly tax of workers from 1,000 to 2,000 Thai Baht.

Yatai Group did not respond to questions from Justice For Myanmar.

Yulong Bay Park and Apollo Park

The BGF/KNA is directly invested in at least two notorious cyber scam compounds through the companies Myanmar Apolo International Investment Company Limited (Apollo Park) and Yulong Bay Resort Tourism Development Company Limited (Yulong Bay Park), based on a review of corporate records and open-source data. Apollo Park and Yulong Bay Park are located by the Thaungyin (Moei) river between Myawaddy town and Shwe Kokko. Construction began on both parks in 2019, satellite images from Google Earth show, and continued after the military’s illegal coup attempt. Job posts and reports on social media indicate the parks are still operational and are the location for so-called “pig butchering” and other types of scams run with trafficked labour.

Members of social media channels used by people working in the scam industry in Myanmar have posted stories detailing detention, abuse and forced criminality at Yulong Bay Park. In a 2023 article from Chinese media Red Star News, a Chinese victim referred to as Li describes how he was lured to Yulong Bay Park after being promised a well-paid job in Thailand. After a failed attempt to escape and making a complaint to the park’s management committee, Li was handcuffed, tortured, and had money extorted from his family. Following the involvement of Chinese volunteers and a complaint to Chinese police, he was rescued and repatriated by a “local military” which likely refers to the BGF/KNA, the park’s joint owners. Li’s torturers also threatened to sell him to Apollo Park.

Online posts and video about the Yulong Bay scam operation shows an entrance with the sign “Shwe Padauk Myaing” in Burmese. In April, local media site reported that 100 Myanmar workers of the company were fired for not returning to work soon enough after they were displaced due to armed conflict. The article claimed that the company is Chinese run and operates a casino in the park.

Yulong Bay Resort Tourism Development Company Limited shareholders include San Myint’s son, Saw Htoo Eh Moo, Saw Soe Hlaing Oo, and the UK-sanctioned Saw Min Min Oo, alongside a Singapore citizen, Aw Ziyang (also known as Hu Ziyang).

While Justice For Myanmar could not find a website or social media account for Yulong Bay Park, Apollo Park has a Chinese language Facebook page with the full name of the company in Burmese and a logo. The page includes job recruitment ads, some of which bear the hallmarks of scam recruitment, as well as photos of the park that show a series of low-rise office blocks, a night club and a convenience store. One post from September 2021 in Chinese describes Apollo as a military cooperation project in a secure military administrative area.

Social media posts describe Apollo Park as a notorious scam operation and videos have circulated that claim to expose the identity of the bosses of the Apollo scam operation.

Myanmar Apolo International Investment Company Limited shareholders include Saw Htoo Eh Moo, Saw Soe Hlaing Oo, Li Chunhuan, who is a Chinese citizen from Hebei, and two residents of Kachin State: Htin Aung and Win Naing.

The Karen BGF/KNA is profiting from many other cyber scam parks through less formal business arrangements, apparent involvement in land deals and by providing security and logistical support (also see section on utilities below).

Dongmei Park

The Karen BGF is involved in the Dongmei Park (often written as Dongmei Zone in English and known as Saixigang Industrial Park when it was launched), a cyber scam park south of Myawaddy town. The conditions in the park were exposed in a 2023 New York Times feature on a Chinese man nicknamed Neo who was trafficked to the site and forced to work on cryptocurrency scams for a Chinese criminal gang after being falsely promised a well-paid translation job. He was confined to Dongmei Park for seven months. The park is described as “clearly organised around illicit activity”, with illicit drugs available for purchase and the dormitory-type buildings doubling as a brothel. Tight security prevents captives from escaping, with watchtowers and guards in military uniform and rifles stationed at the main gate.

One of the main investors in Dongmei Park is Wan Kuok-koi (also known as Broken Tooth, Yin Gouju), a former leader of the 14K Triad, a major Chinese criminal organisation and who is wanted by Malaysian police. To mark International Anti-Corruption Day in 2020, the USA sanctioned Wan Kuok-koi, Dongmei Group (listed as an alias of Dongmei Investment Group Company Limited in US sanctions) and the World Hongmen History and Culture Association which he heads. The US Treasury announcement noted that the World Hongmen History and Culture Association “is spreading across Southeast Asia” and described it as being utilised by the 14K Triad “as an effort to legitimize itself”.

Wan Kuok-koi set up the Dongmei Park venture with well-connected Malaysian citizens including Dato Dr Mashitah Ibrahim, her husband, Datuk Abdul Shakor bin Abu Bakar, Yong Mun Hong and Dato Sri Liong Kee Huat. Dr Mashitah Ibrahim is a former Deputy Minister in the Prime Minister’s Department and former United Malays National Organisation (UMNO) senator with a PhD in Islamic Shariah. She has continued to play an active role in UMNO after she began her association with Wan Kuok-koi and Dongmei Group, running in the 2022 election as the party’s candidate for the federal constituency of Kuala Kedah (she lost). Mashitah Ibrahim has described herself as “ironlady” for the Dongmei Park project in a post on her personal Facebook account. Datuk Abdul Shakor bin Abu Bakar is a former diplomat. Dato Sri Liong Kee Huat is described by the World Hongmen History and Culture Association as an advisor to Malaysia’s Ministry of Home Affairs.

Dongmei Group has a registered company in Hong Kong, Dongmei Investment Group Company Limited, which has two Malaysian directors and shareholders: Datuk Abdul Shakor bin Abu Bakar and Yong Mun Hong. The company is still registered as of May 2024, despite US sanctions on the company. As recently as 2022, Sri Liong Kee Huat has identified himself as a founder of “Hong Kong Dongmei Group”, although he is not listed in the corporate registry. While Dongmei Group has operated in Malaysia and raised funds from Malaysian investors for Dongmei Park in Myanmar, Justice For Myanmar could not identify a Dongmei company on the Malaysian corporate registry.

An analysis of images posted online show that Dongmei Group is associated with the Malaysian company Grand Commerce Network Sdn. Bhd. Grand Commerce Network is owned by Mashitah Ibrahim and Abdul Shakor bin Abu Bakar, with Ibrahim holding the controlling stake. Financial information on the company from the Malaysian corporate registry shows no revenue from 2019 to 2023 and minimal transactions that suggest the company is dormant. An exception was for the year 2020, when the Saixigang Industrial Park project was launched, with Grand Commerce Group reporting a loss of 766,586 ringgits (US$183,833) in the 2019-2020 financial year.

Although Dongmei Park has been slower to develop than others in the area, the park was envisaged as a large-scale comprehensive park covering an area of 30,000 acres in Myawaddy with an entertainment zone, hotels and office blocks. The launch was detailed in a post on the World Hongmen History and Culture Association’s WeChat account and in posts on Mashitah Ibrahim’s Facebook account.

Mashitah Ibrahim, Abdul Shakor bin Abu Bakar and Sri Liong Kee Huat travelled to Thailand and Myawaddy township on January 29, 2020, with some of their associates. One photo shows Mashitah Ibrahim and Sri Liong Kee Huat in what appears to be the Saixigang Industrial Park construction site, accompanied by Karen BGF troops.

They returned to Thailand and Myanmar the following month, with Mashitah Ibrahim posting on February 23 from Bangkok Airport that she was traveling with a group of 20 “taikos”, a Cantonese term for big brother or boss. One of the bosses was Wan Kuok-koi.

The next day, Mashitah Ibrahim posted from the foundation-laying ceremony at the project site in Myawaddy township, an event that was publicised by the World Hongmen History and Culture Association. At the ceremony, Abdul Shakor bin Abu Bakar gave a speech in which he referred to their “detailed research and market analysis” and told the crowd that Myawaddy is a “potential investment paradise”, mentioning prospects for tourism, gems, leisure and entertainment and blockchain development (in 2022, Dato Sri Liong Kee Huat and one other Dongmei Park investor launched a cryptocurrency called Meta X Dao). In another video of the foundation-laying ceremony, guests assembled on the stage, counted down in Chinese and cheered. Wan Kuok-ki was front and centre, standing between Mashitah Ibrahim and Abdul Shakor bin Abu Bakar.

Photos and video of the foundation-laying ceremony show well-armed Karen BGF soldiers standing across the stage during the proceedings, like a prop, and in the background providing security, further evidence of the militia group’s involvement in the park.

An event was also held for Dongmei Group guests at the Centara Hotel in Mae Sot.

On March 15, 2020, a launch event and “investor appreciation night” for Saixigang Industrial Park was held at the Marriott Hotel in Kuala Lumpur. At the event, four contracts for projects in Saixigang Industrial Park were signed, including with a representative of the Chinese state-owned enterprise, China Railway 21^st Bureau. A charitable donation was made to “youth club activities”, with photos showing a giant CIMB Bank cheque issued by Dongmei Group and Grand Commerce Network. The backdrop of the stage featured two logos: Saixigang Industrial Park and Grand Commerce Network. Justice For Myanmar contacted CIMB Bank and China Railway 21^st Bureau’s parent company, China Railway Construction Corporation, regarding their business links to Dongmei Group. They did not respond.

Mashitah Ibrahim, Abdul Shakor bin Abu Bakar and Liong Kee Huat did no respond to questions from Justice For Myanmar.

Jinxin Park

Jinxin Park is a cyber scam centre park located on the outskirts of Myawaddy Town, on the bank of the Thaungyin river, upstream from the 2^nd Thai-Myanmar Friendship Bridge. Social media posts describe the brutality of the park. In one, screenshots of a chat messagepurported to be from a person trapped in Jinxin Park describes people having their legs broken as punishment for trying to escape.

A video published on Douyin shows San Myint’s involvement in Jinxin Park. In the video, San Myint and other BGF officials visit the park, view construction and inspect plans. Justice For Myanmar geolocated the footage using satellite imagery of Jinxin Park. The video also shows San Myint socialising with a man purported to be Xiong Shijia, who in various social media posts is identified as the park’s boss.

Jinxin Park was established and operated by Jinxin Holding Company Limited, registered in Myanmar with two directors: Cao Guolei, a Chinese citizen from Anhui, and Shwe Htay, a Myanmar citizen with a registered address in Lashio. The company was wound up in 2022under Myanmar’s Insolvency Law but the park continues to operate.

KK Park

The Karen BGF is also linked to the notorious KK Park. A recent Deutsche Welleinvestigation found that BGF troops were providing security in KK Park, a cyber scam park where extreme human rights violations inflicted on victims lured to work in the park have been extensively documented. The United States Institute of Peace has also reported Karen BGF/KNA involvement in KK Park, as well as other cyber scam parks and “casino cities”.

Myawaddy New City

The Karen BGF/KNA have big business ambitions in Myawaddy.

In Myawaddy town, the Karen BGF/KNA’s Chit Linn Myaing business is part of the “Myawaddy New City” development with Steel Stone Group of Companies. Steel Stone Group is a Myanmar developer established under the former military junta, receiving valuable contracts including on the construction of the Yangon-Mandalay highway. Myawaddy New City is a 544-acre project that includes apartment blocks, a mall, a resort, and a hotel. It could become another Karen BGF/KNA crime hub. An October 2021 video published by Steel Stone Group shows that land has already been cleared.

The sale of plots in Myawaddy New City was launched in 2020 in partnership with iMyanmarHouse Company Limited, with a sales event held simultaneously in Yangon and Myawaddy that featured a ribbon cutting ceremony with San Myint and Saw Htoo Eh Moo. It also list plots in Myawaddy New City for sale on its website.

iMyanmarHouse is majority owned by the Australian publicly listed company, Frontier Digital Ventures. Frontier Digital Ventures did not respond to questions regarding their company’s involvement in Myawaddy New City.

Powering organised crime

The BGF/KNA extracts further profits through the sale of utilities to cyber scam and illegal casino and online gambling operations, which need stable electricity and high bandwidth internet.

In 2018, the Karen BGF company Shwe Myint Thaung Yinn Industry & Manufacturing (SMTY) signed power purchasing contracts with a subsidiary of the Thai state-owned Provincial Electricity Authority (PEA) to export electricity to Myawaddy township at three locations: Myawaddy town, Shwe Kokko and Lay Kay Kaw (Ban Le Le Ko), which is located south of Myawaddy town. There is a high demand for power from several cyber scam compounds and casino developments south of Myawaddy town and in the vicinity of Lay Kay Kaw, including Dongmei Park, KK Park and the Huanya International New City project, the latter of which has reported links to the Karen BGF/KNA and some Karen National Union figures.

Shwe Myint Thaung Yinn Industry & Manufacturing is controlled by the Karen BGF/KNA major Saw Tin Win and his wife, Nan Myint Myint Win. Notably, there was a particularly high demand for the purchase of electricity at Shwe Kokko, according to PEA data analysed by Prachatai.

Following the agreement, a Thai associate of the Karen BGF, Chumroen Benchavitvilai, who is the sole director of the Thai company Bioenergy Development Company Limited, began facilitating the implementation of grid-to-grid power to Myawaddy and Shwe Kokko. Posts on Benchavitvilai’s Facebook account up to early 2023 show the central role played by Saw Htoo Eh Moo and Saw Tin Win from the Karen BGF/KNA, as well as the involvement of Myanmar and Thai companies and cronies.

Plans posted online from a May 2022 Bangkok meeting that Benchavitvilai held with Yatai representatives and Khine Zaw, the president of Earth Group of Companies, show PEA distributing power to Shwe Kokko with the involvement of Enova on the Thai side of the border and “STMY” on the Myanmar side. Khine Zaw is the sister of Thida Zaw, wife of Tay Za, who is the chairperson of the crony conglomerate Htoo Group of Companies. STMY is likely a misspelling of SMTY, the acronym for Shwe Myint Thaung Yinn Industry & Manufacturing.

Enova Group is a Thai company engaged in engineering, procurement and construction in the electricity sector and its client list includes PEA. Benchavitvilai held a series of meetings with Enova from 2018 onwards and also accompanied at least one Enova representative on a trip to Karen State in 2020, in which he described “pooling together with Grand Myawaddy Group to get the full support for our power supply into Shwe Kokko”. Grand Myawaddy is an illegal casino in Myawaddy. Evova Group did not respond to questions regarding its business in Myanmar.

From July to September 2022, Benchavitilai held a series of meetings with the Yatai and Karen BGF leadership, as well as PEA in Mae Sot. Among other things, he discussed plans to provide an additional 40 MWe to Shwe Kokko.

Benchavitilai has also been involved in securing financing for the power project and has held multiple meetings with the Kasikorn Bank representative in Myanmar. In February 2020, Benvhavitilai held a meeting with Kasikorn Bank in Mae Sot with the arrangement of the bank’s Myanmar office to discuss support for power generation and distribution in Myawaddy and Shwe Kokko.

In June 2023, under domestic and international pressure, PEA cut the supply of electricity to Lay Kay Kaw and Shwe Kokko. As of March 2024, the Karen Information Centre reported disrupted electricity supply from Thailand.

Since 2019, Benchavivilai has been developing plans for mini-LNG off-grid power generation in Myawaddy township. Justice For Myanmar could not confirm the current status of this but if implemented, it could support cyber scam and illegal casino and online gambling operations without requiring access to the Thai or Myanmar grids. Chumroen Benchavitvilai could not be reached for a response.

The Karen BGF has an LNG business, Chit Linn Myaing Energy, which is 40% owned by San Myint’s family. The company imports and distributes LNG and has at least one gas filling station in Shwe Kokko. In 2022, one of its trucks came under attack by resistance forces. The BGF/KNA business, Shwe Myint Thaung Yinn, has an additional oil and gas trading business with retail stations on the Asia Highway.

The BGF/KNA also earns revenue in the energy sector by smuggling fuel from Thailand. After the supply of electricity from Thailand was cut, cyber scam operators and illegal casinos powered their businesses with generators, increasing the demand for fuel which the BGF/KNA could exploit.

The Karen BGF reportedly installed high capacity internet at Shwe Kokko and has been “profiting from reselling the huge bandwidth at a considerable mark-up”. In response to the threat of cyber scams and online gambling, Thailand’s National Broadcasting and Telecommunications Commission has cracked down on the transmission of signals to Myanmar from telecom towers across the border and recently inspected towers adjacent to Shwe Kokko.

Quoting a Yatai employee, Mizzima reported that there was a fibre-optic internet connection from Mytel that was being used for scam operations following the Thai crackdown on cross-border telecommunications. Mytel is a Myanmar telecoms operator under the joint venture company, Telecom International Myanmar Company Limited, whose members include the military conglomerate Myanmar Economic Corporation and Viettel Global Investment JSC, which is under Vietnam’s Ministry of National Defence.

Illicit trade  

The Karen BGF/KNA earn significant revenue through illicit trade that passes the illegal border crossings they operate along the Thaungyin river, taxing “possibly billions of dollars”annually. Profitable goods include vehicles, fuel, electronics, construction materials and alcohol, some of which are imported and distributed by Karen BGF/KNA companies. The Karen BGF/KNA also taxes people crossing at their jetties along the river.

The Karen BGF/KNA collect further fees on trucks transporting smuggled goods from the Thai border to Hpa-an and Yangon via the Kawkareik – Nabu – Htilon – Hpa-an road.

Karen BGF/KNA coffers are set to grow sharply should they maintain a presence in Myawaddy town with the junta, where they could collect a share of revenue collected from the movement of people and goods across the two official “friendship” bridge border crossings with Thailand.

The Karen BGF/KNA distributes smuggled goods through its wholesale and retail trade businesses, some of which are linked to its tourism and hospitality operations.

Tourism cartel-style

Close to the Karen State capital, Hpa-an, is Chit Thu Myaing Resort, which features a multi-story duty-free shop and an amusement park decorated with a decommissioned commercial aircraft from the crony conglomerate Htoo Group’s now defunct Air Bagan. The duty-free shop sells alcohol, tobacco, jewellery and fashion, among other things.

San Myint’s family own hot pot restaurants in Chit Thu Myaing and Shwe Kokko, and a coffee shop in Shwe Kokko. Posts on Facebook suggest the involvement of San Myint’s wife, Nan Khin Hla Thu, in the management of some of these businesses.

The Karen BGF/KNA business, Shwe Myint Taung Yinn, operates a number of retail and tourism businesses in Karen State, including a restaurant, a convenience store and a waterfall.

One Karen BGF project has been to build a cable car for U Kawidaza, a leading figure in the extremist Buddhist nationalist “Ma Ba Tha” movement and the abbot of the Zwekabin monastery. U Kawidaza has met with war criminal Min Aung Hlaing after his illegal coup attempt. The cable car project is a consortium between Chit Linn Myaing Toyota Company Limited and ZMH Group of Companies, with Myanmar Native Land Public Company Limited acting as the local contractor.

ZMH Group was established as a trading company in 1997, under the former junta, importing vehicles, machinery and other goods from Japan. It is led by Banya Zaw, who has also been involved in negotiations for the grid-to-grid power supply to Myawaddy and Shwe Kokko. ZMH and the Karen BGF set up a project company in 2018, Zwe Ka Pin Land & Cable Car Development Company Limited.

The project contracted the Swiss/Austrian Doppelmayr/Garaventa Group and the Swiss company LABAG AG for the cable cars and engineering, and the Austrian companies LCS Cable Cranes GmbH and ZTE Leitner ZT GmbH for the cable crane system.

In 2017, San Myint, Banyar Zaw and their associates travelled to the ski resorts of Mount Pilatus in the Swiss alps and Mellau in Austria, during which time San Myint signed the cable car contract, posts on Facebook show.

Photos published on social media reveal the role of the Myanmar military in supporting the cable car development, including through the use of an air force helicopter and the deployment of air force and army personnel for installation of the cable car infrastructure on Mount Zwekabin.

The cable car project has been at least partially constructed but the project company has not provided any update on its Facebook page since 2020.

In response to questions from Justice For Myanmar regarding the cable car project, a spokesperson Doppelmayr Seilbahnen GmbH stated, “due to the local circumstances we have stopped all our activities for this project in spring 2021. The Doppelmayr Group follows high international compliance standards and acts properly and with integrity when dealing with their business partners. Objective and transparent assessment criteria are applied for the selection of business partners.”

LABAG AG, LCS Cable Cranes GmbH and ZTE Leitner ZT GmbH did not respond to questions regarding their involvement in the cable car project.

Once operational, the project will generate revenue for the Karen BGF/KNA and the extremist Buddhist nationalist led Zwekabin monastery.

In 2019, Saw Min Min Oo disclosed that Chit Thu Myaing Resort and the cable car project were financed by Myanmar Oriental Bank, CB Bank and KBZ. Saw Min Min Oo only gave figures on Myanmar Oriental Bank financing, which was 3 billion kyat (US$2 million) for the resort and 7 billion kyat (US$4.6 million) for the cable car project. Google Maps list Myanmar Oriental Bank and CB Bank ATMs in the vicinity of Chit Thu Myaing Resort.

Mining

Mining has long been a socially and environmentally destructive source of revenue for the Karen BGF/KNA. Chit Linn Myaing Mining & Industry Company Limited is 68% controlled by San Myint’s family. The company held two gypsum mining licences, which are listed in the 2017-18 Extractive Industries Transparency Initiative (EITI) report, published in 2020. The licences were granted in 2014, under the military’s proxy Union Solidarity and Development Party (USDP) government. In addition, Shwe Myint Thaung Yinn Industry & Manufacturing Company Limited had one gypsum licence and one antimony licence, according to the same EITI data.

Justice For Myanmar could not confirm the current status of the mines since the junta has illegally taken control of the Ministry of Natural Resources and Environmental Conservation and Myanmar has been delisted from EITI.

Chit Linn Myaing Mining & Industry Company Limited’s disastrous mining practices can be seen in the case of its quarry operation at Lun Nya mountain in Karen State, which was a source of limestone for part of the Asian Development Bank’s East-West Corridor highway project. As has been documented by the Coalition for Human Rights in Development, residents in the area were concerned about the quarry polluting their water and went to inspect the site in November 2017. They were fired upon by Karen BGF troops who were guarding the quarry. After villagers protested, the local administrator was removed for refusing to take action against residents who had damaged a road to the quarry and legal action was initiated against eleven villagers.

‍The Karen BGF/KNA must be held accountable for their international and transnational crimes

San Myint, his family and a small number of other Karen BGF/KNA members have built an extensive criminal business network in partnership with criminal associates who hold Chinese, Thai, Malaysian, Cambodian and Singaporean citizenship. This criminal business network is a global threat. The Karen BGF/KNA and their families enrich themselves from causing widespread suffering to local communities, workers from across Myanmar and the world who are kept in slave-like conditions, and the victims of cyber scams everywhere.

The Karen BGF/KNA criminal enterprise has been built with the support and protection of the Myanmar military and the illegal junta, which profit from transnational crime. The Karen BGF/KNA commits international crimes as part of the junta’s terror campaign, such as in September 2021 when the militia used children as forced porters and human shields.

These international and transnational crimes have continued amid insufficient international action against the Karen BGF/KNA and the Myanmar military junta.

The illegal military junta is the Karen BGF/KNA’s partner in crime and cannot be a partner in tackling the proliferation of cyber scam, illegal casino and online gambling operations in Karen State. For Myanmar to build a federal democracy, the Myanmar military cartel and its allied militias must be dismantled. Perpetrators of international crimes must be held accountable.

As an immediate step, Justice For Myanmar urges governments to comprehensively sanction the Karen BGF/KNA, its leaders, businesses, directors, shareholders and enablers. While we have welcomed sanctions by the UK on San Myint, Saw Min Min Oo and She Zhijiang, far more action is needed. Justice For Myanmar calls for immediate sanctions prioritising the following individuals and entities that are key parties to the Karen BGF/KNA criminal network, in addition to sanctions against the Karen BGF/KNA as an entity in itself (download the full list of companies and individuals for targeted sanctions below):‍

Karen BGF/KNA individuals and their families

• San Myint (Saw Chit Thu)
• Nan Khin Hla Thu
• Saw Htoo Eh Moo
• Saw Chit Chit
• Nan Hnin Nandar Aye
• Saw Min Min Oo
• Saw Tin Win
• Nan Myint Myint Win

Karen BGF/KNA companies

• Chit Linn Myaing Toyota Company Limited
• Chit Linn Myaing Mining & Industry Company Limited
• Chit Linn Myaing Energy Company Limited
• Myanmar Apolo International Investment Company Limited
• Myanmar Yatai International Holding Group Company Limited
• Shwe Myint Thaung Yinn Holdings Limited
• Shwe Myint Thaung Yinn Industry & Manufacturing Company Limited
• Yulong Bay Resort Tourism Development Company Limited

We urge Thailand to block the Karen BGF/KNA and its business associates from operating in its territory, using Thai banks, and purchasing electricity and internet from providers in Thailand.

Authorities in the region, notably China, Hong Kong, Cambodia, Malaysia, Singapore and Thailand, should investigate the involvement of their citizens, residents and companies that are perpetrating, enabling and benefiting from the transnational crimes and human rights violations committed in Myanmar, and hold them accountable. Depending on the degree of involvement, this can include denial of licences and permits, deregistration from company registers and stock exchanges, visa bans, administrative penalties, closure of bank accounts and disconnection from utilities, sanctions, and criminal prosecutions.

The Karen BGF/KNA will continue their criminal businesses unless they are stopped. Justice must be served.

‍Explore the evidence

Spreadsheet with details of the companies and their directors and shareholders for targeted sanctions: Download Excel

Myanmar Yatai International Holding Group Company Limited financial statements: Download PDFs October-March 2022 | 2020-21 | 2019-20

Ya Tai International Holding Group Company Limited juristic person information: Download PDF

Yatai International Holding Group Company Limited incorporation form: Download PDF

Yatai International Holding Group Company Limited 2022 annual return: Download PDF

Dongmei Investment Group Company Limited incorporation form: Download PDF

Dongmei Investment Group Company Limited director search: Download PDF

DGG Asia Limited 2023 annual return: Download PDF

Myawaddy New City master plan: Download PDF (and satellite version)

Myanmar Industrial Raw Material Producer’s Association memorandum of incorporation: Downlaod PD‍

Update (May 22, 2024): Response from EXIM Bank added.

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