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

August 18, 2026

Thailand Proposes Expanded KYC and Due Diligence for Cash-related Transactions

Subscribe to Updates

The Bank of Thailand (BOT) is seeking public comment on proposed amendments that would significantly expand know-your-customer (KYC) and customer due diligence (CDD) requirements for cash-related transactions at financial institutions (FIs) and specialized financial institutions (SFIs). Released on August 5, 2026, the proposed regulation would supersede BOT Notification No. 16/2569, which focused primarily on cash withdrawal transactions. The public comment period is open through September 3, 2026.

The amendments reflect concerns that FIs and SFIs may be used to facilitate the movement, concealment, and conversion of criminal proceeds, potentially damaging institutional operations and public confidence in the financial system.

Expanded Scope of Covered Transactions

The most significant change is the broadening of the definition of “cash-related transactions.” Previously, the regulation covered only cash withdrawals and uncrossed check withdrawals. The amended regulation extends coverage to include:

  • Cash deposits, check deposits, or receipt of funds from the public not in the form of deposit accounts;
  • Thai baht (THB) banknote exchange (different denominations);
  • Receipt of cash for issuing checks and drafts; and
  • Purchase, sale, or exchange of foreign banknotes.

Mandatory Identity Verification and Risk Management

For all cash-related transactions, FIs and SFIs must require customers, or authorized or delegated persons, to present identification or verify their identity before every transaction, including one-time (walk-in) transactions. Specific identification requirements vary by transaction type, customer nationality, and channel (branch vs. electronic).

FIs and SFIs must also establish comprehensive risk management processes and procedures for cash-related transactions. These requirements include identifying customers or authorized representatives in accordance with transaction-specific verification standards, analyzing customer behavior, implementing risk-management measures proportionate to the customer’s risk profile, and recording abnormal behavior in relevant systems. The BOT also encourages institutions to proactively guide customers toward transaction channels that offer greater traceability than cash.

For corporate customers in high-risk business sectors—including foreign exchange, real estate, gems, gold and other precious metals, and high-value luxury goods—FIs and SFIs must request additional information on the source of funds, assets, income, or wealth of the persons whose cash the entity is depositing.

Enhanced Due Diligence Threshold

When an unusual transaction is detected, or when a customer’s cash-related transactions across all channels—including branches, electronic branches/devices, and banking agents—total THB 5 million or more (or equivalent) within one day, the FI or SFI must take the following actions depending on the transaction type:

  • Withdrawals or uncrossed checks: Request information on the transaction purpose.
  • Deposits: Request information on the source of funds (and purpose, if conducted by an authorized person).
  • Money exchange: Request both the source of funds and the transaction purpose.

The institution must also assess whether the transaction is consistent with the customer’s profile and normal behavior. If inconsistencies, unreasonableness, or grounds for suspicion are found, the transaction must be classified as high-risk, triggering enhanced due diligence (EDD).

Refusal of Transactions and Escalation

If EDD cannot be completed but the customer provides a reasonable justification or demonstrates necessity for the cash-related transaction, the FI or SFI may proceed under its risk management framework, provided that a senior manager above the branch manager level approves and the customer is closely monitored. If the customer cannot demonstrate reasonable necessity, the institution must refuse the transaction and report it to the Anti-Money Laundering Office (AMLO) as required by law.

Monitoring, Reporting, and Customer Care

FIs and SFIs must establish processes to monitor, detect, and review customer cash-related transaction behavior, set appropriate risk levels, and regularly update these processes. They must also maintain records relating to customer identification, transaction purposes, source-of-funds information, transaction behavior, and information obtained through EDD reviews for regulatory, audit, and internal control purposes. Institutions must prepare and submit reports on abnormal financial behavior or cash-related transactions in the format prescribed by the BOT. Additionally, FIs and SFIs must have appropriate, prompt, and fair processes to assist customers adversely affected by cash-related transaction risk management measures where a transaction is later found not to be abnormal.

Proposed Effective DatesThe BOT has proposed an effective date of October 15, 2026, for the main provisions. Additional EDD requirements for specified legal entities would become effective on April 15, 2027. For SFIs, the timeline will be determined following Ministry of Finance consent.

Next Steps

FIs and SFIs should assess their cash-related transaction risk management frameworks for compliance gaps given the expanded scope. Corporate clients in high-risk industries—including real estate, gems and precious metals, foreign exchange, and luxury goods—should prepare for heightened source-of-funds due diligence. Comments may be submitted through September 3, 2026.

Related Professionals

Industries

Fintech

Practices

Banking and Finance

Compliance and Investigations

Corporate/M&A

Location

RELATED INSIGHTS​ 

November 24, 2025
A recent warning from the Central Bank of Myanmar (CBM) against cryptocurrency use upholds the country’s ongoing strategy of enforcing strict prohibitions on unauthorized cryptocurrency activities while also promoting the controlled development of a central bank digital currency (CBDC). The CBM’s warning, issued November 16, 2025, reminded the public of announcements in May 2019 and a notification in May 2020 confirming that all online and offline cryptocurrency transactions are strictly prohibited. The CBM also clarified that no financial institution in Myanmar is authorized to deal with digital currencies. The warning highlighted global risks, such as money laundering, scams, tax evasion, hacking, and severe financial losses caused by price volatility and insufficient regulation. The CBM urged the public to use only legitimate banking channels and avoid illegal cryptocurrency activities. The warning comes five months after the CBM issued a notification announcing the formation of the Central Committee for the Issuance of a Central Bank Digital Currency. This committee includes senior CBM officials, representatives from relevant ministries and the banking sector, and technology experts. Its main role is to research CBDC models, test secure digital payment systems, and ensure that any future implementation aligns with Myanmar’s monetary policy and financial stability objectives. Taken together, these two actions illustrate the CBM’s continued pursuit of its dual strategy to promote innovation through CBDC development while prohibiting cryptocurrency use. Businesses should note that while CBDC pilot programs may appear in the future, cryptocurrencies remain off-limits.
Read More
November 7, 2025
Tilleke & Gibbins has contributed the Vietnam chapter to the latest edition of the Global FinTech Guide published by Multilaw. The guide provides a comprehensive overview of the legal and regulatory framework governing financial technology across major jurisdictions around the world. Compiled by experienced practitioners from Multilaw member firms, the Global FinTech Guide examines how technological innovation is transforming financial services and how regulators are adapting to developments such as digital payments, virtual assets, and online financial platforms. The publication offers comparative insights into regulatory regimes and presents detailed, jurisdiction-specific analysis for companies, investors, and entrepreneurs active in the FinTech sector. The Vietnam chapter, prepared by lawyers in Tilleke & Gibbins’ technology, media, and telecommunications team, surveys the key legal and regulatory developments shaping the country’s FinTech ecosystem. It covers the following areas: Payment services Asset and portfolio management Financial advisory and broking services (including robo-advisory and auto-trading) Trading platforms, social trading platforms, and signal following Crowdfunding, crowdinvesting, and crowdlending Distributed ledger technology (DLT) and cryptocurrencies Loan services, factoring, loan broking, and finetrading Identification Online banking services Initial coin offerings (ICOs) and token sales Insurtech Regtech and compliance management Know-your-customer (KYC) requirements Tilleke & Gibbins also contributed the Thailand chapter to the Global FinTech Guide. The full guide is available on the Multilaw website.
Read More
November 7, 2025
Tilleke & Gibbins has contributed the Thailand chapter to the latest edition of the Global FinTech Guide published by Multilaw. The guide offers an overview of the legal and regulatory environment for financial technology across key jurisdictions worldwide. Prepared by leading experts from Multilaw member firms, the Global FinTech Guide explores how innovation is reshaping the financial sector and how governments and regulators are responding to emerging technologies such as digital payment services, cryptocurrencies, and online financial advisory platforms. The publication enables quick comparison of regulatory frameworks and provides detailed country-level insights for investors, startups, and established financial institutions engaging in FinTech activities. The Thailand chapter, authored by lawyers in Tilleke & Gibbins’ technology and financial services teams, outlines the country’s evolving regulatory landscape for fintech operations. It addresses the following topics: Payment services Asset and portfolio management Financial advisory and broking services (including robo-advisory and auto-trading) Trading platforms, social trading platforms, and signal following Crowdfunding, crowdinvesting, and crowdlending DLT and cryptocurrencies Loan services, factoring, loan broking, and finetrading Identification Online banking services Initial coin offerings (ICOs) and token sales Insurtech Regtech and compliance management Know-your-customer (KYC) requirements Tilleke & Gibbins also contributed the Vietnam chapter to the Global FinTech Guide. The full guide is available on the Multilaw website.
Read More
September 24, 2025
On September 12, 2025, the Bank of Thailand (BOT) officially released its AI Risk Management Guidelines for Financial Service Providers, building upon the draft guidelines issued in June 2025. The guidelines reflect a balanced approach, encouraging innovation while safeguarding financial stability and consumer protection. The guidelines are targeted at all financial service providers, including financial institutions and special financial institutions under the Financial Institution Business Act, as well as payment providers under the Payment Systems Act. The guidelines apply to both AI systems developed in-house and those developed by third parties that are adopted for use by financial service providers. AI Risk Management Guidelines The two main pillars in managing AI risk are (1) governance of AI system implementation and (2) AI system development and security controls, consisting of the following key elements: 1. Governance Stakeholder roles and responsibilities. Boards and senior management assume accountability for decisions and operations involving AI systems, and are responsible for defining roles and responsibilities for AI oversight. This includes establishing an AI system usage policy, designating personnel responsible for AI risk management, and building awareness of AI-related risk within the organization. Organizations are expected to foster internal capabilities to use AI securely and avoid overreliance that could compromise business continuity or customer service. AI system usage policy. Policies governing AI usage should align with organizational goals, regulatory obligations, and recognized responsible AI frameworks—such as the FEAT principles (fairness, ethics, accountability, and transparency). These policies should be reviewed regularly to respond to technological advancements and evolving risk profiles. Risk management throughout the AI lifecycle. Risk management should encompass the entire AI lifecycle, from establishing risk appetite to implementing continuous risk assessment and control measures tailored to specific use cases. Financial service providers should assess risks and impacts of AI usage on operations and customer services.
Read More