You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

March 5, 2026

Thai SEC Heightens Enforcement Against Cross-Border Digital Asset Platforms

Thailand’s Securities and Exchange Commission (SEC) has filed a criminal complaint against a licensed digital asset broker, its overseas trading platform, and its executives for allegedly operating an unlicensed digital asset exchange targeting Thai customers. The case marks an escalation in the SEC’s enforcement efforts against unlicensed offshore platforms that attempt to serve Thai users through local licensed entities.

Criminal Complaint

On February 20, 2026, the SEC filed a criminal complaint with the Economic Crime Suppression Division against a local licensed digital asset broker, its overseas global trading platform, and its executives. The SEC alleges that the parties violated the Digital Asset Business Emergency Decree B.E. 2561 (2018) by cooperatively operating a digital asset exchange business on a cross-border basis since 2023 without the required SEC license.

According to the SEC, the local broker promoted the overseas platform’s services to the public through Thai-language posts on social media channels, with services available exclusively to customers residing in Thailand. Access to the global platform was provided through the local broker’s website and mobile application. Customers who registered for the local broker’s services were automatically granted access to the global platform without having to undergo a separate identity verification process. The SEC also found that the local broker provided back-office system support services to the global platform.

The SEC considers these activities to constitute joint operation of an unlicensed digital asset exchange. The former executives of the local broker are being held liable as the responsible persons during the relevant period. The SEC emphasized that the complaint initiates the criminal process, and the decision to prosecute or convict the accused parties will ultimately be made by law enforcement authorities and the criminal courts.

Platform Blocking

The SEC has also coordinated with the Ministry of Digital Economy and Society to block public access to the global platform under the Emergency Decree on Measures for the Prevention and Suppression of Technology Crime (No. 2) B.E. 2568 (2025). Access is expected to be restricted beginning March 22, 2026. The SEC has cautioned current users in Thailand to take appropriate steps regarding their digital assets held on the platform before the blocking date and reiterated its warning against using the services of unlicensed digital asset operators.

Key Takeaway

This enforcement action reflects the SEC’s heightened scrutiny of unlicensed offshore digital asset platforms and demonstrates that such platforms may not rely on local licensed entities to offer cross-border trading services targeting Thai users.

RELATED INSIGHTS​ 

December 8, 2021
On February 9, 2021, Vietnam’s Ministry of Public Security (MPS) released the full text of the Draft Decree on Personal Data Protection (“Draft PDPD”) for public consultation, after having released an outline in December 2019, with an ambitious goal for the Draft PDPD to be promulgated and take effect on December 1, 2021. This date has now passed and the Draft PDPD remains unissued, with no concrete details on when the situation will change. Many new contents have been introduced in the Draft PDPD (please see our previous articles here and here). In this article, we take a deeper look at the issues that have attracted the most attention from national and international stakeholders as they wait for the draft to be finalized and promulgated. Please click below to read the full article.  
November 29, 2021
On November 25, 2021, the Myanmar Investment Commission (MIC) issued a list of investment sectors that will receive priority attention in order to encourage national development and state building. The investment activities that MIC will prioritize are the following: Fertilizer manufacturing Cement manufacturing Iron and steel manufacturing Agriculture and livestock farming and related industries Value-added manufacturing of foodstuffs Electric vehicle manufacturing Pharmaceutical and medical device manufacturing Public transportation services Both foreign investors and local investors may invest in these sectors, and the MIC, ministries, and relevant state and regional governments will provide necessary assistance to the investors under the Myanmar Investment Law 2016. For more details on the new requirements, please contact Tilleke & Gibbins at [email protected] or +95 9 772 440 001.
November 24, 2021
Attorneys from Tilleke & Gibbins have provided the latest update to the Thailand contribution to Doing Business in…, a Q&A-style guide published by Thomson Reuters Practical Law that presents an overview of the legal framework for doing business in 63 jurisdictions worldwide. The Thailand chapter of the guide outlines Thailand’s legal system and key laws applicable to foreign companies doing business in the country. The chapter specifically covers the following main topics: Legal system: Thailand’s court system and codified legal system. Foreign investment: Lists of reserved business activities, restrictions on doing business with certain jurisdictions, exchange controls and currency regulations, and grants and incentives available to investors. Business vehicles: Ordinary partnerships, registered ordinary partnerships, limited partnerships, private limited companies, and public companies. Environment: Main laws and regulations, factory operation. Employment: Laws, employment contract requirements, work permits, and termination and redundancy. Tax: Taxes on employment, tax and nontax resident employees and businesses, corporate income tax, value added tax, special business tax, municipal tax, stamp duty, dividends, interest, intellectual property royalties. Competition: Important aspects of Thailand’s regulatory regime surrounding competition, centered around the updated Trade Competition Act. Antibribery and corruption: Laws, compliance requirements, regulatory authority. Intellectual property: Patents, trademarks, registered and unregistered designs, and copyright. Marketing agreements and advertising: Regulation of marketing agreements, Thailand’s Consumer Protection Act, direct marketing, role of the Consumer Protection Board and Food and Drug Administration. E-commerce: E-commerce laws and regulations, marketing and sales via online platforms. Data protection: An outline of Thailand’s Personal Data Protection Act. Product liability: Procedures and regulations for product liability and product safety, including the Unsafe Goods Liability Act and the Consumer Case Procedure Act. Product liability: Key regulatory authorities for trade competition, environmental issues, and financial services. To browse, download, or print the Thailand chapter, please visit the Practical Law website.
October 25, 2021
Michael Ramirez, a counsel in Tilleke & Gibbins’ dispute resolution group in Bangkok, has updated the firm’s contribution to the Global Attorney-Client Privilege Guide, published by Lex Mundi. The newly expanded guide provides information on what constitutes attorney-client privilege in over 70 countries around the world. The Thailand section of the guide contains in-depth information on the function and applications of attorney-client privilege in Thailand (or, as explained in the guide, an equivalent concept enshrined in Thai law), including coverage of the following topics: Privilege in corporations Common interest doctrine Litigation funding Crime-fraud exception Work product doctrine/litigation privilege Other privileges including mediation, accountant-client and settlement negotiation The interactive guide features expert contributions by Lex Mundi member firms from jurisdictions worldwide. Readers can browse the contributions, generate country-specific reports, and compare attorney-client privilege in multiple jurisdictions. For more information, please visit the Lex Mundi website.