Tilleke & Gibbins has contributed the Vietnam chapter to the latest edition of the Global FinTech Guide published by Multilaw. The guide provides a comprehensive overview of the legal and regulatory framework governing financial technology across major jurisdictions around the world. Compiled by experienced practitioners from Multilaw member firms, the Global FinTech Guide examines how technological innovation is transforming financial services and how regulators are adapting to developments such as digital payments, virtual assets, and online financial platforms. The publication offers comparative insights into regulatory regimes and presents detailed, jurisdiction-specific analysis for companies, investors, and entrepreneurs active in the FinTech sector. The Vietnam chapter, prepared by lawyers in Tilleke & Gibbins’ technology, media, and telecommunications team, surveys the key legal and regulatory developments shaping the country’s FinTech ecosystem. It covers the following areas: Payment services Asset and portfolio management Financial advisory and broking services (including robo-advisory and auto-trading) Trading platforms, social trading platforms, and signal following Crowdfunding, crowdinvesting, and crowdlending Distributed ledger technology (DLT) and cryptocurrencies Loan services, factoring, loan broking, and finetrading Identification Online banking services Initial coin offerings (ICOs) and token sales Insurtech Regtech and compliance management Know-your-customer (KYC) requirements Tilleke & Gibbins also contributed the Thailand chapter to the Global FinTech Guide. The full guide is available on the Multilaw website.

On September 12, 2025, the Bank of Thailand (BOT) officially released its AI Risk Management Guidelines for Financial Service Providers, building upon the draft guidelines issued in June 2025. The guidelines reflect a balanced approach, encouraging innovation while safeguarding financial stability and consumer protection. The guidelines are targeted at all financial service providers, including financial institutions and special financial institutions under the Financial Institution Business Act, as well as payment providers under the Payment Systems Act. The guidelines apply to both AI systems developed in-house and those developed by third parties that are adopted for use by financial service providers. AI Risk Management Guidelines The two main pillars in managing AI risk are (1) governance of AI system implementation and (2) AI system development and security controls, consisting of the following key elements: 1. Governance Stakeholder roles and responsibilities. Boards and senior management assume accountability for decisions and operations involving AI systems, and are responsible for defining roles and responsibilities for AI oversight. This includes establishing an AI system usage policy, designating personnel responsible for AI risk management, and building awareness of AI-related risk within the organization. Organizations are expected to foster internal capabilities to use AI securely and avoid overreliance that could compromise business continuity or customer service. AI system usage policy. Policies governing AI usage should align with organizational goals, regulatory obligations, and recognized responsible AI frameworks—such as the FEAT principles (fairness, ethics, accountability, and transparency). These policies should be reviewed regularly to respond to technological advancements and evolving risk profiles. Risk management throughout the AI lifecycle. Risk management should encompass the entire AI lifecycle, from establishing risk appetite to implementing continuous risk assessment and control measures tailored to specific use cases. Financial service providers should assess risks and impacts of AI usage on operations and customer services.

Thailand’s Ministry of Finance has introduced a five-year personal income tax exemption on capital gains from the disposal of cryptocurrency or digital tokens. The Ministerial Regulation No. 399, published in the Government Gazette on September 5, 2025, offers the personal income tax exemption for transfers occurring between January 1, 2025, and December 31, 2029. The ministerial regulation was enacted to promote Thailand as a global financial center and digital asset business hub while encouraging increased domestic investment in digital assets. Key Conditions The exemption, which covers capital gains from cryptocurrency and digital token disposals during the specified five-year period, applies only to individuals. Companies that trade in digital assets are not eligible for this tax exemption. With the tax holiday set to expire in 2029 (unless extended), individual traders should plan ahead for postexemption taxation to ensure full compliance with Thailand’s personal income tax requirements. Proper documentation of digital asset transactions during the exemption period will be essential for future tax compliance. For more details on this tax exemption, or on any aspect of Thailand’s tax law and regulations, please contact Saravut Krailadsiri at [email protected] or Papavarin Sarawongsuth at [email protected].

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