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.