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,

Thailand’s Securities and Exchange Commission (SEC) has amended its digital asset regulations to permit the offering, trading, and provision of services related to tokenized environmental commodities by licensed digital asset exchanges, brokers, and dealers. This regulatory development is aimed at facilitating Thailand’s green economy and net-zero goals while diversifying the products available in the regulated digital assets market. The environmental commodities currently being traded on certain market platforms and via over-the-counter channels include: Carbon credits: Tradable certificates representing a reduction of CO₂ emitted into the atmosphere. Renewable energy certificates (RECs): Tradable proof of electricity generated from renewable energy sources. Carbon allowances: Tradable permits to emit a capped amount of greenhouse gases. The tokenization of these instruments is essentially the process of converting them into digital tokens, making it possible to list them on blockchain exchanges for trading purposes. Background Tokenized carbon credits, RECs, and carbon allowances fall under the category of utility tokens for consumption purposes or tokens representing entitlement certificates—that is, group 1 utility tokens, which are not considered financial products. The offering, trading, and provision of secondary-market services of this type of token are exempted from licensing requirements for regulated digital asset businesses under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018). Under the previous regulatory framework, licensed digital asset business operators were not allowed to provide services involving such unregulated tokens, as it was deemed to be engaging in “other businesses,” which digital asset operators generally cannot engage in without prior SEC approval. Regulatory Amendment Under the amended digital asset regulations, licensed digital asset exchanges, brokers, and dealers may now apply for SEC approval to offer services related to these tokenized assets as “other businesses,” including listing them for trading on digital asset exchanges. Apart from requiring operators to comply with the general conditions

Under Thai law, authorized directors stand as a company’s mind and will and, as such, may incur personal criminal liability for acts or omissions committed in the course of company business. When allegations surface, directors must be prepared for the practical reality that, before guilt or innocence is ever adjudicated, they could be deprived of liberty unless bail release is promptly achieved through the competent legal authority. When Bail Can Be Granted Two procedural moments trigger the need to consider bail. The first arises during the investigative phase, when a claim is lodged against a director with the competent law enforcement authorities. Upon receipt of a complaint, the assigned inquiry officer summons the director for questioning, compiles evidence, and ultimately forwards a prosecution or nonprosecution recommendation to the public prosecutor. Although the public prosecutor retains ultimate discretion to indict an accused director, the police or prosecutor may conclude that pretrial detention is necessary and may therefore apply to the court for an order to hold the director in court custody. The second moment occurs after a criminal case is filed directly with the court. This occurs once a court accepts a criminal case filed by a prosecutor against a director or, alternatively, when the court accepts a case filed by an individual for trial. For cases filed by individuals, the plaintiff presents prima facie evidence at the preliminary hearing, and the court will accept the complaint if it finds sufficient grounds, thereby conferring upon the director the status of a criminal defendant. Upon acceptance of the criminal case, the court then has the inherent authority to order custody pending trial unless the defendant secures bail release. Procedural Considerations Experienced litigants typically prepare bail security in advance and submit a bail petition at the earliest possible time. While there are

On September 1, 2025, Myanmar’s Directorate of Investment and Company Administration (DICA) issued Directive No. 106/2025 to remind all companies and organizations registered under the Myanmar Companies Law of their obligation to strictly comply with the DICA registrar’s orders, directives, and procedures. This directive highlights the importance of legal and procedural compliance in corporate filings, governance changes, and operational conduct. It also signals increased scrutiny over documentation submitted during annual returns, share transfers, and director appointments or resignations. Public companies will be subject to closer regulatory attention, and new company registrations will involve vetting of proposed directors to ensure prior compliance with applicable laws. Compliance The directive emphasizes the following points: Companies must ensure full compliance with the Myanmar Companies Law and all directives issued by the registrar. This includes the proper submission of annual returns and adherence to updated requirements for share transfers and changes in directors. Companies and organizations must comply with all applicable laws, rules, directives, and procedures issued by relevant ministries and departments. If any authority takes action due to noncompliance, the registrar may also take appropriate measures. Noncompliance may result in regulatory sanctions, including restrictions on future company participation and vetting under anti–money laundering and counter–terrorism financing protocols. Prospective directors of newly registered companies will be vetted to confirm no prior violations of applicable laws. Entities must respond promptly and accurately to document requests from the registrar, both during initial registration and in subsequent filings. Companies are strongly advised to review their internal compliance frameworks and ensure readiness to meet DICA’s documentation and procedural expectations. In particular, companies must respond promptly and accurately to document requests from the registrar, whether during initial registration or in subsequent filings. For more information on this DICA announcement, or on any aspect of corporate registration, or assistance with