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

June 23, 2026

Thailand Establishes New Refund Process for Victims of Tech Crimes

On May 14, 2026, Thailand published a ministerial regulation in the Government Gazette to prescribe measures for prevention and suppression of technology crimes. The regulation creates a comprehensive procedural framework for returning money and digital assets to victims of technology crimes. It will take effect 90 days after publication (in mid-August 2026), giving affected entities a limited window to prepare.

Mandatory Reporting Obligations for Financial Institutions

When a deposit account, e-money account, or digital asset wallet is frozen in connection with a technology crime, the relevant financial institution or business operator must report transaction data to the Anti-Money Laundering Office (AMLO) via AMLO’s designated electronic system.

Required data elements include account numbers (sender and receiver), names, identification or passport numbers, legal entity registration numbers, phone numbers, remaining balance, damage amount, transaction reference numbers, and the bank case ID.

Institutions that already share data through the information-sharing system under the emergency decree are deemed to have satisfied this reporting obligation, creating an incentive for platform participation.

When the Royal Thai Police or the Department of Special Investigation seize or freeze assets related to technology crimes, they must provide AMLO with investigation reports, complaint evidence, money-trail data, and account statements.

Notification and Claims Process

Once the AMLO secretary-general approves verified reports of a technology crime, the account information of persons connected to the crime will be published in the Government Gazette, triggering a 90-day window for victims to file claims and for related persons to file objections. Officers will also publish details on AMLO’s electronic media and send registered mail to identified victims, which will be deemed received after 7 days domestically or 15 days internationally.

Victims have 90 days from the date the crime is published in the Government Gazette to file claims through AMLO’s electronic system. Claims must include the victim’s information, damage amount, refund channel, and supporting evidence. Related persons whose accounts have been frozen may file objections with evidence that the funds are unrelated to the crime.

The claim will be reviewed by a designated transaction committee. Dissatisfied parties may challenge the decision in civil court within 30 days. Once an order becomes final, AMLO will coordinate with police and financial institutions to lift freezes and transfer funds to victims’ designated accounts.

Next Steps

Financial institutions, e-money providers, and digital asset service providers should:

  • Assess their current systems and begin integrating with AMLO’s electronic reporting platform before the mid-August 2026 effective date.
  • Develop internal workflows to respond promptly to AMLO orders to lift freezes and transfer funds within the required 7-day timeframe.
  • Coordinate compliance teams to align technology-crime victim refund processes with existing AML obligations, given that the regulation leverages AMLO’s transaction committee and AML infrastructure.

RELATED INSIGHTS​ 

April 30, 2026
Vietnam’s Decree No. 134/2026/ND‑CP, which took effect on 9 April 2026, plays an important role in detailing and implementing Vietnam’s Intellectual Property (IP) Law in the context of rapid digital transformation and the growing application of artificial intelligence (AI). The new decree provides comprehensive guidance on the application of copyright and related‑rights regulations, addressing key issues such as authorship, ownership, statutory exceptions and limitations, registration procedures, and enforcement mechanisms. Through these measures, Decree 134 seeks to achieve an appropriate balance between safeguarding the legitimate interests of rightsholders and fostering innovation, research, and technological advancement, thereby strengthening the state’s framework for the effective management, protection, and exploitation of intellectual property in the digital and AI‑driven environment. Some notable aspects of Decree 134 are discussed below. Copyright for AI-Created Works Decree 134 provides important guidance on the determination of copyright and related rights in works created with the assistance of AI. Article 5a reaffirms the principle that human creativity remains central to copyright protection, clarifying that copyright or related rights arise only where a human makes a substantial and decisive intellectual contribution, exercises effective control over the creative outcome, and assumes responsibility for the content and its legality. At the same time, the provision confirms that AI is regarded solely as a technological tool rather than a rights‑holding subject, thus ensuring consistency with the fundamental concepts of authorship and ownership under the IP Law. By introducing requirements on transparency, proof of human contribution, and compliance with AI‑specific labelling and technical marking obligations, Decree 134 establishes a clear and enforceable legal framework for the responsible use of AI in creative activities. Lawful Use of Copyrighted Texts and Data Article 37a of Decree 134 sets out the specific conditions under which copyrighted texts and data may be lawfully used for scientific research, experimentation,
April 23, 2026
Vietnam has progressively positioned blockchain as a strategic technology within its broader digital transformation agenda over the past decade. From early policy orientations to more recent legislative developments, the regulatory approach has gradually shifted from high-level recognition to more concrete legal integration. Against this backdrop, a new draft decree regulating activities relating to product and goods identification, authentication, and traceability (the “Draft Decree”) marks a notable turning point. Rather than merely referencing blockchain as a policy priority, the Draft Decree incorporates blockchain directly into a nationwide regulatory system, positioning it as part of the underlying infrastructure for data governance and public administration in relation to the management, verification, and traceability of product-related data. Evolution of Vietnam’s Blockchain Legal Framework: The Draft Decree in Context Vietnam’s blockchain legal framework has developed in several distinct phases. The first phase, beginning around 2019, was characterized by high-level policy recognition in several resolutions of the Party Central Committee. Particularly, blockchain was identified as part of the broader category of digital technologies critical to industrial modernization and participation in the Fourth Industrial Revolution. These resolutions did not regulate blockchain directly, but established its strategic importance at the national level. The second phase (2023 to 2025) saw the introduction of national strategies and technology policies that more explicitly recognized blockchain as a priority technology. Those policies collectively signaled a clear policy commitment to developing blockchain infrastructure and applications. However, these instruments remained largely at a policy-level and did not establish binding regulatory frameworks. The third phase (from 2025) involves the gradual integration of blockchain into sectoral legislation. Laws such as the Law on Digital Technology Industry (2025), the Law on Personal Data Protection (2025), and the Law on Science, Technology, and Innovation (2025) have introduced concepts such as digital assets, crypto assets, and even specific
April 21, 2026
Thailand’s Personal Data Protection Committee (PDPC) has launched a public consultation period on a draft notification setting out criteria for data subject access requests (DSARs). The draft notification addresses practical uncertainties in handling DSARs by introducing standardized procedural requirements for data controllers. The consultation period runs from April 16 to May 15, 2026. The notification will enter into force 30 days from the date of its publication in the Government Gazette. Key Features of the Draft Notification The draft notification covers the following key areas: Scope of information subject to access. Data controllers must enable data subjects to access at least the following upon request: (1) personal data collected directly from them; (2) personal data obtained from other sources; and (3) the source of personal data obtained from other sources without consent. Information required under section 23 of the PDPA and information that must be recorded pursuant to section 39 of the PDPA—such as the categories of personal data collected and purposes of processing—must also be made available. Submission channels and formal requirements. Data controllers must provide at least in-person and postal channels for DSARs, while electronic or other channels are optional. Requests may be made either directly by the data subject or through an authorized representative, and must be signed and include sufficient identifying information, a preferred response method, and DSAR details. Identity verification documents (and proof of authority if the request is through a representative) are required, and additional documentation may be requested for verification or communication purposes. Data controllers may use different verification methods for DSARs submitted via electronic or other channels, provided this does not create undue obstacles to the exercise of data subject rights. Verification and response timelines. Data controllers must complete preliminary verification within seven business days of receiving a request. If a
April 10, 2026
Thailand has introduced new regulatory guidance requiring digital platform operators to adopt structured, transparent, and fair fee practices. On March 16, 2026, the Electronic Transactions Development Agency (ETDA) published Announcement No. DPS 2/2569, titled “Guidelines for Transparency and Fairness in Digital Platform Service Fee Determination,” issued under the Royal Decree on Digital Platform Service Business Operations B.E. 2565 (2022). The guidelines establish a framework governing how digital platform operators should set, disclose, and adjust fees charged to users and related service providers such as logistics and payment providers. Although framed as best-practice guidance rather than legally binding rules with explicit penalties, the guidelines carry regulatory weight under the royal decree and represent a significant step toward structured governance of digital platform fee practices in Thailand. The guidelines establish various transparency principles and divide fees into two distinct categories—compulsory and additional—with specific governance principles for each. Transparency Principles The guidelines recommend that digital platform operators adopt several transparency measures to ensure that users can fully understand the costs of using a platform. Fee catalog. All fees should be consolidated into a single, accessible location, which should include the fee name, definition, scope of covered services, calculation methodology, rate, billing period, and calculation examples. Minimum service disclosure. Operators should disclose the minimum service that users can expect, such as baseline visibility, product listing capabilities, access to transaction data, and back-end dashboard access. Price structure disclosure. Operators should disclose the categories of costs underlying their fees, such as system maintenance, cybersecurity, and operational costs. While exact cost figures need not be made public, operators should be able to provide numerical data to regulators upon request. Clear fee formulas. Fee calculations should be simple and easy to understand—for example, percentage of net sales, cost per order, or cost per product listing. Operators should