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 27, 2026

Thailand Proposes Overhaul of Licensing Framework for Money Changers

Subscribe to Updates

The Bank of Thailand (BOT) is seeking public feedback on a proposed overhaul of the regulatory framework for licensed money changers authorized by the finance minister, under the Exchange Control Act, to buy and sell foreign banknotes separately from commercial banks and specialized financial institutions. The BOT published the draft principles on August 19, 2026, for public consultation, with comments accepted through September 18, 2026.

If adopted in its current form, the new framework would substantially raise licensing standards, require existing licensees to undergo a review and upgrade process, temporarily freeze new applications in 2027, and reduce application intake rounds from 2028 onward, with significant implications for both existing operators and prospective new entrants.

The overhaul initiative stems from the BOT’s recognition of a need to prevent the use of licensed money changers as channels for financial crime. The stated objectives are to build public confidence, ensure the safety of financial service users, and align the supervisory framework with the current risk profile of the business and evolving market conditions.

Upgraded Licensing Standards

The BOT intends to significantly revise the licensing framework, including requirements relating to registered capital, branch management, operational standards, and customer transaction limits. Detailed criteria have not yet been released and are expected to be subject to further consultation. All existing licensees will be required to upgrade to meet the new standards and submit evidence of compliance for BOT review on a case-by-case basis. Existing licensees that are unable to satisfy the upgraded requirements may face regulatory consequences, subject to the final framework and BOT review process.

Freeze and Reopening

The BOT will temporarily stop accepting new license applications throughout 2027 to focus resources on inspecting and upgrading existing money changers. Any party wishing to obtain a new money changer license must submit its application by the end of December 2026.

New applications will be accepted again once the upgraded supervisory framework is in place in 2028. From that point onward, the BOT may reduce application intake rounds from four per year to two per year to improve the quality and efficiency of assessments under the new criteria.

To summarize the timing of these developments:

  • End of December 2024: Close of current new applications acceptance period.
  • Throughout 2027: Application freeze; BOT inspects and upgrades all existing licensees.
  • 2028: Reopening of new applications under the upgraded framework; possible reduction to two intake rounds per year.

Implications for Existing Money Changers

Every current licensee will need to meet significantly higher standards across capital, branch management, operational standards, and customer transaction limits. This will likely require substantial capital investment, operational restructuring, and system upgrades to satisfy the BOT’s individual review. All enhancement measures must be completed and submitted during 2027, giving money changers a limited compliance window. Money changers unable to meet the new criteria face the risk of license revocation.

Implications for Prospective New Entrants

Any entity planning to enter the money-changing business must file its application by December 2026 or face a year-long wait until 2028. Even after reopening, the potential halving of application intake rounds will reduce the windows available for new market entry going forward.

Market Impact

Higher capital and operational requirements may push smaller money changers out of the market, potentially leading to industry consolidation. However, the reforms are designed to enhance the safety and reliability of money-exchange services for end users and the broader financial system.

Existing licensed money changers should assess their current compliance posture against the anticipated new standards and begin preparing for the 2027 upgrade deadline. Prospective new entrants should prioritize filing their applications before the December 2026 cutoff to avoid the temporary freeze period. All interested parties should consider submitting comments during the public consultation period, which runs through September 18, 2026.

Related Professionals

Industries

Fintech

Practices

Banking and Finance

Location

RELATED INSIGHTS​ 

June 23, 2026
On May 14, 2026, Thailand published a ministerial regulation in the Government Gazette to prescribe measures for prevention and suppression of technology crimes. The regulation creates a comprehensive procedural framework for returning money and digital assets to victims of technology crimes. It will take effect 90 days after publication (in mid-August 2026), giving affected entities a limited window to prepare. Mandatory Reporting Obligations for Financial Institutions When a deposit account, e-money account, or digital asset wallet is frozen in connection with a technology crime, the relevant financial institution or business operator must report transaction data to the Anti-Money Laundering Office (AMLO) via AMLO’s designated electronic system. Required data elements include account numbers (sender and receiver), names, identification or passport numbers, legal entity registration numbers, phone numbers, remaining balance, damage amount, transaction reference numbers, and the bank case ID. Institutions that already share data through the information-sharing system under the emergency decree are deemed to have satisfied this reporting obligation, creating an incentive for platform participation. When the Royal Thai Police or the Department of Special Investigation seize or freeze assets related to technology crimes, they must provide AMLO with investigation reports, complaint evidence, money-trail data, and account statements. Notification and Claims Process Once the AMLO secretary-general approves verified reports of a technology crime, the account information of persons connected to the crime will be published in the Government Gazette, triggering a 90-day window for victims to file claims and for related persons to file objections. Officers will also publish details on AMLO’s electronic media and send registered mail to identified victims, which will be deemed received after 7 days domestically or 15 days internationally. Victims have 90 days from the date the crime is published in the Government Gazette to file claims through AMLO’s electronic system. Claims must include
Read More
May 25, 2026
Thailand published new rules on May 1, 2026, establishing clear procedures for how the Anti-Money Laundering Office (AMLO) handles digital assets seized during criminal and money laundering investigations. Taking effect the following day, the Regulation of the Anti-Money Laundering Board on the Custody and Management of Seized or Frozen Assets (No. 3) B.E. 2569 applies to digital asset businesses, cryptocurrency holders, and anyone subject to asset seizure under Thailand’s anti-money laundering laws. For the first time, authorities now have a detailed roadmap for transferring seized digital property from private or foreign control into secure state custody. Digital asset businesses holding customer assets under investigation must be prepared to comply with these rules compelling repatriation of such assets in enforcement actions. Expanded Definition of Digital Assets The regulation defines digital assets to include not only those covered by Thailand’s existing digital asset business law but also any other property that can be stored using the same methods as digital assets. This broad formulation means the custody rules will apply to emerging blockchain-based assets and tokenized property that may not yet fall within the statutory definition of a digital asset business, giving authorities flexibility as the technology evolves. Mandatory Transfer to Domestic Custody When digital assets are held with service providers outside Thailand, AMLO will first attempt to transfer them to an account the office maintains with a licensed domestic digital asset business operator. If the domestic operator does not support that particular asset, the office will instead move the assets to its own cold wallet (offline, internet-isolated storage system). If neither option is feasible, the seizing official will report the situation to the Anti-Money Laundering Committee for alternative instructions. A similar hierarchy governs assets held in an accused party’s private wallet or by any third party that is not a
Read More
April 23, 2026
Vietnam has progressively positioned blockchain as a strategic technology within its broader digital transformation agenda over the past decade. From early policy orientations to more recent legislative developments, the regulatory approach has gradually shifted from high-level recognition to more concrete legal integration. Against this backdrop, a new draft decree regulating activities relating to product and goods identification, authentication, and traceability (the “Draft Decree”) marks a notable turning point. Rather than merely referencing blockchain as a policy priority, the Draft Decree incorporates blockchain directly into a nationwide regulatory system, positioning it as part of the underlying infrastructure for data governance and public administration in relation to the management, verification, and traceability of product-related data. Evolution of Vietnam’s Blockchain Legal Framework: The Draft Decree in Context Vietnam’s blockchain legal framework has developed in several distinct phases. The first phase, beginning around 2019, was characterized by high-level policy recognition in several resolutions of the Party Central Committee. Particularly, blockchain was identified as part of the broader category of digital technologies critical to industrial modernization and participation in the Fourth Industrial Revolution. These resolutions did not regulate blockchain directly, but established its strategic importance at the national level. The second phase (2023 to 2025) saw the introduction of national strategies and technology policies that more explicitly recognized blockchain as a priority technology. Those policies collectively signaled a clear policy commitment to developing blockchain infrastructure and applications. However, these instruments remained largely at a policy-level and did not establish binding regulatory frameworks. The third phase (from 2025) involves the gradual integration of blockchain into sectoral legislation. Laws such as the Law on Digital Technology Industry (2025), the Law on Personal Data Protection (2025), and the Law on Science, Technology, and Innovation (2025) have introduced concepts such as digital assets, crypto assets, and even specific
Read More
March 5, 2026
Thailand’s Securities and Exchange Commission (SEC) has filed a criminal complaint against a licensed digital asset broker, its overseas trading platform, and its executives for allegedly operating an unlicensed digital asset exchange targeting Thai customers. The case marks an escalation in the SEC’s enforcement efforts against unlicensed offshore platforms that attempt to serve Thai users through local licensed entities. Criminal Complaint On February 20, 2026, the SEC filed a criminal complaint with the Economic Crime Suppression Division against a local licensed digital asset broker, its overseas global trading platform, and its executives. The SEC alleges that the parties violated the Digital Asset Business Emergency Decree B.E. 2561 (2018) by cooperatively operating a digital asset exchange business on a cross-border basis since 2023 without the required SEC license. According to the SEC, the local broker promoted the overseas platform’s services to the public through Thai-language posts on social media channels, with services available exclusively to customers residing in Thailand. Access to the global platform was provided through the local broker’s website and mobile application. Customers who registered for the local broker’s services were automatically granted access to the global platform without having to undergo a separate identity verification process. The SEC also found that the local broker provided back-office system support services to the global platform. The SEC considers these activities to constitute joint operation of an unlicensed digital asset exchange. The former executives of the local broker are being held liable as the responsible persons during the relevant period. The SEC emphasized that the complaint initiates the criminal process, and the decision to prosecute or convict the accused parties will ultimately be made by law enforcement authorities and the criminal courts. Platform Blocking The SEC has also coordinated with the Ministry of Digital Economy and Society to block public
Read More