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December 26, 2025

Thailand Issues Mandatory Guidelines Enhancing Digital Fraud Controls

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The Bank of Thailand (BOT) has released the Guidelines for Digital Fraud Management, which took effect on December 17, 2025, incorporating certain amendments to the draft guidelines issued in March 2025. These official guidelines aim for end-to-end digital fraud prevention, with a particular focus on mule accounts, to enhance trust and security in Thailand’s financial system.

The guidelines apply to “financial service providers,” including:

  • Financial institutions and special financial institutions under the Financial Institution Business Act; and
  • Operators of Inter-institutional Fund Transfer System e-money services and e-fund transfer services under the Payment Systems Act.

Besides commercial banks and e-money operators that offer fund-transfer services, other providers may adopt requirements based on risk proportionality and baseline standards set out in the guidelines (for instance, an e-money operator that does not offer e-fund transfer services could consider implementing a fraud monitoring and detection system according to the risk level of its service).

The guidelines establish the following key requirements:

  • Policy and oversight. Directors and senior executives of financial service providers must adopt appropriate “end-to-end” fraud management policies and KPIs to manage digital fraud, covering prevention, monitoring, detection, management, resolution, and support for affected customers. The fraud management policy must be regularly reviewed, and whenever there is a situation or change that significantly affects the efficiency of the fraud management. Any significant update to the policy must first be approved by the board of the financial service provider. The BOT also encourages providers to collaborate in establishing industry standards aligned with applicable laws and regulations to ensure consistency and best practices across the sector.
  • Fraud management processes. Financial service providers must establish a clear framework for managing digital fraud throughout the customer lifecycle—from customer onboarding to service termination—covering at least the following processes:
    • Know your customer (KYC) and customer due diligence (CDD): The KYC procedure must also include identification of account operating objectives, and the financial service provider must conduct CDD according to the Anti-Money Laundering Act B.E. 2542 (1999).  If customer behavior signals that the customer is a potential owner of mule accounts (i.e., deposit or e-money accounts used as tools to receive and transfer funds obtained through the commission of technology crime), enhanced CDD must be applied. Providers must assess and classify customers based on their risk level for being mule account owners or fraud victims, using information from KYC, CDD, and reliable sources. Risk classifications must remain current and reflect prevailing circumstances.
    • Fraud monitoring and detection: Providers must develop proactive processes to detect and monitor unusual transactions and utilize data from multiple sources (e.g., Central Fraud Registry and data obtained from other financial service providers) to identify potential mule accounts and fraud. This may involve adopting new technologies (e.g., artificial intelligence) to enhance efficacy and stay ahead of emerging fraud techniques.
    • Action and response to fraud: Providers must develop swift and appropriate measures to prevent, limit, and promptly mitigate digital fraud damage, including handling suspected mule accounts. They must also respond clearly, fairly, and swiftly to support customers affected by fraud (e.g., by offering 24/7 customer support through dedicated hotlines and electronic channels, having clear timeframes for assisting customers affected by fraud incidents, and reporting to the BOT any incidents that cause widespread customer damage or affect the financial service provider’s reputation).
  • Information sharing. Financial service providers must have mechanisms to share accurate information promptly with one another, according to the framework under the law on technology crime suppression and other relevant laws, and must appoint a responsible person to coordinate and procure information necessary for any investigations.
  • Awareness. Financial service providers must proactively raise customers’ and the public’s awareness of digital fraud to prevent and reduce potential damage. Required actions include disseminating information on an easily accessible service channel (e.g., mobile app or infographic on social media). The BOT also encourages financial service providers to have customers take awareness tests.
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