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 19, 2025

Thailand Launches Measures to Suppress Corporate Mule Accounts

On January 1, 2025, the Department of Business Development (DBD) in Thailand’s Ministry of Commerce implemented new stringent corporate registration screening measures in collaboration with several other government agencies to prevent entities from opening corporate mule accounts to commit criminal activities in Thailand.

The DBD’s Order of the Office of Central Company and Partnership Registration No. 3/2024 stipulates a new method for registering the establishment of partnerships and limited companies for people who have been involved in underlying crimes or who are owners of bank accounts that are being used for underlying crime, as per the notification of the Anti-Online Scam Operation Center (AOC) to the Anti-Money Laundering Office (AMLO) and the collated AMLO list of such persons.

The order establishes the following key requirements:

  • Managing partners and directors of partnerships and limited companies, respectively, whose names have been listed by the AMLO as a person who is involved in an underlying offense, or as the owner of a bank account being used for the underlying offense, must appear before the registrar in person.
  • The concerned persons cited on the AMLO list must provide valid documentation of their identity to the DBD registrar (e.g., national identification card, government official identification card, government or state enterprise employee identification card, alien identification card, passport, document used in lieu of a travel document, or other similar documents with photo identification).

This collaboration between the DBD and various relevant government agencies aims to eradicate the problem of fraudsters using mule accounts set up under legally established entities to deceive the public. It also seeks to enhance checks and screening of corporate mule accounts that are used to carry out criminal activities such as money laundering or cybercrime. These actions are part of the Thai government’s broader policy to suppress economic crimes.

For more details about the new DBD regulations, or on any aspect of business registration in Thailand, please contact Penrurk Petchmani at [email protected].

RELATED INSIGHTS​ 

October 7, 2026
On August 5, 2026, the State Bank of Vietnam (SBV) issued Circular No. 39/2026/TT-NHNN (Circular 39) amending and supplementing a number of articles of Circular No. 16/2014/TT-NHNN (Circular 16). Circular 39 took effect on September 19, 2026, establishing a framework for offshore credit institutions to conduct cross-border payments through accounts held in Vietnam. Key Provisions Prior to the issuance of Circular 39, Circular 16 allowed non-residents, including offshore credit institutions, to use bank accounts they had opened at Vietnam-based licensed banks only for their own permitted transactions (e.g., payment for current transactions or capital transactions), not for providing cross-border payment services to third parties in Vietnam. Circular 39 provides a more flexible framework by expressly permitting offshore credit institutions to utilize both foreign currency and VND accounts they have opened at Vietnam-based licensed banks for cross-border payment activities, including: Processing international payment and fund transfer transactions for their customers under written agreements between the offshore credit institutions and licensed banks in Vietnam; and Conducting receipt and payment transactions through such accounts. The offshore credit institution’s use of accounts in Vietnam and other related matters must be governed by a written agreement between the credit institution and the licensed bank. This agreement serves as the operational basis for cross-border payment services, while remaining subject to Vietnamese law. Practical Implications Circular 39 opens a significant new channel for correspondent banking activity in Vietnam. International banks, foreign payment service providers, and fintech companies operating in or seeking to enter the Vietnamese market should take note, as this new legal framework facilitates expanded cross-border payment capabilities. From a market perspective, Circular 39 marks a shift to greater regulatory certainty. When the law was unclear, foreign fintech companies or credit institutions tended to rely on close engagement with Vietnam-based licensed banks and a higher
October 7, 2026
M&A specialists at Tilleke & Gibbins have contributed the Vietnam chapter to Private M&A 2027, a guide published by Lexology Panoramic. The publication provides practical insights into private mergers and acquisitions frameworks in jurisdictions worldwide. The Vietnam chapter addresses key aspects of private M&A transactions, including: Structure and process, legal regulation, and required consents Advisers, negotiation, and documentation Due diligence and disclosure obligations Pricing, consideration, and financing Conditions, preclosing covenants, and termination rights Representations, warranties, indemnities, and postclosing covenants Taxation of transfers Employees, pensions, and benefits Recent legal, regulatory, and market practice developments The chapter highlights how Vietnam’s legal framework governs private acquisitions and disposals, outlines typical transaction processes and structures, and provides guidance on common regulatory and practical considerations. It also notes recent trends, including increased scrutiny of merger control filings by the Vietnam Competition Commission and regulatory changes affecting M&A approvals. The full Vietnam chapter is available as a PDF through the button below. Readers can also gain 30 days of complimentary access to Private M&A 2027 and Lexology Panoramic’s full library of resources through this link.
October 2, 2026
On July 24, 2026, a new 12.5% Section 301 tariff took effect on most imports from Thailand into the United States. The tariff was imposed by the Office of the US Trade Representative (USTR) under Section 301 of the Trade Act of 1974, following a finding that Thailand had failed to impose and effectively enforce a prohibition on imports of goods produced with forced labor. The new tariff replaced the temporary 10% Section 122 surcharge that had applied since February 24, 2026, following the US Supreme Court’s invalidation of the prior tariffs imposed under the International Emergency Economic Powers Act (IEEPA). The 12.5% tariff is not the only potential source of additional US duties on Thai-origin goods. Thailand is also subject to a separate Section 301 investigation concerning structural excess manufacturing capacity, which could result in additional duties. Unlike the Section 122 surcharge, which was capped at 15% and limited to 150 days, Section 301 provides a more flexible framework for imposing and maintaining trade measures. Section 301 actions are generally subject to a four-year termination rule but may continue following a review if continuation is requested. The new tariff therefore represents a potentially longer-term change in the tariff treatment of Thai-origin goods entering the US market. This article explains the legal and policy developments that led to the new tariff, how the Section 301 tariff differs from the tariff regimes that preceded it, Thailand’s response and ongoing negotiations with the United States, and the practical implications for businesses that manufacture, export, import, or distribute goods between Thailand and the United States. From IEEPA to Section 122 to Section 301 IEEPA Era (April 2025–February 2026) Beginning in April 2025, the US administration imposed sweeping tariffs under the International Emergency Economic Powers Act (IEEPA), invoking national emergencies relating to trade
September 30, 2026
On September 15, 2026, Vietnam’s Ministry of Finance (MOF) released for public consultation a draft circular on reporting and information disclosure in the pilot crypto asset market. The draft implements Resolution No. 05/2025/NQ-CP on the Pilot Implementation of the Crypto Asset Market in Vietnam and provides further detail on how licensed crypto asset service providers (“CASPs”) will be supervised once the market becomes operational. The draft indicates a data-intensive supervisory model, with licensed CASPs serving as the first line of market oversight. Public Disclosure Requirements The draft imposes detailed public disclosure requirements on CASPs, aimed primarily at market transparency. CASPs and crypto asset issuers must make disclosures in both Vietnamese and English, retain reported and disclosed information for at least 10 years, and keep information published on their websites accessible for at least five years. For CASPs, disclosure obligations arise both periodically and when specific events occur. A CASP must announce any crypto asset to be admitted to trading on its website at least seven days before trading begins and publish periodic financial statements. Certain extraordinary events and information requested by the MOF must generally be disclosed within 24 hours. CASPs must also provide ongoing market information. During trading hours, they must publish key trading data, including prices and volumes, daily highs and lows, average prices, the three best bid and offer levels, and transactions by foreign investors. By 9:00 a.m. each trading day, they must publish specified information on the previous day’s trading activity. Regulatory Reporting Requirements Separate from public disclosure, the draft requires CASPs to provide regulators with detailed information enabling ongoing supervision of their operations and the market. For market activity, CASPs must report decisions to admit or remove a crypto asset from trading within 24 hours, submit previous-day trading data to the State Securities Commission