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

December 26, 2025

Thailand Issues Mandatory Guidelines Enhancing Digital Fraud Controls

Subscribe to Updates

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.
Related Professionals

Industries

Fintech

Technology

Practices

Banking and Finance

Location

RELATED INSIGHTS​ 

January 9, 2024
As of January 1, 2024, all films distributed in cyberspace in Vietnam must display ratings and warnings (if required) for viewers, following the phased-in effectiveness of Decree No. 131/2022/ND-CP of the Government dated December 31, 2022, guiding the implementation of the Law on Cinematography (Decree 131). While Decree 131 took effect on January 1, 2023 (the same date as the Law on Cinematography), it provided a grace period of one year for films to be distributed in cyberspace without the display of ratings or warnings. Now, for continued distribution in cyberspace of such films, distributors must add ratings and warnings in compliance with regulations issued under Circular No. 05/2023/TT-BVHTTDL of the Ministry of Culture, Sports and Tourism (MOCST) dated April 5, 2023 (Circular 05). Film Rating Film distributors can either carry out the film rating by themselves or request the MOCST to provide the rating. In the former case, the distributor must request the MOCST to recognize its eligibility for self-rating. (Based on our experience successfully obtaining this recognition for a client, this procedure may take about two to three months for completion, depending on the availability of required information and materials.) If a distributor cannot obtain recognition for film self-rating eligibility, it must request the MOCST to provide the film rating for each and every film it distributes in cyberspace. Display of Ratings and Warnings Circular 05 requires that the film rating must be displayed clearly and prominently in the introduction of a film in order for a user to make an informed decision to access that film or not. Moreover, the rating must be displayed on the left or right corner of the screen during the entire distribution time. Warning contents must be in words or sound which must be displayed three seconds after the beginning of
Read More
January 4, 2024
On December 25, 2023, Thailand’s Personal Data Protection Committee (PDPC) issued two notifications under sections 28 and 29 of the Personal Data Protection Act 2019 (PDPA) that address essential aspects and criteria for the cross-border transfer of personal data. These notifications are scheduled to come into effect on March 24, 2024. Key points in the notifications are outlined below. Adequate Data Protection Standards (Section 28) Unless otherwise provided by the PDPA, the destination country or international organization that receives the transferred personal data must have “adequate data protection standards,” as determined by the following factors: Legal measures and mechanisms. The destination country or international organization must have legal measures or mechanisms aligned with the personal data protection laws in Thailand. Specifically, the obligations of data controllers need to include providing appropriate security measures, implementing personal data protection measures that are suitable and that enable the exercise of data subjects’ rights, and establishing effective legal remedial measures. Regulatory authority. The presence of an agency or organization entrusted with the duties and authority to enforce laws and regulations related to personal data protection is also a critical factor. In addition, this notification empowers the Office of the PDPC to refer cases, either independently identified or proposed by a data controller, to the PDPC for adjudication. The PDPC retains the discretion to make decisions on a case-by-case basis or to establish a list of destination countries or international organizations that it considers to have adequate data protection standards. Binding Corporate Rules and Appropriate Safeguards (Section 29): In the realm of global data exchange, two prominent mechanisms have emerged as key enablers of secure and compliant transfer of personal data: Binding corporate rules (BCRs). Implementation of BCRs involves enforcing an approved policy for safeguarding personal data transferred among affiliated businesses or within the
Read More
January 2, 2024
Myanmar’s Ministry of Commerce (MOC) has released updated information regarding the registration fees for online retail businesses. The fees and criteria, which are included in the MOC’s Export/Import Newsletter No. 17/2023 dated December 28, 2023, are laid out below. Registration Fees The official registration fees vary depending on the applicant type: Companies or other commercial organizations: MMK 70,000 (approx. USD 33.5) for registration and renewal; MMK 3,000 (approx. USD 1.5) for each amendment. Small and medium enterprises (SMEs): MMK 50,000 (approx. USD 24) for registration and renewal; MMK 3,000 (approx. USD 1.5) for each amendment. Individual applicants: 30,000 MMK (approx. USD 14.5) for registration and renewal; MMK 3,000 (approx. USD 1.5) for each amendment. Validity Period Registrations approved from January 1, 2024, will be valid for two years from the date of grant. The requirement for online retail businesses to register their operations was announced in July 2023. Based on statements from the MOC, online retail businesses need to complete their registration by late January 2024 to avoid potential enforcement actions. Regarding SMEs, the MOC will also evaluate their SME registration certificate issued by the Agency Office under the Small and Medium Enterprises Development Law 2015. For assistance completing the registration process, or for more details on any aspect of online retail operations in Myanmar, contact Tilleke & Gibbins at [email protected].
Read More
December 15, 2023
As part of its membership in Lex Mundi, Tilleke & Gibbins has published an updated edition of its Guide to Doing Business in Thailand for 2023. This guide outlines the key factors for starting and operating a business in the Thai market. Issues covered include: Investment incentives Financial facilities Exchange controls Import and export regulations Structures for doing business Requirements for the Establishment of a Business Operation of the Business Cessation or Termination of the Business Labor legislation, relations, and supply Tax Immigration requirements This publication is part of Lex Mundi’s Country Guides series prepared by member firms in more than 100 jurisdictions worldwide. The guides serve as a useful resource for planning international business strategy and researching new markets. The full Guide to Doing Business in Thailand is available through the button below.
Read More