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Compliance and Investigations

Compliance and Investigations

Key Contacts

Cambodia

Laos

Myanmar

Thailand

Vietnam

Jay Cohen

     +855 23 964 210

     [email protected]

John Frangos

     +66 2056 5790

     [email protected]

Prisna Sungwanna

     +66 2056 5656

     [email protected]

Yuwadee Thean-ngarm

     +95 9 772 440 002

     [email protected]

John Frangos

     +66 2056 5790

     [email protected]

Michael Ramirez

     +66 2056 5794

     [email protected]

Chuyen Hong Huu Le

     +84 28 628 45687

     [email protected]

John Frangos

     +66 2056 5790

     [email protected]

OVERVIEW

Guiding clients through cross-border compliance with deep local insight and regional expertise.

Tilleke & Gibbins’ Compliance and Investigations practice provides strategic counsel to clients navigating complex regulatory and enforcement landscapes across Southeast Asia. We advise on a broad range of white-collar matters, including internal investigations, government inquiries, criminal defense, asset recovery, and anti-corruption compliance.

Our team combines decades of experience with deep local insight and regional perspective to support clients in managing risk and responding effectively to sensitive, high-stakes issues. We regularly represent companies and executives before law enforcement bodies, criminal courts, and regulatory agencies in each respective jurisdiction, and collaborate across our offices in Cambodia, Indonesia, Laos, Myanmar, Thailand, and Vietnam to support cross-border matters.

With a strong understanding of Southeast Asian business culture and regulatory expectations, we deliver practical, commercially focused advice tailored to each client’s needs. Our commitment to integrity and excellence ensures that clients receive trusted guidance and robust representation in all aspects of compliance and investigations.

Case Studies

Experience

  • Advised a leading multinational pharmaceutical company on conducting an anticorruption compliance audit in its Thai subsidiary. Prior to the audit we provided advice to the client and its U.S.-based global anticorruption counsel on Thai anticorruption law and compliance issues in the Thai healthcare industry. After the audit, we reviewed relevant interview notes to identify potential red flags and areas for compliance enhancement.
  • Representing a world-leading manufacturer in a USD 200+ million global fraud case involving former employees in the company’s Thai operations. Among other things, we conducted employee investigations and interviews, advised on termination of employees, and liaised with the Crime Suppression Division of the Royal Thai Police, various embassies, the Anti-Money Laundering Office, and similar offices in other jurisdictions around the world.
  • Prepared anticorruption, anti-money laundering, and unfair competition compliance policies for a multinational corporation with operations in over 100 countries, including countries with extraterritorial anticorruption laws such as the FCPA. We also advised on the implementation of our client’s compliance program in Thailand, which involved tailoring our client’s global compliance concerns to the local Thai jurisdiction.
  • Worked with a leading multinational law firm, and acted as local counsel on an internal corporate anticorruption investigation at the Thai subsidiary of a global beverage manufacturer. We assisted the client in interviewing employees to gather crucial information, reviewed evidence, and advised on various issues of Thai law, including anticorruption, tax matters, property, and regulatory licenses, among others, to help the client identify if alleged bribes actually took place.
  • Assisted an industry-leading provider of computer storage technologies and solutions, with an internal investigation and review of claimed wrongdoing by a senior-level Thai administrative employee. We conducted a thorough review of preliminary investigative reports to assist in our conduct of on-the-ground employee interviews and assessments, and provided detailed summaries and reporting of our investigative findings and advice on Thai law.
  • Acted for the Thai subsidiary of a multinational plate glass manufacturer in a high-stakes criminal investigation by Thailand’s Department of Special Investigation (DSI) for allegedly purchasing black market minerals for use by its manufacturing facility.
  • Assisted a multinational project management company in conducting an internal investigation involving bid rigging on energy and infrastructure projects in Thailand and across Southeast Asia. Our investigations uncovered significant wrongdoing by an employee, which motivated the client to revamp their internal policies to avoid similar situations in the future.
  • Advised several pharmaceutical companies on anticorruption regulations related to their business dealings and procurement contracts with Thai government hospitals.
  • Advised a global food and beverage company on an extensive internal anticorruption investigation in Thailand.
  • Assisted a multinational energy services company on an internal bid-rigging investigation in Thailand.
  • Advised a European pharmaceutical company on an internal fraud and anticorruption investigation in Vietnam.
  • Assisted a global energy services firm on defending an anticorruption investigation brought by the Thai authorities.
  • Designed and implemented a compliance, ethics, and health care professional dealings program across a client’s Southeast Asia offices.

PROFESSIONALS

RELATED INSIGHTS

September 11, 2025
Thailand traditionally has had a reputation as a “crossroads” for numerous illegal activities and of the laundering of significant sums of tainted money. Member of the Financial Action Task Force (FATF)? No. Any Egmont members? Yes. Thailand’s Anti-Money Laundering Office (AMLO) is a member of the Egmont Group. Regulation The relevant law, known as the Anti-Money Laundering Act (the Act), was passed in March 1999 with the aim of combating not only the drug trade but also other illicit activities, such as corruption, criminal fraud and prostitution. There have been a number of changes and updates to the Act, the most recent one in late 2015, in which the Act was amended to include: Additional predicate offences such as offences relating to human trafficking, online gambling and offences relating to unfair practices relating to derivatives and agricultural commodity futures. Broader scope of money laundering offence. Non-disclosure obligations to applicable financial institutions and reporting entities. Compulsory training to financial institutions and reporting entities’ employees responsible to monitor and ensure compliance with the Act. Retention period. Enhanced penalties Additionally, discussions did take place mooting further changes to the Act, set out in 2020 and 2021 drafts. Proposed changes included suggestions to expand the definitions of financial institutes, predicate offences and professions, as well as to impose greater reporting and due diligence responsibilities on companies subject to the Act. However, recent amendments to the Act in 2022 only included minor procedural and substantive changes that did not materially alter or expand the Act. The most notable amendments were changes to an injured party’s rights to claim damages caused by a predicate offence and the rights of beneficiaries claiming assets seized by the government in connection with a predicate offence. Financial intelligence unit Of the total number of transactions reported to AMLO annually,
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August 1, 2025
Tilleke & Gibbins has contributed the Vietnam chapter to Corporate Governance 2025, part of the International Comparative Legal Guides (ICLG) series published by Global Legal Group. This respected guide offers comprehensive, jurisdiction-specific overviews of corporate governance laws and practices around the world. Each jurisdictional chapter follows a clear Q&A format, providing practical insights into critical issues such as: Sources of corporate governance regulation Shareholders’ rights, powers, and responsibilities Structure and duties of management bodies Stakeholder involvement in governance Transparency and reporting requirements ESG and sustainability-related obligations Cybersecurity and technology-related disclosures The Vietnam chapter was authored by Tram Ngoc Bich Nguyen, Truc Thi Thanh Tran, Dung Thi Phuong Le, and Quang Minh Vu, members of Tilleke & Gibbins’ corporate and commercial team in Ho Chi Minh City. The authors provide detailed analysis of Vietnam’s corporate governance framework, including recent developments such as the 2025 amendments to the Law on Enterprises requiring disclosure of ultimate beneficial ownership and the increasing emphasis on sustainable business practices and responsible corporate conduct. The chapter also discusses practical considerations for foreign investors in Vietnam, such as overlapping signing authorities between key company officers, enforcement of shareholders’ agreements, and disclosure obligations related to ownership and management roles. The complete Vietnam chapter is available as a PDF below. The Vietnam chapter—and the full Corporate Governance 2025 guide—are also freely available on the ICLG website.
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June 16, 2025
Thailand has amended its primary anticorruption law to provide robust new protections and direct assistance to whistleblowers. The Organic Act on Anti-Corruption (No. 2) B.E. 2568 (2025) was published in the Government Gazette on June 5, 2025, and came into force the following day. The amendment introduces a clear framework for safeguarding and supporting individuals who report graft. The amendment addresses a critical gap in the previous legislation by establishing formal mechanisms to protect and assist those who come forward with information. The key changes aim to shield whistleblowers from retaliatory legal and disciplinary actions, thereby encouraging more citizens to participate in exposing corruption without fear of reprisal. Key updates to the law are discussed below. Whistleblower Immunity The amendment clarifies and strengthens legal immunity by revising section 132 of Thailand’s original anticorruption law from 2018. Under the revised section, individuals who provide good-faith statements, information, evidence, or opinions to the National Anti-Corruption Commission (NACC) regarding offenses under its jurisdiction will be protected from civil, criminal, and disciplinary liability. This protection is explicitly extended to individuals who provide information to other state agencies tasked by the NACC to investigate corruption, such as the Public Sector Anti-Corruption Commission or the whistleblower’s own supervisors. Protection and Assistance A new section added to the law establishes a clear and swift process for activating protections. When the NACC learns that a whistleblower is facing legal complaints, criminal charges, or disciplinary action due to their report, the commission must review the matter and decide on providing protection within 15 days. If the NACC determines that the whistleblower acted in good faith, its office is required to provide immediate assistance. Legal and Financial Support Another newly introduced section outlines a wide range of assistance measures the NACC office can provide in civil and criminal cases
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June 6, 2025
As from July 1, 2025, as part of its ongoing efforts to digitalize and streamline the delivery of public services, the Vietnamese government will officially conduct administrative procedures, both online and offline, only via electronic identity (“e-ID”) accounts on the VNeID platform. In particular: Online administrative procedures carried out via the National Public Service Portal or via information systems for administrative procedures at the ministerial or provincial level are required to be implemented by using e-ID accounts only. When receiving dossiers, authorities will be required to check and verify the e-IDs of companies or individuals responsible for conducting administrative procedures. Further, it is worth noting that to complete the registration of an e-ID account for a company, the legal representative of the company must hold a level-2 e-ID account. Compliance Considerations Vietnam’s first regulation of e-ID accounts for individuals and organizations was issued in Decree No. 59/2022/ND-CP dated September 5, 2022, on electronic authentication and identification. This decree was subsequently replaced by Decree No. 69/2024/ND-CP dated June 25, 2024, which governs the same matters. Registration and operation of e-ID accounts are centralized through VNeID, a digital ID app developed by the National Population Data Center under the Ministry of Public Security of Vietnam. Although the registration of e-ID accounts for companies is not explicitly mandated by law, the absence of an e-ID account may hinder companies from completing administrative procedures, including licensing and reporting obligations. Such non-compliance could consequently result in administrative penalties. To mitigate unexpected non-compliance and administrative fines due to the lack of an e-ID account, companies should be well prepared for and implement the registration of a company e-ID account as soon as possible.
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AWARDS & RANKINGS
September 12, 2025
The 2025/2026 edition of the IFLR1000 Asia-Pacific rankings, released by International Financial Law Review (IFLR), highlights Tilleke & Gibbins’ continued excellence in financial and corporate transactional work. The firm has maintained its strong rankings across multiple jurisdictions and practice areas while achieving notable upgrades and new recognitions, reaffirming its position as a leading firm in the Asia-Pacific region. This year, Tilleke & Gibbins received firmwide rankings in key jurisdictions, including: Thailand Banking & Finance—Tier 3 Capital Markets: Debt—Tier 3 Capital Markets: Equity—Tier 3 M&A—Tier 2 Project Development—Tier 2 Restructuring & Insolvency—Tier 3 Vietnam Banking & Finance—Tier 4 M&A—Tier 3 Project Development—Tier 3 Cambodia Financial & Corporate—Tier 2 Project Development—Tier 2 Laos Financial & Corporate—Tier 2 In addition to these firmwide rankings, Tilleke & Gibbins had several standout individual recognitions, with 12 lawyers honored in the 2025/2026 individual rankings—an increase from last year’s 10. This year’s results include upgraded rankings for John Frangos and new rankings for Charupat Boon-Long, Derrick Khoo, Prisna Sungwanna, and Saravut Krailadsiri. The full list is as follows: Charunun Sathitsuksomboon—Highly Regarded, M&A, Thailand; Women Leader Charupat Boon-Long—Rising Star, M&A, Thailand (new ranking) David Mol—Rising Star, Corporate and M&A, Cambodia Derrick Khoo—Rising Star (Partner), Financial and Corporate, Thailand (new ranking) Jay Cohen—Highly Regarded, Banking, Cambodia John Frangos—Highly Regarded, Restructuring & Insolvency, Thailand (upgraded ranking) Niti Muangkote—Rising Star, Financial & Corporate and Project Development, Laos; Highly Regarded, Banking & Finance, Thailand Prisna Sungwanna—Highly Regarded, Financial & Corporate, Laos (new ranking) Saithong Rattana—Notable Practitioner, Project Development and M&A, Laos Santhapat Periera—Highly Regarded, Banking & Finance and M&A, Laos; Highly Regarded, Banking & Finance, Thailand Saravut Krailadsiri—Notable Practitioner, Thailand (new ranking) Tram Ngoc Bich Nguyen—Highly Regarded, M&A, Vietnam To see the full set of IFLR1000 rankings for Tilleke & Gibbins’ jurisdictions, please see the Cambodia, Laos, Thailand, and Vietnam pages
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September 3, 2025
Tilleke & Gibbins is honored to announce that the firm has been shortlisted for three prestigious categories at the Asialaw Awards 2025. This year’s shortlist reflects the outstanding work of the firm’s teams across Southeast Asia and highlights their ongoing commitment to delivering exceptional client service in the region. In the firmwide category, Tilleke & Gibbins was nominated for: Cambodia Firm of the Year Laos Firm of the Year In the individual category, Prisna Sungwanna was shortlisted for Laos Female Lawyer of the Year, joining an impressive field of nominees from other leading firms. The Asialaw Awards celebrate the most outstanding firms and lawyers across the Asia-Pacific region. The 2025 winners are set to be announced at an awards ceremony in Ho Chi Minh City in November. For more information on the Asialaw Awards 2025 and to browse a full list of the nominees, please visit the Asialaw website.
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July 21, 2025
Tilleke & Gibbins has been nominated for Southeast Asian Firm of the Year at Law.com’s Asia Legal Awards 2025. This nomination follows the firm’s win last year and reflects the team’s ongoing commitment to delivering exceptional legal services across the region. The winner will be announced at the in-person awards ceremony in Singapore on September 10, 2025. For more information on the Asia Legal Awards 2025, and to browse the full list of nominees in all categories, please visit the Law.com International website.
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May 13, 2025
Tilleke & Gibbins has been recognized in the In-House Community (IHC) Firms of the Year 2024, earning accolades across 19 categories in Thailand and Vietnam. The results, based on surveys of in-house counsel across Asia, reflect client perspectives on the quality and responsiveness of legal services in key practice areas. The firm received 11 Firm of the Year awards and two honorable mentions in Thailand, along with six Firm of the Year awards in Vietnam. Notably, Tilleke & Gibbins was named “Most Responsive International Law Firm” in both jurisdictions—an acknowledgment that underscores the firm’s longstanding commitment to client service. Firm of the Year – Thailand Most Responsive International Law Firm Antitrust/Competition Banking and Finance Employment Energy and Projects Intellectual Property International Arbitration Litigation and Dispute Resolution Real Estate and Construction Taxation Technology, Media, and Telecommunications Honorable Mention: Capital Markets Honorable Mention: Corporate and M&A Firm of the Year – Vietnam Most Responsive International Law Firm Employment Intellectual Property International Arbitration Litigation and Dispute Resolution Technology, Media, and Telecommunications The IHC Firms of the Year rankings are determined through responses from thousands of in-house counsel and corporate decision-makers in Asia and the Middle East. Tilleke & Gibbins is honored to receive this recognition from the clients and peers it serves across the region.
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