In the upmarket Yankin township of Yangon, near the iconic Inya Lake, the Golden City complex dominates the skyline.

Capped with a giant “Huawei” sign for Golden City’s biggest tenant, the buildings are home to powerful Chinese multinational corporations, including CITIC, China Railway Construction Corp, Bank of China, China State Construction Engineering and China International Telecommunication Construction Corporation. The development also boasts 221 luxury apartments, of which 147 are leased to Huawei.

But behind the veneer of gaudy gold-patterned buildings, there is a bloody fact:

Golden City channels millions of dollars to the office of the Quartermaster General, the military’s department which buys weapons of war that are used on the people of Myanmar in the commission of war crimes and crimes against humanity.

In fact, Golden City is built on land controlled by the Myanmar army.

Revenues from Golden City should be a national asset and rightfully belong to the people of Myanmar.

But payments for land has never reached the national budget.

In reality, substantial payments have been grabbed by military leaders who recently tightened their hold on Myanmar through their brutal and illegitimate February 1 coup.

The Golden City development has been built with a 50-year build-operate-transfer contract. It means the buildings are set to be fully owned by the military at the end of this contract, providing a valuable asset and a source for long-term off-budget financing.

The cost of constructing Golden City and the lease payments to the military have been raised through the Singapore Stock Exchange (SGX), creating urgent questions for Singapore’s stock market and financial regulator.

The Myanmar military is a criminal entity, in breach of international human rights and international humanitarian law and the project involves the theft of public assets.

So why has SGX facilitated the financing of these crimes? And what if any checks did it put in place to satisfy itself that this development was worthy of raising substantial funds on the Singapore Stock Exchange?

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Emerging Towns and Cities Singapore Ltd (ETC)

ETC is a Singapore-based developer and lead investor in Golden City. It holds 49% of the equity in the Myanmar-based holding company.

ETC channels their business through shell companies, with additional investment flowing from four businesses incorporated in the British Virgin Islands and whose ownership is hidden.

Golden City is ETC’s sole real estate development. The sale and rent of property in the complex is its main source of revenue.

The Myanmar-based project company Golden Land Real Estate Development, and Nature Link Co. Ltd., the Myanmar-based partners, signed a lease agreement with the Quartermaster General’s office in 2013. Days later, they were granted a Myanmar Investment Commission permit by the military’s proxy government, led by the Union Solidarity and Development Party (USDP).

Nature Link is part of Jewellery Luck, a crony-owned group of companies that develop real estate, operate hotels and have mining and forestry interests, based in Yangon’s Olympic Hotel.  

According to ETC’s 2017 annual report, the Golden City deal with the military involves a “land use premium” payment of US$6.3 million, plus annual payments of US$2.8 million, with exemptions on lease payments from 2013-16.

The total in payments to the military over the maximum 70-year terms amounts to US$191.1 million.

As of December 31, 2019, ETC had accrued US$32.185 million for land lease payments to the Myanmar army.

Golden City’s biggest institutional shareholders include Phillip Securities Pte Ltd, CGS-CIMB Securities (Singapore) Pte Ltd, Maybank Kim Eng Securities Pte. Ltd, ABN Amro Clearing Bank N.V., DBS Nominees Pte Ltd, Citibank Nominees Singapore Pte Ltd and OCBC Securities Private Ltd.

In January 2021, ETC announced a proposed placement of 1.33 billion new shares, with over half to be sold to Hong Kong-based HS Global Group Limited. HS Global Group is a holding company owned by Dalian Hesheng, which also has subsidiaries involved in the development and supply of military and police vehicles, including anti-terrorism assault vehicles, bulletproof cars and anti-riot personnel carriers. The deal would more than double ETC’s capitalisation to over $74 million SGD.

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International banks exposed to the military’s crimes through ETC

In addition to capital raised through the SGX, ETC has credit facilities with major regional banks to finance the project, including ICBC, Maybank and E.SUN.

ICBC’s credit facility involves Myanmar crony bank KBZ, which operates mining businesses with military-owned companies recently sanctioned by the US government.

The E.SUN loan is guaranteed by Ayeyarwaddy Bank, a crony bank that is part of Max Myanmar Group, which also has deep links to the military.

Myanmar’s Yoma Bank has a partnership with ETC and markets discounted loans for residential apartments in Golden City, priced from US$150,000-US$600,000 per unit.

The partnership agreement was signed by Yoma’s chief performance officer Murray McDougall and ETC’s CEO Tan Thiam Hee on September 29, 2017, at the height of the Myanmar military’s campaign of genocide against the Rohingya.

Yoma Bank’s involvement signals due diligence failings by the governments of Singapore and Norway, which purchased equity in Yoma Bank in 2020 through GIC and Norfund respectively. The World Bank's private arm, the International Finance Corporation (IFC), holds a 5% equity stake in Yoma Bank converted from a 2014 loan, and therefore the IFC's performance standards should be applied in Yoma's business activities.

Yoma Bank’s links to the Golden City project should have raised obvious red flags for Yoma Bank investors, at a time when  evidence was publicly available regarding the military’s business links to their international crimes.

Banks with credit facilities connected to the Golden City project must immediately suspend them until the project ends all payments to the Myanmar military and stolen assets are returned to the people.

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Junta chief’s family in the money: Senior General Min Aung Hlaing

In addition to lease payment, Justice For Myanmar found links between Golden City and businesses operated by the children of Junta chief, Senior General Min Aung Hlaing.

For instance, Everfit, an upmarket gym franchise owned by Senior General Min Aung Hlaing’s daughter Khin Thiri Thet Mon operates in the Golden City complex.

Senior General Min Aung Hlaing’s daughter-in-law, Myo Yadanar Htaik, has used Golden City for her entertainment business Stellar Seven, which is the Myanmar organiser for the Japan-based Miss International beauty pageant. In 2017 and 2018, the training camp for Miss International Myanmar was held at Golden City and Golden City is listed as the accommodation sponsor.

This suggests the possibility of deeper business ties to the most brutal and powerful generals.

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End business with the Myanmar military

Following the military’s illegitimate coup, there have been mass protests in defiance of the generals’ power grab. The military has cracked down, deploying soldiers and using live ammunition against peaceful protesters, killing seven and injuring many.  

Since the coup, there have been more than 696 arbitrary detentions as of February 24, as well as curfews and restrictions on peaceful assembly. The internet has been weaponised, with periodic shutdowns and widening internet censorship.

The military’s conduct is enabled by their business interests, from deals like Golden City, which provides a steady flow of unrestricted revenue. This incentivises the military to hold onto power and enables them to sustain a crackdown against the civil disobedience movement.

It is imperative that there is immediate, comprehensive and targeted action against the Myanmar military and their business interests.

The military coup is the latest unlawful act by the military, following continued war crimes and crimes against humanity and the campaign of genocide against the Rohingya. The military is a criminal entity and must be treated as such.

The SGX must act. ETC is using the stock exchange to raise funds which finances war criminals and earns revenue for Myanmar’s military junta. ETC must be suspended from trading until they cease payments to the Myanmar Army. The people of Myanmar deserve justice.

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Correction (Mar. 3, 2021)

ETC in their response to the SGX's regulatory actions, in which they announced a suspension of trading and the initiation of an independent review of their land lease payments to the Myanmar army's office of the quartermaster general, pointed out that Golden City does not have a ballroom. Justice For Myanmar incorrectly wrote that Golden City has a ballroom that was used by Stellar Seven, a business owned by Junta chief Senior General Min Aung Hlaing's daughter-in-law and we have amended this in our web feature. In fact, Golden City does not have a ballroom. Golden City was used for a training camp and was the accommodation sponsor for the Miss International Myanmar pageant in 2017 and 2018, organised by Stellar Seven.