Overview
The Myanmar Accountancy Council (MAC) has issued Instruction dated 15 September 2026, reminding all accountants and designated non-financial businesses and professions (DNFBPs) of their obligations under FATF Recommendation 6 to screen clients against the UN Security Council sanctions lists (UNSCR Sanction List).
The instruction responds to the 31st update to the consolidated ISIL (Da'esh) and Al-Qaida sanctions list and related designations, and directs all reporting entities to treat sanctions screening as a live, ongoing compliance duty — not a one-off onboarding check.
What the Instruction Requires
- Screen against the UNSCR Sanction List. All client relationships, beneficial owners and counterparties must be checked against the UN consolidated sanctions lists before establishing a business relationship and on an ongoing basis thereafter. This aligns with FATF Recommendation 6 (targeted financial sanctions related to terrorism and terrorist financing).
- Monitor official updates. Entities must follow the press releases of the relevant Security Council sanctions committees, including:
- UNSC 1267/1989/2253 ISIL (Da'esh) and Al-Qaida Committee — press releases
- UNSC 1718 (DPRK) Sanctions Committee — press releases
- Act on the SC/16446 notification. The instruction references SC/16446, by which the Security Council ISIL (Da'esh) and Al-Qaida Sanctions Committee amended entries on the consolidated list. Matching names must trigger immediate freezing and reporting obligations — no transactions may proceed without clearance.
- Track updates continuously. DNFBPs are expected to update their websites, web pages and Facebook pages as new designations are published, and to ensure their screening systems reflect the latest list versions without delay.
Recent Amendments to the ISIL (Da'esh) and Al-Qaida Sanctions List
Per the attached UN committee records, recent amendments to the consolidated list include:
| Document Symbol | Date of Submission | Description |
|---|---|---|
| SC/16446 | 4 September 2026 | Security Council ISIL (Da'esh) and Al-Qaida Sanctions Committee Amends Two Entries… |
| SC/16435 | 18 August 2026 | Security Council ISIL (Da'esh) and Al-Qaida Sanctions Committee Amends 21 Entries… |
| SC/16433 | 14 August 2026 | Security Council ISIL (Da'esh) and Al-Qaida Sanctions Committee Amends Four Entries… |
The full materials — sanctions list, resolutions, committee guidelines, exemptions to the measures, press releases, monitoring team reports, ombudsperson information, implementation assistance notices and member state reports — are published on the UN Security Council sanctions website.
Practical Steps for Compliance
- Update your screening tools with the latest consolidated UN list, plus applicable domestic designations under the Anti-Money Laundering Law and related rules.
- Screen at onboarding and continuously: new list entries can be added at any time — the 1267/1718 press-release pages are the authoritative source of amendments.
- Immediate action on a match: freeze funds/assets without prior notice, refrain from dealing, and report to the Financial Intelligence Unit (FIU-Myanmar) and relevant authorities.
- Document everything: retain screening evidence, match-resolution rationale, and escalation records to demonstrate compliance to supervisors.
- Raise awareness: brief engagement teams on the SC/16446 amendment and confirm that client due diligence files reflect current ownership and control information.
Why This Matters
Failure to screen, or to act on a sanctions match, exposes firms to regulatory sanction, criminal liability and reputational damage — and risks breaching Myanmar's AML/CFT framework, which is assessed against the FATF 40 Recommendations. With the ISIL/Al-Qaida list amended repeatedly within a single quarter (August–September 2026 alone), static, outdated lists are a compliance failure waiting to happen.
Reference Links
- UN Security Council Sanctions — main portal
- 1267/1989/2253 ISIL (Da'esh) and Al-Qaida Sanctions Committee
- 1267 Committee press releases
- 1718 Sanctions Committee (DPRK) press releases
- FATF Recommendation 6 — Targeted financial sanctions related to terrorism & terrorist financing
- FATF Guidance on the Implementation of Financial Provisions of UNSCRs
Source: Myanmar Accountancy Council Instruction 15 September 2026, with the attached UN Security Council ISIL (Da'esh) & Al-Qaida Sanctions Committee press-release records (SC/16446, SC/16435, SC/16433).