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August 27, 2026

Thailand Tightens Enforcement Against Nominee Land Ownership by Foreign Nationals

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On August 25, 2026, Thailand’s Ministry of Interior issued an urgent circular letter (No. MorTor 0515.2/Wor 19097) to all provincial governors, introducing enhanced enforcement guidelines for the investigation and prosecution of suspected nominee landownership by foreign nationals. The circular letter builds upon a prior circular letter issued on April 19, 2023 (No. MorTor 0515.2/Wor 7665), which first established the framework for provincial-level investigation committees and interagency cooperation on this issue.

Under Thailand’s Land Code, foreign nationals are generally prohibited from owning land. To circumvent this restriction, some foreign nationals have historically used Thai nominees, whether individuals or Thai-registered juristic persons, to hold land on their behalf. Various government enforcement measures have been progressively strengthened in recent years.

The new circular letter introduces three key measures:

  1. Expanded investigation committees. Provincial authorities must add representatives from specialized investigative agencies (such as local police superintendents) to the existing Fact-Finding and Investigation Committees, giving them broader access to shareholding data, tax records, immigration information, financial records, and evidentiary materials.
  2. Proactive screening of juristic persons. Provincial Land Offices are now required to actively screen and flag juristic persons (companies, partnerships, etc.) that show risk indicators of acting as nominees for foreign land ownership. The screening results must be referred to the investigation committees, which will determine whether the entity qualifies as a “foreign national” under the Land Code or was set up to circumvent the law.
  3. Two-track enforcement actions. Based on the committee’s findings, enforcement may consist of one or both of the following:
    • Land disposal: If a juristic person is classified as a foreign national under the law, the provincial governor sets a deadline for the entity to dispose of the land under the Land Code.
    • Criminal prosecution: If the entity was established specifically to hold land on behalf of a foreign national in circumvention of the law, land officers must file a criminal complaint and follow the case through to final judgment.

This circular letter represents a continued escalation in Thailand’s enforcement against nominee land ownership. It formally calls for active, province-wide screening of corporate landholders through strengthened multiagency investigation committees, exposing foreign nationals with land arrangements structured through Thai entities, as well as the Thai nationals and professionals who facilitate them, to heightened scrutiny and potential criminal liability, while standardizing enforcement across all provinces to ensure a consistent nationwide approach.

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