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

May 25, 2026

Thailand Strengthens State Custody Procedures for Seized Digital Assets

Subscribe to Updates

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 licensed domestic digital asset business operator. AMLO will transfer them without delay to another licensed domestic provider or, if that proves impossible, to the office’s cold wallet. In either scenario, the seizing official must document the asset account details, asset type, quantity, and value as of the seizure date, and the identity of the responsible custodian.

All fees and expenses incurred in transferring seized digital assets will be deducted directly from the assets themselves. The custodian will be required to report these costs to the secretary-general of the Anti-Money Laundering Board and notify the seizing official.

Cold Wallet Security Standards

The regulation requires cold wallets to use encryption key storage methods that are not connected to the internet. While the text does not enumerate every technical specification, it establishes that offline storage is the baseline security standard and that only designated personnel may maintain custody of these keys. If obstacles prevent compliance with these prescribed methods, the responsible custodian must seek approval from the AMLO secretary-general for alternative storage that still provides adequate security.

Practical Implications

The regulation eliminates discretion over whether and how seized digital assets are moved into state custody. Digital asset businesses should expect that any assets seized from their platforms or their customers will be transferred swiftly to another licensed provider or into offline storage. Operators holding customer funds under investigation must be prepared to facilitate these transfers without delay and to cooperate with documentation requirements. Businesses and individuals who hold digital assets with foreign service providers should also understand that Thai authorities now have a clear legal pathway to compel repatriation of those assets during enforcement actions.

For victims of money laundering, these regulations offer new hope for asset recovery. The clear procedures for seizing and securing digital assets—whether held domestically or abroad—create a more effective enforcement framework that can help trace, freeze, and ultimately return stolen funds to those harmed by financial crimes.

Related Professionals

Industries

Fintech

Technology

Practices

Dispute Resolution and Litigation

Location

RELATED INSIGHTS​ 

April 21, 2026
Thailand’s Personal Data Protection Committee (PDPC) has launched a public consultation period on a draft notification setting out criteria for data subject access requests (DSARs). The draft notification addresses practical uncertainties in handling DSARs by introducing standardized procedural requirements for data controllers. The consultation period runs from April 16 to May 15, 2026. The notification will enter into force 30 days from the date of its publication in the Government Gazette. Key Features of the Draft Notification The draft notification covers the following key areas: Scope of information subject to access. Data controllers must enable data subjects to access at least the following upon request: (1) personal data collected directly from them; (2) personal data obtained from other sources; and (3) the source of personal data obtained from other sources without consent. Information required under section 23 of the PDPA and information that must be recorded pursuant to section 39 of the PDPA—such as the categories of personal data collected and purposes of processing—must also be made available. Submission channels and formal requirements. Data controllers must provide at least in-person and postal channels for DSARs, while electronic or other channels are optional. Requests may be made either directly by the data subject or through an authorized representative, and must be signed and include sufficient identifying information, a preferred response method, and DSAR details. Identity verification documents (and proof of authority if the request is through a representative) are required, and additional documentation may be requested for verification or communication purposes. Data controllers may use different verification methods for DSARs submitted via electronic or other channels, provided this does not create undue obstacles to the exercise of data subject rights. Verification and response timelines. Data controllers must complete preliminary verification within seven business days of receiving a request. If a
Read More
April 10, 2026
Thailand has introduced new regulatory guidance requiring digital platform operators to adopt structured, transparent, and fair fee practices. On March 16, 2026, the Electronic Transactions Development Agency (ETDA) published Announcement No. DPS 2/2569, titled “Guidelines for Transparency and Fairness in Digital Platform Service Fee Determination,” issued under the Royal Decree on Digital Platform Service Business Operations B.E. 2565 (2022). The guidelines establish a framework governing how digital platform operators should set, disclose, and adjust fees charged to users and related service providers such as logistics and payment providers. Although framed as best-practice guidance rather than legally binding rules with explicit penalties, the guidelines carry regulatory weight under the royal decree and represent a significant step toward structured governance of digital platform fee practices in Thailand. The guidelines establish various transparency principles and divide fees into two distinct categories—compulsory and additional—with specific governance principles for each. Transparency Principles The guidelines recommend that digital platform operators adopt several transparency measures to ensure that users can fully understand the costs of using a platform. Fee catalog. All fees should be consolidated into a single, accessible location, which should include the fee name, definition, scope of covered services, calculation methodology, rate, billing period, and calculation examples. Minimum service disclosure. Operators should disclose the minimum service that users can expect, such as baseline visibility, product listing capabilities, access to transaction data, and back-end dashboard access. Price structure disclosure. Operators should disclose the categories of costs underlying their fees, such as system maintenance, cybersecurity, and operational costs. While exact cost figures need not be made public, operators should be able to provide numerical data to regulators upon request. Clear fee formulas. Fee calculations should be simple and easy to understand—for example, percentage of net sales, cost per order, or cost per product listing. Operators should
Read More
April 10, 2026
As digital commerce continues to reshape consumer behavior in Thailand, the Office of the Consumer Protection Board (OCPB) has been taking steps to review and update key regulations for online platforms. The OCPB has had a particular focus on addressing the risks posed by e-marketplace businesses—from misleading product information to fraudulent online transactions. Some of the regulator’s current legislative efforts related to Thailand’s labeling regulations as well as potential changes to the country’s law on direct sales and marketing. Proposed Changes to Consumer Protection Labeling Regulations On February 24, 2026, the OCPB convened a public hearing to review the Notification of the Committee on Labels re: Specification of Goods as Controlled Label Goods B.E. 2565 (2022) and its annex issued under the Consumer Protection Act. The closed-door session, which started the OPCD’s process of seeking feedback on the proposed changes, brought together representatives from government agencies, business operators, and consumer groups. The OCPB explained that its review of the labeling regulations aims to address regulatory gaps arising from evolving commercial practices, particularly the expansion of e-commerce and cross-border transactions. Authorities highlighted recurring issues involving product information that is unclear, incomplete, or potentially misleading in digital sales channels. The proposed revisions are intended to improve consumers’ access to accurate and complete product information, ensure that label disclosures remain relevant amid the growth of e-commerce, and strengthen protections against deceptive or misleading digital advertising. The review is being undertaken pursuant to the Consumer Protection Act B.E. 2522 (1979). As part of the initiative, the OCPB signaled a potential update to the categories of “controlled label products” as well as enhanced disclosure obligations for business operators, with the broader aim of promoting greater transparency, reinforcing operator accountability, and aligning Thailand’s labeling framework with current market conditions. The OCPB secretary general emphasized that
Read More
April 9, 2026
As part of its ongoing public consultation process for the development of new practical guidelines under the Personal Data Protection Act B.E. 2562 (2019) (PDPA), Thailand’s Personal Data Protection Committee (PDPC) held a two‑day public hearing on April 1–2, 2026. The hearing followed an online questionnaire and stakeholder engagement activities conducted in March 2026 and reflects the PDPC’s continued efforts to develop guidance that aligns international regulatory standards with Thai operational realities. The public hearing provided a forum for participants from both the public and private sectors to exchange views with the PDPC on the proposed guidance so that it responds to the needs of the business community while supporting effective and balanced enforcement of the PDPA. The PDPC emphasized that the consultation process is part of a wider policy objective to build trust in the convenient, secure, and internationally aligned exchange of data. Structure of the Consultation Process According to the PDPC, the initiative to develop the draft PDPA guidelines is being implemented through three core phases: Review of international best practices. The PDPC has conducted a comparative review of data protection guidance and regulatory approaches in jurisdictions with internationally recognized standards, including Singapore, the United Kingdom, the European Union (EU), and Japan. These materials are intended to serve as a reference point for developing practical recommendations across key subject areas under the PDPA. Identification of practical issues and challenges. To ensure that the guidelines respond to real‑world compliance challenges in Thailand, the PDPC has gathered views from a broad range of stakeholders across the public sector, the private sector, and the general public. This phase included focus group discussions and questionnaires aimed at identifying areas to provide organizations with greater clarity and consistency on regulatory expectations. Preparation of draft guidelines. Insights from the comparative study and stakeholder
Read More