Several shipments had direct links to a storage unit in Vietnam, and one fuel trading company has an office in London

Last year saw spike in deadly airstrikes from Myanmar military

‘The best way to stop the Myanmar military from carrying out lethal airstrikes is to stop all jet fuel imports into the country’ - Montse Ferrer

Evidence suggests Myanmar’s military is using new tactics to import aviation fuel after sanctions were imposed in response to airstrikes that have unlawfully killed and injured civilians, Amnesty International said today (31 January) ahead of the third anniversary of the 2021 coup.

Analysis of shipping, satellite, trade and customs data carried out by Amnesty shows significant changes to how aviation fuel entered Myanmar over the past year, with the military appearing to use new routes and rely on storage units to deliberately obscure the origins of the fuel.

The supply chain of aviation fuel to Myanmar appears to have shifted considerably since sanctions were passed by the UK, the USA, the EU and others last year. Buyers in Myanmar are no longer purchasing fuel directly but apparently relying on multiple purchases and sales of the same fuel to distance themselves from the original supplier of the fuel. Amnesty’s new research uncovers this apparent ruse.

The findings show that in 2023, as pressure built on companies and states to suspend shipments of jet fuel to Myanmar in the wake of an Amnesty Investigation into the supply chain, there was a lull in imports between January and March. In April, imports began to rise and vessel-tracking data, satellite imagery and customs and trade data show that at least six shipments entered the country between April and August last year. In August, the US passed its latest round of sanctions on jet fuel, which appears to have led to another fall in imports from September to November, after which Amnesty identified one final jet fuel shipment in December 2023. The seven shipments, comprising at least 67 kilotonnes of aviation fuel, represent an increase in shipments compared to 2021-22, year on year.

While in 2021-22 the majority of aviation fuel entered Myanmar as direct sales of fuel shipments - making it much easier to trace suppliers - in 2023 fuel appears to have been bought and sold more than once before arriving in Myanmar. In addition, vessels identified by Amnesty picked up aviation fuel at a storage unit in Vietnam immediately prior to transporting the shipments to Myanmar.

Montse Ferrer, Amnesty International’s East and Southeast Asia and the Pacific Director, said:

“Airstrikes killed or injured hundreds of civilians across Myanmar in 2023, and left many feeling nowhere is safe. The best way to stop the Myanmar military from carrying out lethal airstrikes is to stop all jet fuel imports into the country.”

“A lot can happen at a storage unit - fuel can be blended to mask its origin, sellers can lose track of buyers as fuel changes hands, storage unit owners or managers can claim ignorance once the fuel arrives at rented-out tanks.

“This could be a way to evade sanctions.”

Vietnam connection

The seven shipments in 2023 loaded aviation fuel at a small storage site called Cai Mep Petroleum terminal close to Ho Chi Minh City, which is operated by local company Hai Linh Co. Ltd. Shipments occurred in April, May, June, July, August and December.

Vessel-tracking and customs data has made it possible to identify what is likely to have occurred during these shipments. First, the original supplier sold the jet fuel to a trader. That trader would have then off-sold it - once or multiple times - but in all cases, the second-to-last sale of the jet fuel before transfer to Myanmar was from a trader to a Vietnamese company. This Vietnamese company then received the fuel at a storage terminal in Cai Mep managed by Hai Linh. After storing the fuel for anywhere between a few hours to several days, that fuel was sold to Myanmar and transported by vessel.

Amnesty has identified three shipments to Vietnam that were immediately preceded by deliveries from identifiable locations. In one case, a shipment of jet fuel in August originated (although having been transported by a different vessel) from the China National Offshore Oil Corporation terminal in Huizhou, the third-largest national oil company in China. According to vessel-tracking data and satellite imagery, two other shipments in April and May onloaded the jet fuel at the Pengerang Independent Terminals, a storage terminal in Malaysia partly owned by Royal Vopak, before it arrived in Vietnam and was subsequently transported to Myanmar (also by a different vessel).

Vietnamese customs data has also made it possible to identify the fuel traders that made the second-to-last purchase of jet fuel that transited through Vietnam. The most prominent of these is BB Energy (Asia) Pte. Ltd., the Singapore branch of privately-owned BB Energy, based in Dubai and described as “among the world’s leading independent energy trading companies”, with 30 offices around the world, including one in London. At least three of the seven shipments that transited through Vietnam before arriving in Myanmar involved this company. 

It is unclear whether the trading companies knew the fuel they were selling to Vietnamese companies would soon thereafter be taken to Myanmar. These traders sold the fuel to a Vietnamese company, which then appears to have sold the jet fuel to a Myanmar purchaser. Customs data indicates one of these companies to be Hai Linh Ltd., the company that owns and operates the storage terminal at Cai Mep. 

Offloaded in sanctioned-linked Yangon terminal

All seven aviation fuel shipments were offloaded at the former Puma Energy terminal in Thilawa area port in Yangon in Myanmar. Following Puma Energy’s departure from Myanmar in December 2022, the company sold its assets and transferred the management of the Thilawa terminal to a joint venture between Shoon Energy Thilawa Terminal Co. Ltd. (formerly Asia Sun Aviation) and a state-owned and military-controlled entity, MPE. Several Shoon Energy companies - although not the company managing the terminal - have been sanctioned by the UK, the USA, the EU and others for their role in the import and distribution of aviation fuel. Six of the seven Vietnamese shipments were transported by the Chinese-flagged oil tanker HUITONG 78 (IMO 9646479). The remaining shipment was carried out by Liberian-flagged oil tanker YIDA 8 (IMO 9936941). Amnesty was unable to confirm the current owners of these vessels.

Corporate responsibility and countries’ obligations

Companies have a responsibility to seek to prevent or mitigate adverse human rights impacts by conducting human rights due diligence. Companies should assess an entire value chain for human rights risks and harms, and companies can become directly linked to the harms - and in certain cases, liable under sanctions regimes - as a result of the irresponsible usage of the products or services they supply or manage. This includes jet fuel suppliers, fuel traders and storage terminal managers such as BB Energy, the China National Offshore Oil Corporation Hai Linh, Vopak and others.

All states have a duty to protect against human rights abuses by all actors, including by companies. This means that states must protect individuals and communities from the harmful activities of companies through effective policies, legislation, regulation and adjudication.

Right of reply

All of the companies named in this press release were contacted for comment with the exception of Shoon Energy Thilawa Terminal Co. Ltd, who were contacted by Amnesty at the time the findings regarding them were originally published. The only company to respond was Royal Vopak who said they respected human rights and claimed to have no record of a vessel birthing at Pengerang storage terminal on or about the dates Amnesty identified, a claim which conflicts with Amnesty’s evidence.