The Myanmar military is relying extensively on French-manufactured Avions de Transport Regional (ATR) aircraft to transport troops, arms and supplies for its combat operations, as it commits war crimes and crimes against humanity with impunity.  

Evidence obtained by Justice For Myanmar – including photographs, budget expenditure documents, contracts for the purchase of aircraft, maintenance, repair and overhaul files, meeting records, public information and details from individuals who have first-hand experience – provides new details into the Myanmar military’s acquisition and use of ATR turboprop aircraft, involving a global network of companies.

Private Myanmar military arms brokers and commercial airlines have transferred ATR aircraft to the military, in some cases hiding the end user in an apparent attempt to evade sanctions. Myanmar, European, US, Israeli and Singaporean companies have also assisted the military through the supply of parts and the provision of maintenance. One Myanmar airline has leased at least two ATR aircraft from the military, providing it with a source of revenue.

ATR is a Franco-Italian aircraft manufacturer, operating as a joint venture between Airbus (France) and Leonardo (Italy). Headquartered in Blagnac in the outskirts of Toulouse, in southern France, ATR is a major manufacturer of aircraft for regional aviation, providing turboprop-engined aircraft with a capacity of up to 78 seats. As ATR itself has advertised, the turboprop aircraft it manufactures are particularly useful for accessing challenging airfields, including those with limited infrastructure such as narrow or unpaved runways – well-suited for remote parts of Myanmar. As of August 2022, ATR 42 and ATR 72 aircraft models accounted for 28 of Myanmar’s 45 registered commercial aircraft.

The ATR aircraft currently in the possession of the Myanmar air force are being used in a context in which the military is committing repeated grave violations of international human rights and humanitarian law with total impunity. Since February 2021, the junta has used aircraft to conduct indiscriminate attacks on the people of Myanmar, including through the targeting of civilians and civilian infrastructure such as schools and hospitals, killing scores of people and causing large-scale displacement.

Publicly available information and Justice For Myanmar sources confirm the frequent deployment of ATR aircraft by the Myanmar military:

• Flight data obtained through ADS-B exchange confirms the regular deployment of the military’s ATR aircraft. For instance, MSN 927 was deployed on January 5, 2024, flying over northwestern Myanmar, a region where the military has been committing war crimes and crimes against humanity.
• A 2024 video posted on TikTok by a soldier shows a troop deployment to Chin State in an ATR military aircraft.
• On January 24, 2024, the Myanmar military flew back 92 soldiers who had fled to Mizoram, India, with an ATR aircraft.
• On 18 May 2022, the Myanmar air force deployed an ATR-42 aircraft for aerial reconnaissance while it conducted a coordinated air-to-ground strike in Thae Baw Boe south of Myawaddy.
• The military has modified two ATRs as maritime patrol aircraft with advanced capabilities for intelligence, surveillance and reconnaissance.
• Eyewitness accounts from reliable sources also confirm that ATR aircraft have been used by Myanmar’s air force to transport troops and weapons, not only to military air bases, but also to civilian airports under the control of the Department of Civil Aviation (DCA) of the Ministry of Transport and Communications. Since the attempted coup in February 2021, the DCA has been illegally under junta control.
• The military has deployed repurposed ATR aircraft to civilian air fields including Sittwe, Myitkyina, Lashio, Bhamo, Loikaw and Keng Tung. People with direct experience of Myanmar air force operations have reported that ATR civilian passenger aircraft have also been spotted regularly in areas where there has been heavy fighting and sustained military operations, and where civilian flights have been suspended.
• Local Myanmar media reported as early as December 2021 that the Myanmar military was using the airport at Loikaw, the Karenni capital, to deploy troops and weapons, including on commercial flights with ATR aircraft.

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The use of ATR aircraft for military end-use purposes in Myanmar raises concerns as to the seemingly total absence of due diligence by companies that have supplied ATR aircraft, parts, components and associated maintenance services, despite European Union (EU) restrictive measures that prohibit the export from the EU of equipment for military end-use in Myanmar.

Since the military’s coup attempt, the military has required a significant number of critical components and spare parts for its ATR aircraft. Leaked Myanmar military expenditure documents for the 2021-2022 financial year from after the coup attempt show planned purchases of almost US$19 million in parts for the air force’s ATR fleet. Of this, US$11.96 million was for ATR 42 aircraft and US$6.97 million was for ATR 72 aircraft. Parts included multifunction computers, engine electronic control units, landing gear and radar units.

In January 2024 the USA issued a supplemental business advisory warning that “Burma’s commercial aviation sector – including services, components, and fuel – is deeply intertwined with the military’s aviation operations”. The advisory specifically cited the “roughly ten ATR aircraft” which the military uses to “move personnel and equipment around the country”, alongside the country’s commercial airline fleet of 20 ATR fixed-wing aircraft. It warned US businesses and individuals of the risk of supplying spare parts for ATR aircraft either directly to Myanmar, or indirectly via proxies in Singapore or Thailand, due to “the potential for diversion of those spare parts for use by the military”. This advisory is a welcome step but more action is urgently needed to block the Myanmar military’s continued use of ATR aircraft.

Justice For Myanmar calls on governments and suppliers to block the Myanmar air force from accessing spare and replacement parts, receiving training to flight crew and maintenance personnel, or accessing instructions needed for the continuing airworthiness of its ATR aircraft.

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The Myanmar military’s ATR enablers

The following companies have supported the Myanmar military’s acquisition, maintenance, repair and overhaul (MRO) of ATR aircraft from 2013 onwards.

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The Mingalar Aviation/Air KBZ network

According to sources with first-hand experience of the military’s use of ATR aircraft, one of the principal suppliers to the Myanmar military is Mingalar Aviation. Mingalar Aviation operated as Air KBZ until a name change in January 2024.

Mingalar Aviation/Air Kanbawza (Air KBZ) is a privately owned domestic Myanmar airline based in Yangon. According to corporate data published by Orbis, one of the Mingalar Aviation/Air KBZ directors is Moe San Aung, a former military official who has served as managing director. It was formerly part of the crony Kanbawza Group of Companies (KBZ Group), which completed its divestment from the company in December 2023, according to an announcement. The airline was taken over by 24 Hour Group, another crony conglomerate with interests that include mining and aviation fuel. 24 Hour Group also took over Myanmar Airways International (MAI) from KBZ Group, which completed its exit in March 2021.

Mingalar Aviation/Air KBZ plays a key role in the Myanmar air force’s ATR fleet through the procurement and leasing of five ATR aircraft.

Air KBZ sold two ATR aircraft to Myanmar air force that it had previously owned: an ATR 72-500 (MSN 545) transferred in 2015-16, and an ATR 72-600 (MSN 1085) that was commissioned in December 2021, according to a source with knowledge of aircraft. MSN 1085 was again registered by Mingalar Aviation in January 2024 under an apparent lease with the military. This would provide the military with a regular source of revenue from the lease.

Since 2013, Air KBZ has also leased another ATR 72-500 aircraft with MSN 658 from the Myanmar air force, providing the military with revenue from the lease. The plane was procured by the Myanmar military arms broker MWG (detailed below) for the air force, leased to Air KBZ for civilian use, and is operated as part of Mingalar Aviation’s fleet.

Air KBZ has also allowed the arms broker International Gateways Group (detailed below) to use their name in the air force’s acquisition of two ATR 72-500 aircraft from Vietnam Airlines. The aircraft were MSN 927 and MSN 939, commissioned by the air force in 2018 according to a source with knowledge of the aircraft. Vietnam Airlines did not respond to questions from Justice For Myanmar.

Air KBZ has facilitated international MRO services for MSN 658, despite it being owned by the air force. In 2018, the French MRO provider Sabena Technics repaired the plane’s hydro mechanical brake in France and the engine manufacturer Pratt & Whitney, a subsidiary of the USA-based RTX Corporation, shipped an engine to Myanmar for the plane. The plane also had its engine overhauled in France in 2016 by the then Airbus subsidiary Vector Aerospace (now part of StandardAero Aviation Holdings). Up until 2016, MRO services for the plane were provided by Airwork under an 8 years check agreement. Airwork is a global aviation company based in New Zealand that provides aircraft leasing and MRO services.

Sabena Technics signed a deal with Air KBZ in 2016 for global support of the airline’s fleet of ATR 72-500 and ATR 72-600 aircraft which remained in place until at least 2021. This has enabled Air KBZ to benefit from Sabena Technics’ services for repair and overhaul of rotable components, and it may have also supported other Myanmar air force ATR aircraft.

Sabena Technics, Pratt & Whitney, StandardAero and Airwork did not respond to questions from Justice For Myanmar about their business in Myanmar.

The Singapore company ATR Eastern Support has also made several shipments to Air KBZ in 2020. The countries of origin of these supplies includes Germany, Italy, Canada, the USA and France.

Corporate records by ATR Eastern Support, a fully owned subsidiary of ATR International S.A.S., confirm that the company continued to supply parts to Myanmar after the military’s coup attempt. In 2021, ATR Eastern Support’s trade receivables for Myanmar were US$10.87 million, and they fell to US$438,659 in 2022. ATR Eastern Support’s financial statements did not disclose the recipients or end users in Myanmar and ATR did not respond to questions from Justice For Myanmar.

ATR did not respond to questions from Justice For Myanmar.

The high risk of diversion to the military raises doubts over the effectiveness of the export control mechanisms the above countries had in place at the time.  

In addition, Air KBZ’s sister airline, MAI, which was also led by Moe San Aung until 2021, has cooperated with the junta. In February 2024, MAI and Russia’s S7 airlines signed a codeshare agreement to boost traffic between the two countries. MAI also has a codeshare agreement with Aeroflot, a Russian state-owned airline that is sanctioned by the UK for “obtaining a benefit from and supporting the Government of Russia”.

MAI launched direct flights to Russia in September 2023 and the airline has transported military generals to Russia, where they regularly negotiate arms deals.

A photo posted by MAI on its official Facebook account on March 24, 2024 confirms the airline’s reception of an ATR 72-600 aircraft (MSN 1039, registered in Myanmar as XY-AMU) previously in service with Australian airline Virgin Australia. This aircraft was transferred to Myanmar despite the growing public evidence of MAI and 24 Hour Group’s links to the junta.  

An MAI spokesperson wrote that “any questions about Mr. Moe San Aung’s role in MAI are irrelevant since he has not since the transition to the current owners was completed, effective 2019.” However, an extract on MAI from the Myanmar corporate registry confirms that Moe San Aung was a director until February 15, 2021.

The spokesperson also wrote that, “as a commercial airline, we cannot comment on your assumptions or claims about Myanmar officials' travel or their purpose for travel, as we have travelers from various travel segments & types who travel due to flight schedules and network connectivity to/from Myanmar.”

Mingalar Aviation did not respond to an email detailing its business with the Myanmar military.  

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The KT Group network

KT Group is a Myanmar crony conglomerate that brokers arms and has land leases with the military and its conglomerate Myanma Economic Holdings Limited (MEHL). One of its trading subsidiaries, MWG Limited, registered in the British Virgin Islands, has brokered the acquisition of several aircraft used by the Myanmar military, including ATRs, according to leaked documents and correspondence between MWG and the Myanmar air force. KT Group and MWG are led by Jonathan Myo Kyaw Thaung, who was sanctioned by the USA in 2022 for his role in providing financial and material support to the Myanmar military.

Documentary evidence confirms the existence of contracts between MWG and the army’s directorate of procurement in 2013 for the purchase and delivery of two aircraft (MSN 602 and MSN 658). The leased aircraft were delivered to the Myanmar air force immediately after their arrival in Myanmar and have since been reconfigured into military transport planes.

In addition to the ATR aircraft, MWG also arranged the purchase of two Fokker aircraft from an arm of KLM Royal Dutch Airline for the Myanmar military in 2017. The Fokker-70 aircraft are reportedly still being used by the Myanmar military for VIP travel by coup leader and war criminal Min Aung Hlaing.

Shipment records obtained by Justice For Myanmar also confirm that MWG has continued to import aircraft spare parts at least through 2020 from the Singaporean companies EAM Global Logistics, Meridian Aviation Services and Dowell Airline Support/Dowell Aviation, which could support the air force’s ATR fleet. EAM Global Logistics and Dowell Airline Support did not respond to questions from Justice For Myanmar.

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The International Gateways Group network

International Gateways Group (IGG) is a notorious Myanmar military arms broker that has supplied millions of dollars in military goods, including two ATRs. It has been sanctioned by the USA, UK, EU and Canada. In a possible attempt to evade sanctions, the group’s main company International Gateways Group of Company Limited recently changed its name to Nay Pyi Taw Sugar Mills Company Limited. The group is led by Naing Htut Aung.

IGG procured two ATR 72-500s from Vietnam Airlines that were delivered to Myanmar in 2018. Both were purchased under the Air KBZ name, although they were never operated by Air KBZ.

IGG has also provided MRO services for several ATR aircraft in the Myanmar air force’s fleet, including larger operations that require the replacement of key components, after group subsidiary Gateways Hongkong Company Limited won a military tender in 2017. Under the deal, Gateways Hongkong helped overhaul and repair three ATR-42 aircraft in active use by the Myanmar military (two ATR 42-320 models with MSN 178 and MSN 159 and one ATR 42-500 with MSN 602), in collaboration with ST Aerospace (currently operating as ST Engineering Aerospace) and ATR Eastern Support in Singapore. Gateways Hongkong was liquidated following the military’s coup attempt.

ST Engineering denied any ongoing sales, agreements or licences with the Myanmar military’s directorate of defence industries or International Gateways Group. “We abide by all applicable laws and observe all UN sanctions and treaty obligations to which Singapore is a signatory in the conduct of our business,” an ST Engineering spokesperson responded in an email.

Export data from Singapore confirms that in 2020, ATR Eastern Support shipped parts for ATR aircraft on numerous occasions. The consignee of these shipments – some containing products from the USA, France and Italy – was Myanmar Consultancy Co. Ltd, which is part of the IGG network and was formerly owned by Naing Htut Aung.

US-made parts included cathode ray tubes for the electronic flight instrument system, a flight deck instrument display system, anti-icing controllers designed for activation before the aircraft enters icy conditions and unspecified aircraft spare parts. French-made parts included emergency batteries and current limiters.

In 2019, International Gateways Group was publicly named by the UN Independent International Fact-Finding Mission on Myanmar for its donations to the Myanmar military in support of its “clearance operations” against the Rohingya. ATR Eastern continued to ship parts to International Gateways Group despite its complicity in genocide and the fact it and Myanmar Consultancy do not operate an airline, which should have raised red flags as to the end user.

Myanmar Consultancy has a long relationship with the Myanmar military. In 2015, Myanmar Consultancy proposed to supply guided cluster bombs for A-5 IIK aircraft to the office of the chief of the Myanmar air force. In 2013, Myanmar Consultancy proposed the modification of an ATR 42-500, MSN 602, to a maritime patrol aircraft for the Myanmar air force. Following the military’s coup attempt, Myanmar Consultancy extended its registration with the army’s directorate of procurement to continue its arms brokering business.

In 2023, IGG was named by the UN Special Rapporteur on Myanmar for providing the military with ATR 72 spare parts following its coup attempt.  

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The Htoo Group network

Htoo Group is a crony conglomerate led by Tay Za that has sold the military at least one ATR aircraft and provided MRO services for at least six of the air force’s ATR aircraft.

In 2015-2017, Htoo Group subsidiary Air Bagan sold an ATR 42-320 (MSN 159) to the Myanmar military. A 2015 leaked letter from Air Bagan to the Myanmar air force commander-in-chief proposed to sell the plane for US$3 million and public sources show the aircraft registered to the air force from 2017. The aircraft became one of the military’s two maritime patrol aircraft (MPA) after it was modified by the Israeli defence giant Elbit Systems, according to leaked documents and sources with knowledge of the transactions. Elbit technicians travelled to Myanmar during that period to work on the aircraft modifications. At the time, Star Sapphire Group of Companies was the sole representative of Elbit Systems in Myanmar and the relationship led to an application for a criminal investigation in Israel.

A spokesperson from Elbit Systems responded, “Elbit Systems Ltd. had limited business in [Myanmar] up until 2016, after which no business was initiated by Elbit. All activities were subject to licenses issued by the Israeli Ministry of Defence (IMOD) and Elbit has terminated its activities even prior to the formal suspension of the licenses (which were revoked by the IMOD in 2017).”

Air Bagan also provided support for the military’s ATR 42-500 model MSN 602.

While Air Bagan is no longer operating as a commercial airline, the company remains registered in Myanmar.

Prior to the military’s attempted coup on February 1, 2021, regular maintenance of some of the air force’s ATR aircraft were carried out by the Htoo Group subsidiary Yangon Aircraft Engineering Aircraft Company (YAECO) under two-year to eight-year check agreements. YAECO claims to be the sole MRO provider for all ATRs in Myanmar, authorised to provide up to 8 year checks.

YAECO’s Chief Operating Officer, Thet Oo Maung is a former engineering officer of the Myanmar air force, according to his LinkedIn profile. A 2018 Myanmar air force meeting note, previously published by Justice For Myanmar, shows that Thet Oo Maung and YAECO’s maintenance operations director, Soe Naing, met with the air force and directorate of procurement in April 2018 to discuss the provision of services, including the conversion of at least two ATR-72 aircraft for "Cargo Conversion and Troop Seats with Containers Version”. According to the document, the modification would be done in two stages. In stage one, the aircraft would be converted to "Full Cargo", and in such a change, the overhead bin, ceilings, side walls, partitions and galleries originally installed would be removed from the cargo kits, and cargo nets would be installed with a reinforced floor panel with a resistance of 400 kg/m2.

In stage 2, “troop seats and containers installation", 54 foldable troop seats and related accessories would be installed.

Soe Naing is also responsible for the maintenance operations of some of the Myanmar air force’s ATRs, including MSN 658 and MSN 545. According to reliable sources, Soe Naing had regular communications with Myanmar air force officials until at least 2020 regarding MRO services for its ATR aircraft.

A leaked letter from the commander in chief of the Myanmar air force dated October 2017 also confirms that YAECO was among three bidders for the overhaul, repair and exchange of key components for three of the Myanmar air force’s ATR aircraft.

Following the military’s 2021 coup attempt, Htoo Group and Tay Za were sanctioned by the USA, UK and the EU. Pye Phyo Tay Za, who plays a leading role in Htoo Group and YAECO, has also been sanctioned by the US, UK and Canada. The UK listed Pye Phyo Tay Za’s role in YAECO as a reason for its sanctions designation. Htoo Group and Air Bagan were sanctioned by Canada in 2012.

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Myanmar National Airlines (MNA)

Myanmar National Airlines (MNA) is a state-owned airline that was illegally seized by the junta following the military’s coup attempt. It operates a fleet of ATR-72 aircraft and has supplied aircraft for the military.

Two ATR 72-500 aircraft in use by the Myanmar air force were transferred by MNA in 2013 (MSN 781) and 2014 (MSN 765). According to a leaked document, the air force intended to convert these aircraft for VIP transport. Justice For Myanmar has not been able to ascertain the status of these plans. A third aircraft, ATR 42-320 (MSN 178) was transferred to the air force in 2016 and was modified to a maritime patrol aircraft with the support of Elbit Systems.

MNA also uses its ATR fleet for military transport. For instance, on April 7, 2024, an MNA ATR aircraft was used by the military junta to repatriate troops and cargo from Thailand, after resistance victories in Myawaddy township.

MNA has long been closely associated with the Myanmar air force through the fact that many of its pilots are ex-air force and the company has had close links to senior air force figures. MNA’s former directors include Linn Htet – the Singapore-based nephew of former Myanmar air force chief Maung Maung Kyaw. As Reuters has reported, Linn Htet previously represented major U.S. aviation brands like Bell and Cessna in Myanmar and is involved in all aspects of Myanmar’s aviation sector, both civil and military.

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Other Myanmar airlines

The Myanmar air force is supported by personnel from other civil airlines for the maintenance of navigation software in its ATR flee. This is done unofficially, in an apparent attempt to evade sanctions, according to a source with direct knowledge of the arrangements. Staff of these companies assist air force personnel to update the navigation software every 18 months.

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The Miya Win network

Myanmar air force pilots are trained in Myanmar with the assistance of a flight simulation training device (FSTD) supplied to the military by the Austrian company AXIS Flight Training Systems GmbH. The flight simulator was procured by the Myanmar military arms broker Miya Win International Company Limited. Miya Win is now under sanctions and export controls imposed by the USA, Canada and the UK.

Flight simulator training devices provide pilot training at both instructor level and student level and have been used by military pilots to build their ATR piloting skills by simulating flight conditions that pilots may encounter.

To help conceal the Myanmar air force as the true end user of this device, a company called Asia Golden Phoenix Consultancy Services was listed as the end user, operator and training provider. Asia Golden Phoenix is linked to Miya Win through a common director and shareholder, Nay Htut Win.

The simulator received a licence from the European Aviation Safety Agency (EASA) in February 2020. Following the purchase of the simulator by Asia Golden Phoenix, AXIS staff travelled to Myanmar to install it. This is confirmed by both sources with first-hand experience of the Myanmar air force and photographic evidence obtained by Justice For Myanmar. The role of AXIS staff in the set-up and installation was later confirmed by AXIS in an email to Justice For Myanmar.  

AXIS told Justice For Myanmar that the simulator was procured by Miya Win International, and that Asia Golden Phoenix was listed as the end-user. The company also confirmed that it continued to provide parts and support to Miya Win International after the acquisition, but declined to disclose the last date it supplied parts for the simulator.

The FSTD was installed on military land close to Yangon airport in Mingaladon. According to a source with knowledge of the transaction, AXIS staff also provided training to air force personnel to maintain the simulator. However, AXIS denies this and claims they only provided maintenance training to Asia Golden Phoenix personnel.        

The flight simulator is a dual use item and should have required authorisation from Austrian authorities prior to being exported to Myanmar. While the flight simulator training device can be used for civilian end-purposes, its end-use in Myanmar is clearly military. EASA did not respond to questions from Justice For Myanmar regarding the simulator. However, after writing to them, EASA suspended the flight simulator’s certificate on April 25, 2022 and surrendered it a year later after.

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Cut all support for the Myanmar air force!

It is unacceptable that the Myanmar military has managed to obtain ATR aircraft, spare parts and components and MRO over a prolonged period, as it has committed genocide, war crimes and crimes against humanity with total impunity.

The fact that the Myanmar air force is the end-user of at least ten ATR aircraft identified in this investigation raises serious questions over the due diligence of export control authorities and the companies involved.

Under international standards on business and human rights – including the UN Guiding Principles on Business and Human Rights (UN Guiding Principles) – all companies, including States that control or own companies, have a responsibility to respect human rights. These standards provide companies in the aviation industry with the baseline for identifying and minimising human rights risks related to the products and services that they provide.

To know and to show that they meet their responsibility to respect human rights, companies should identify, prevent and mitigate adverse human rights impacts through due diligence. When it comes to identifying and assessing human rights risks— the first step of human rights due diligence—international standards such as the UN Guiding Principles require companies to maintain a wide view of possible impacts across their full value chain, including as it relates to end-user and end-use. In practical terms, this means identifying the human rights risks related to the full range of a company’s business activities and relationships. In the Myanmar context, companies are expected to conduct heightened due diligence because it is a known conflict situation.

International companies identified in this investigation should take immediate action to halt any ongoing or committed business with Myanmar arms brokers or civilian airline companies that have facilitated the transfer of ATR aircraft to the Myanmar air force and provided MRO for these aircraft.

Considering the apparent poor (if any) end-user due diligence conducted, there are serious doubts as to the willingness of the companies identified to take measures to ensure that the Myanmar air force can no longer use ATR aircraft in the commission of atrocity crimes.

Legal prohibitions on doing business with the Myanmar military or arms brokers would have applied to some of the exporting authorities identified in this investigation. For instance, since 2008, EU restrictions require countries to “exercise special caution and vigilance in issuing licences, on a case-by-case basis and taking account of the nature of the military technology or equipment, to countries where serious violations of human rights have been established by the competent bodies of the United Nations, by the European Union or by the Council of Europe”. This includes dual-use goods that might end up in the hands of the military or police or militias under its command.

Reports by the UN Fact-Finding Mission and the UN Special Rapporteur on Myanmar have clearly documented the military’s commission of international crimes and serious human rights violations, demanding careful assessments before granting export licences. Pursuant to the UN Guiding Principles, it is incumbent on States to implement their respect for international human rights standards in ways that recognise their influence on companies with multinational operations. Where they can exercise influence, such as through conducting enhanced due diligence on the granting of export licences, they must. This enhanced due diligence includes compliance with existing international, autonomous, and secondary sanctions, with avoiding breaching international criminal law, and with compliance with international human rights treaties to which the State is a party.

The EU has also restricted supply and assistance to the Myanmar military through restrictive measures. In April 2018, the initial list of prohibited items was expanded to include dual-use goods through Council Decision 2018/655. The direct consequence of these measures is that EU companies are not allowed to sell or export certain products or provide certain services capable of being used in the military context. This includes the prohibition of indirect transfers via third parties, such as brokers. Consequently, companies have a duty to research other buyers or lessees to ensure that they are not supplying the Myanmar military.

Authorities in Austria and France in particular should investigate whether the companies identified in this investigation have complied with the EU’s restrictive measures on Myanmar. Singaporean export control authorities should investigate whether companies operating in their territory, including ATR Eastern Support, EAM Global Logistics, Meridian Aviation Services and Dowell Airline Support, have complied with applicable export controls in their dealings with Myanmar entities. Shipments of ATR spare parts from Singapore to the Myanmar military were also identified by the UN Special Rapporteur in his 2023 report, the Billion Dollar Death Trade. Where breaches can be proven, consideration should be given to the range of administrative, civil, or criminal penalties that can be enforced to deter continuous and future breaches of autonomous sanctions, export controls, anti-money laundering and counter-terrorism financing laws, and other domestic criminal laws.

Additional sanctions should urgently be imposed by the EU, UK, USA, Canada and Australia on the groups of companies supporting the Myanmar military’s ATR fleet, including Miya Win International, KT Group, International Gateways Group, 24 Hour Group, Htoo Group, as well as the junta-controlled Myanmar National Airlines. Where entities are already sanctioned, the companies and individuals who provide them the many benefits of access, labour, technical services, assets, liquidity, goodwill, and connections should have sanctions breaches enforced against them in the jurisdictions that own those sanctions.

Singapore needs to take action to block all Myanmar military arms brokers from operating in its territory. Tay Za of Htoo Group and Naing Htut Aung of International Gateways Group continue to operate in Singapore, despite sanctions imposed on them by Singapore’s allies.

Justice For Myanmar calls on all governments to take urgent action to ensure that the Myanmar air force can no longer access spare and replacement parts, receive training to flight crew and maintenance personnel, or access instructions needed for the continuing airworthiness of the ATR aircraft that it operates. These measures should include prohibitions for type certificate (TC) holders – including ATR itself, engine manufacturers and other equipment manufacturers – and approved parts distributors and MRO providers from supplying any of the companies identified in this investigation as enabling the Myanmar air force’s use of ATR aircraft with:

• approved airworthiness and operational data,
• emergency airworthiness directives,
• service bulletins,
• engines, propellers, parts or appliances needed for the effective functioning of ATR aircraft,
• committed or planned technical support related to repairs, modification, testing, maintenance, or any other technical service, and
• any other relevant technical assistance and training.

The effect of new measures, the designation and enforcement of sanctions, enhanced due diligence in relation to export controls, and international and domestic civil and criminal accountability, should be to ensure that the Myanmar air force can no longer operate its fleet of ATR aircraft. The lives of Myanmar people depend on it.