Thailand’s Anti-Corruption Cooperation Committee has issued a major update to the anticorruption standards required for private entities engaging in high-value state projects. The update, titled “Announcement re: Procurement Limits and Minimum Anticorruption Standards (No. 2),” replaces and amends key provisions of the original announcement dated September 25, 2024. Published in the Government Gazette on April 10, 2026, the new rules take effect on May 10, 2026, and apply to projects valued at more than THB 300 million (approximately USD 9.3 million). The key amendments to the anticorruption standards are detailed below. Expanded Definition of Conflict of Interest The 2026 regulation significantly broadens the scope of what constitutes a conflict of interest compared to the 2024 version, which focused primarily on basic kinship and business ties. Under the new rules, a conflict of interest includes using one’s position or authority to seek benefits for oneself, a group, close associates, or business, including through business relationships, kinship ties, or relationships with spouses or individuals living together as partners without marriage registration. The 2026 announcement also introduces specific examples that were largely absent from the 2024 text, such as holding shares in similar businesses that submit proposals for the same project, or submitting proposals for projects in which a relative, spouse, or unregistered partner is an “involved party” in that procurement. Continuous Compliance: The “Final Payment” Rule Under the 2024 rules, the coverage period for anticorruption policies was less strictly defined. The new regulation mandates a continuous timeline: policies or certifications must remain effective from the date of bid submission until the contractor receives the final payment installment under the contract. If a certification or policy is set to expire before the final payment, the contractor must submit a new self-audit form and supporting evidence to the state agency before the original

Doing business in Thailand means operating under a strict regulatory framework. From time to time, companies may receive unexpected administrative orders from government authorities that restrict their operations, impose new compliance obligations, or levy fines and penalties. When this happens, a business may challenge the order under Thailand’s administrative law system. The primary concern in pursuing administrative litigation is timing, as strict statutory deadlines apply and missing them can permanently affect a company’s rights. First Step: Administrative Appeal Many companies assume the first step is to immediately bring the matter before the Administrative Court to seek revocation or suspension of the order. Some even attempt to request an interim injunction to stop the order from taking effect. However, Thai law generally requires that the company first challenge the order through an administrative appeal with the same agency that issued it. Only after this process is complete can the matter be taken to court. Seeking an interim injunction at this stage is also not possible. This is because Thai law does not allow a standalone application for an interim injunction; an injunction can only be requested together with the underlying complaint filed with the Administrative Court. Since a court complaint cannot be filed until the administrative appeal process has been exhausted, an injunction is usually not available at the early stage. What Are the Timeframes for Administrative Appeal? Thailand applies a two-stage administrative appeal process. The appeal must first be submitted to the same authority that issued the order, which will review its own decision. If that authority affirms its decision, the appeal is then escalated to the relevant higher authority for further review. In most cases, both stages must be completed before a company is allowed to proceed to court. The timeframe for filing an administrative appeal is very

Recent high-profile corporate fraud and accounting scandals have brought increased scrutiny to governance, compliance, and enforcement practices in Thailand, highlighting the legal and practical challenges facing companies operating in the country. As regulators and law enforcement authorities sharpen their focus on financial misconduct, cybercrime, and corruption, businesses must navigate a complex and evolving investigative landscape. Tilleke & Gibbins’ investigations and compliance team examines these issues in the Thailand chapter of The Practitioner’s Guide to Global Investigations – Tenth Edition, published by Global Investigations Review (GIR). The chapter provides a detailed overview of Thailand’s legal framework for corporate investigations, offering practical guidance for companies and counsel responding to regulatory and criminal scrutiny. The Thailand chapter covers key topics including corporate criminal liability, enforcement priorities, internal investigations, data protection considerations, dawn raids, whistleblowing, cyber-related investigations, and cross-border cooperation. It also addresses emerging issues such as cybersecurity enforcement, economic sanctions compliance, and anticipated developments affecting investigations in Thailand. The chapter is authored by John Frangos, Chitchai Punsan, Alongkorn Tongmee, Michael Ramirez, Piyawat Vitooraporn, and Michelle McLeod. The Thailand chapter is available as a PDF below, and the full guide can be accessed on the GIR website.

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,