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

September 11, 2025

Thailand: Anti-Money Laundering

Subscribe to Updates
Thomson Reuters Regulatory Intelligence

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, a relatively small portion result in further investigation for violation of the Act. That said, the trend is for more active participation and enforcement by AMLO in recent years.

Targeted crimes

Currently, the Act covers the transfer or conversion of funds or property obtained from the following predicate offences:

  • Offences relating to narcotics.
  • Human trafficking and offence of sexuality and prostitution.
  • Fraud against the public.
  • Fraud involving financial institutions.
  • Abuse of position by a government official.
  • Extortion.
  • Trade in contraband.
  • Terrorism.
  • Gambling offences, including online gambling, with particular emphasis on large scale organisation of gambling games.
  • Participation in racketeering groups or participation in a criminal association.
  • Receiving stolen property only as it constitutes assisting in the selling, buying, pawning or receiving, in any way, property obtained from the commission of an offence with the nature of business conduct.
  • Counterfeiting or alteration of currencies, seals, stamps and tickets with the nature of business conduct.
  • Criminal trading only where it is associated with the counterfeiting or violating of intellectual property rights to goods or the commission of an offence under the laws on the protection of intellectual property rights with the nature of business conduct.
  • Forgery of a document of right, electronic cards or passports with a nature of regular or business conduct.
  • The unlawful use, holding, or possessing of natural resources or a process of illegal exploitation of natural resources with a nature of business conduct.
  • The commission of an offence relating to murder or grievous bodily injury which leads to the acquisition of assets.
  • Restraining or confining a person only where it is to demand or obtain benefits or to negotiate for any benefits.
  • Theft, extortion, blackmail, robbery, gang-robbery, fraud or misappropriation with a nature of regular conduct.
  • Acts of piracy under anti-piracy law.
  • Unfair securities trading practice under the law on securities and stock exchange or unfair futures trading under the law on futures contracts or unfair practice which affect trading price of agricultural futures under the law on agricultural futures trading.
  • Offences related to arms and arms equipment which is or may be used in combat or war under the law on arms control.

In view of Thailand’s ongoing commitment to the prevention of financial crimes and aim to strengthen regulatory compliance, The Thai Bankers’ Association, the Association of State Financial Institutions and member banks are required to establish industry standards in areas identified by AMLO and the Bank of Thailand as needing improvement. This includes the development of systems and tools to effectively monitor Dual-Use Items and products that have high risks of being used to produce weapons that threaten international security, known as the Common High Priority List: CHPL. These standards will be applied starting January 2025.

Money laundering offence

Under the Act, it is a crime to transfer, convert or receive the transfer of funds or property arising from the above referenced criminal offences for the purpose of hiding or concealing the source of the funds.

The penalties are:

  • Natural person: imprisonment for a term of one year to 10 years and/or a fine of 20,000 to 200,000 baht.
  • Juristic person: a fine of 200,000 to 1,000,000 baht.

It is also important to note that the Act includes provisions targeted specifically at government officials, whereby the aforementioned fines and maximum prison sentences are doubled for government officials and can be tripled if certain categories of government officials are involved in a conspiracy to commit a money laundering offence. This represents a concerted effort to tackle the consistent problem of institutional corruption in Thailand.

Banking transactions are a primary activity subject to scrutiny under the Act, but other financial transactions are also covered. For example, an individual who secretly uses money from a drug sale to purchase shares of publicly traded stocks on the Stock Exchange of Thailand could be prosecuted under the Act.

Furthermore, a corrupt government official who uses money obtained from a bribe to then purchase land runs the risk of being exposed, having the land confiscated and being subject to double-scale fines. Even property developers, who knowingly hold or accept money for concealment that they know is derived from one of the stated criminal offences, can be subject to enforcement under the Act.

Enforcement officials can seize, without a warrant, money or property connected with the commission of one of the enumerated criminal offences or a money laundering offence. In such cases, the owner of the seized property must be able to demonstrate that the property is unrelated to the commission of one of the enumerated crimes, or a money laundering offence, in order to recover the property.

Designated persons

A designated person, which refers to an individual, group, juristic person (legal entity), or organisation that have been identified by AMLO as engaging in terrorism, proliferation, or financing of weapons of mass destruction, may petition the court in line with a Civil Court order as of April 1, 2025, for the following:

  1. To order the delisting of such persons from the designation list.
  2. To lift the freezing of assets.
  3. To seek permission to take any action with the frozen assets.

Reporting requirements

A key provision of the Act is the requirement that financial institutions and other reporting entities that tend to be used as vehicles for money laundering report all cash transactions of 2 million baht or more. Property transactions in excess of 5 million baht must also be reported. Also required for reporting are all suspicious transactions that may be related to one of the enumerated criminal offences, are more complex than normal, lack economic plausibility, or appear to have been undertaken to avoid compliance with the anti-money laundering law.

For such transactions, the financial institutions must require their customers to provide a detailed record of the transactions. The latter requirement is generally left to the practical discretion of the financial institution which must then choose between customer confidentiality concerns and compliance with the Act.

The AMLO has also implemented separate regulations which require all persons entering or leaving Thailand to declare currency in their possession where the amount meets or exceeds certain statutory minimum levels. Recently, the AMLO has released notifications requiring business subject to the Act to establish internal protocols, policies and procedures to address anti-money laundering risks within their company.

Failure to comply with the Act’s reporting requirements is punishable by a fine of up to 1 million baht and a daily fine of up to 10,000 baht a day through the period of violation or not acting correctly. Filing a false report is punishable by imprisonment of up to two years and/or a fine of 50,000 to 500,000 baht.

Thailand has made great progress in its legislative efforts to combat illicit crime and the transfer of funds related to such crimes. While much has been done and the laws are in place, ultimate success depends on the practical enforcement of the law.

 

Tilleke & Gibbins provided this Thailand country update for Thomson Reuters Regulatory Intelligence. The update is available as a PDF through the button below.

Download Full Article
Related Professionals

Practices

Compliance and Investigations

Location

RELATED INSIGHTS​ 

February 13, 2023
Thailand’s Office of the Prime Minister has issued a new regulation titled Giving or Receiving Gifts of State Officials B.E. 2565 (2022). This regulation, which took effect on January 13, 2023, repeals the previous 2001 version and updates certain provisions to be in sync with Thailand’s primary anticorruption law, the Organic Act on Anti-Corruption B.E. 2561 (2018). The regulation prohibits state officials’ family members from receiving gifts from people who are dealing with the officials’ respective agencies. It also prohibits state officials from giving gifts to their supervisors and their supervisors’ family members. An exception, carried over from the previous version of the regulation, is provided for gifts on limited “customary occasions” valued at THB 3,000 or less. There are some notable revisions in the definitions of the new regulation. The term “gift” is now clearly defined to include “training” or “seminars.” In addition, the term “family members” now includes spouses living together “as husband and wife,” even if not legally married. For example, the common-law spouse of an officer considering a license application is not allowed to receive a gift from or attend an overseas seminar organized by the applicant. The regulation also provides: Guidelines for state officials to self-report in case of violation by a family member; Instructions on how to deal with the gifts received in violation; and Disciplinary actions for violation. Importantly, the regulation continues to prohibit the receipt of gifts by state officials’ family members but does not expressly criminalize the giving of gifts by private parties. However, all who deal with government officials should take note of the updated regulation to avoid creating a situation that might violate the rules.
Read More
November 3, 2022
On October 31, 2022, the Department of Trade in Myanmar’s Ministry of Commerce announced that payments for importation at the border are to be made via bank transaction. This announcement comes into force with Import/Export Newsletter No. 10/2022, dated October 31, 2022, issued by the Department of Trade, with the purpose of implementing a systematic payment system for import and export at the border, in accordance with a suggestion made by the Financial Action Task Force (FATF), an international financial watchdog. (This follows the recent news that the FATF has blacklisted Myanmar.) This requirement means that only bank transactions will be accepted for import payments in the border trade. Initially, this system will be applied to trade at the Myanmar-Thailand border only. The new requirement to pay for imports only via bank transaction states that export earnings and other types of foreign currency earnings (including salary and income remitted by Myanmar workers overseas) will be allowed to be used for imports. Importers are required to make the payments for import goods—using these earnings—via their banks. That is, Importers operating in the border trade must have foreign currency earnings received through official banking channels and must make import payments abroad through official banking channels using those earnings. In contrast to previous practices, they are unable to use other sources of income and are not able to make other payment arrangements that do not involve bank transactions. The procedures for importation at the Myanmar-Thailand border are as follows: Companies applying to the Department of Trade for an import license must produce credit advice and original bank statements that prove the receipt of export earnings or other earnings into their bank account. The Department of Trade will scrutinize the reported export earnings or other earnings, and approve the import license for an
Read More
April 8, 2022
As Thailand has paid more and closer attention to anticorruption issues, a number of measures have been introduced and implemented over the years, including the establishment of the Complaint Center for Foreign Investors (CCFI) in 2015. The CCFI was set up by the Office of Public Sector Anti-Corruption Commission (PACC) to promote transparency and integrity in the Thai public sector and enhance the confidence of foreign investors conducting business in Thailand. Though the CCFI has been in operation for many years, many foreign investors conducting business in Thailand have either remained unaware of it or have been reluctant to use it because of concerns that acting against Thai public officials could cause problems for their businesses or in their personal lives. However, recently the PACC has made a renewed push to promote the CCFI as a suitable channel for foreign investors to lodge complaints when they face unfair services or treatment, or face requests for benefits from Thai public officials. Lodging a Complaint with the CCFI The CCFI was established to administer the PACC’s responsibilities under Section 58/2 of the Executive Measures in Anti-Corruption Act B.E. 2551 (2008), which authorizes the PACC to notify the superior of any state agency appearing to have regulations or procedures that fail to comply with the Licensing Facilitation Act; are deemed by the PACC to cause a nuisance or damages to a public service clientele; or cause severe detriment to a government service. Practically, this means that when investors have a complaint that fits the scope described in the law, they can contact the CCFI, which will take action by getting the relevant agency or government authority to examine the issue. In cases concerning agency regulations and procedures, this will be the head of the relevant agency, but if the circumstances indicate malpractice
Read More
March 18, 2022
As many countries have experienced firsthand, corruption and bribery can have severe and far-reaching effects throughout a country’s political and economic systems. They not only impact the financial status and administrative ability of the countries involved, but at the same time, can also create and perpetuate a negative image of those countries to current or potential trade or investment partners. Recognizing the importance of minimizing or eliminating the damaging effects of bribery and corruption, many countries have made—and continue to make—efforts to strengthen their anticorruption and antibribery capabilities. Thailand has enacted relevant laws and enforced anticorruption measures in both the public and private sectors. Under Thai law, a bribe can take the form of property or a benefit. “Property” can be tangible (such as money, a car, a house, etc.) or intangible (such as copyrights, patents, etc.), while a “benefit” can be a gift, a discount, entertainment, healthcare costs, a job promotion, and so on. This article discusses the key provisions related to criminal offenses committed by private parties under three anticorruption laws in Thailand: Organic Act on Anti-Corruption B.E. 2561 (2018) Public Procurement and Supplies Administration Act, B.E. 2560 (2017) Act on Offenses Relating to the Submission of Bids to State Agencies B.E. 2542 (1999) Organic Act on Anti-Corruption The key provision of the Organic Act on Anti-Corruption (OAAC) is Section 176, which prohibits giving, offering, or promising property or a benefit to a public official, foreign public official, or official of a public international organization with the intent to induce the official to wrongfully perform his or her duty. Violations are subject to criminal liability, punishable by imprisonment for up to five years, a fine of up to THB 100,000 (approx. USD 3,000), or both. If the offender is a person associated with a company that does
Read More