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​ 

February 9, 2026
When unauthorized credit card transactions occur, who bears responsibility—the cardholder or the issuing bank? In Thailand, a landmark 2025 ruling by the country’s Supreme Court has clarified this question, establishing a stricter standard for banks in fraud disputes and significantly strengthening consumer protections. The case centered on disputed charges where a customer claimed their credit card had been used without authorization. The bank sued to recover the amount, and both the court of first instance and the Court of Appeal ruled in favor of the bank. However, the Supreme Court overruled their judgments and decided that the customer did not need to pay for the unauthorized transactions, placing liability squarely on the bank. This ruling was based on three key findings, which are outlined below. Finding 1: Insufficient Expert Testimony In this case, the bank bore the burden of proving matters related to the credit card system’s manufacture, design, security, and operation, as required under the Consumer Case Procedure Act B.E. 2551 (2008). To meet this requirement, the bank presented testimony from two employees in its credit card department regarding ’security measures and issuance procedures. However, the Supreme Court found these witnesses unqualified as experts, as they did not present technical or academic evidence and did not possess specialized expertise in credit card technology. As a result, their testimony failed to establish that the bank’s credit card technology was sufficiently secure against fraudulent misuse. Finding 2: Contradictory Terms and Conditions The bank’s own credit card terms and conditions included a provision acknowledging that despite the card’s EMV security standards, cardholders must still exercise caution to prevent unauthorized access. The Supreme Court interpreted this clause as an explicit admission that credit card systems remain vulnerable to hacking and fraud, even with high-level security measures in place. This acknowledgment undermined the
February 4, 2026
On November 18, 2025, Vietnam’s Ministry of Finance released for public consultation a draft decree on administrative sanctions in the field of crypto assets and crypto asset markets (the “Draft Decree”), intended to implement Resolution No. 05/2025/NQ-CP dated September 9, 2025, on the pilot crypto asset market in Vietnam (“Resolution 05”). While Resolution 05 sets out who may participate and under what conditions, the Draft Decree addresses a more practical question for market participants, i.e., what happens if those conditions are not met. In doing so, the Draft Decree offers important insight into how Vietnamese regulators intend to supervise, discipline, and ultimately shape the crypto market during the pilot phase. Regulatory Scope and Overall Sanctions Architecture The Draft Decree applies to both domestic and foreign organizations and individuals engaging in crypto-related activities in Vietnam’s market. Covered entities include: (i) crypto asset issuers; (ii) crypto asset service providers, including trading platforms and market operators; (iii) Vietnamese and foreign investors participating in the pilot market; and (iv) other organizations involved in the offering, issuance, or provision of crypto-related services in Vietnam. The breadth of this scope is deliberate. It appears to reflect a regulatory view that cross-border structures, offshore platforms, and indirect participation may not necessarily insulate market actors from compliance obligations once they operate within the pilot framework. For the crypto industry, this may mark a shift from regulatory ambiguity toward a more explicit articulation of jurisdictional reach. At first glance, the Draft Decree’s monetary penalties appear restrained. The maximum fine per administrative violation is capped at VND 200 million (approx. USD 7,700) for organizations and VND 100 million (approx. USD 3,800) for individuals. However, focusing solely on fine levels risks missing the point. The Draft Decree also places great regulatory weight on supplementary sanctions and corrective measures, including: (i)
January 26, 2026
Tilleke & Gibbins has contributed an updated Vietnam chapter to Foreign Investment Review 2026, a recently published global guide to the legal and regulatory environment for foreign investment in 25 jurisdictions worldwide. Published and distributed by Lexology Panoramic, the guide discusses law and policy on oversight of foreign investment, regulatory frameworks, procedural requirements, and other important stipulations for foreign investors. The Vietnam chapter was prepared by Kien Trung Trinh, a partner in the Tilleke & Gibbins’ Hanoi office, Dung Thi Phuong Le, an associate in the firm’s office in Ho Chi Minh City, Nguyen Thi Huong Nguyen, associate in Hanoi, and Ngan Thuc Nguyen, paralegal in Ho Chi Minh City. The Vietnam chapter covers the following topics: Law and Policy: Government policies and practices, main laws and their scope of application (including details on investment promotional measures), definitions, rules for state-owned enterprises and sovereign wealth funds, relevant authorities and oversight, and national interest provisions. Procedure: Jurisdictional thresholds, national interest clearance, securing approval, the review process for competition clearance and associated penalties, involvement of authorities, facilitation of clearance, and post-closing regulatory powers. Substantive assessment: Substantive tests for clearance, authorities’ consultation with other countries and other relevant parties, transactional prohibitions and objections, mitigating arrangements and challenges to a decision, and protection of confidential information. Recent cases, updates, and trends: Relevant recent case law, key recent and ongoing developments. A PDF of the Vietnam chapter can be accessed through the button below. Tilleke & Gibbins also contributed the Cambodia, Laos, and Myanmar chapters to Foreign Investment Review 2026. Readers can also gain 30 days of complementary access to the full Foreign Investment Review 2026 guide and the rest of Lexology Panoramic’s varied offerings through this link.
January 26, 2026
Tilleke & Gibbins has contributed an updated Myanmar chapter to the recently published Foreign Investment Review 2026, a global guide to the legal and regulatory environment for foreign investment in 25 jurisdictions worldwide. Published and distributed by Lexology Panoramic, the guide discusses law and policy on oversight of foreign investment, regulatory frameworks, procedural requirements, and other important concerns for foreign investors. The Myanmar chapter was prepared by Nwe Oo and Aye Thuzar Hlaing, senior associates in Tilleke & Gibbins’ office in Yangon. The Myanmar chapter covers the following topics: Law and Policy: Government policies and practices, main laws and their scope of application (including details on investment promotional measures), definitions, rules for state-owned enterprises and sovereign wealth funds, relevant authorities and oversight, and national interest provisions. Procedure: Jurisdictional thresholds, national interest clearance, securing approval, the review process for competition clearance and associated penalties, involvement of authorities, facilitation of clearance, and post-closing regulatory powers. Substantive assessment: Substantive tests for clearance, authorities’ consultation with other countries and other relevant parties, transactional prohibitions and objections, mitigating arrangements and challenges to a decision, and protection of confidential information. Recent cases, updates, and trends: Relevant recent case law, key recent and ongoing developments. A PDF of the Myanmar chapter can be downloaded through the button below. Tilleke & Gibbins also contributed the Cambodia, Laos, and Vietnam chapters to Foreign Investment Review 2026. Readers can also gain 30 days of complementary access to the full Foreign Investment Review 2026 guide and the rest of Lexology Panoramic’s varied offerings through this link.