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Compliance and Investigations

Compliance and Investigations

Key Contacts

Cambodia

Laos

Myanmar

Thailand

Vietnam

OVERVIEW

Guiding clients through cross-border compliance with deep local insight and regional expertise.

Tilleke & Gibbins’ compliance and investigations practice provides strategic counsel to clients navigating complex regulatory and enforcement landscapes across Southeast Asia. We advise on a broad range of white-collar matters, including internal investigations, government inquiries, criminal defense, asset recovery, and anti-corruption compliance.

Our team combines decades of experience with deep local insight and regional perspective to support clients in managing risk and responding effectively to sensitive, high-stakes issues. We regularly represent companies and executives before law enforcement bodies, criminal courts, and regulatory agencies in each respective jurisdiction, and collaborate across our offices in Cambodia, Indonesia, Laos, Myanmar, Thailand, and Vietnam to support cross-border matters.

With a strong understanding of Southeast Asian business culture and regulatory expectations, we deliver practical, commercially focused advice tailored to each client’s needs. Our commitment to integrity and excellence ensures that clients receive trusted guidance and robust representation in all aspects of compliance and investigations.

Experience

  • Advised a leading multinational pharmaceutical company on conducting an anticorruption compliance audit in its Thai subsidiary. Prior to the audit we provided advice to the client and its U.S.-based global anticorruption counsel on Thai anticorruption law and compliance issues in the Thai healthcare industry. After the audit, we reviewed relevant interview notes to identify potential red flags and areas for compliance enhancement.
  • Representing a world-leading manufacturer in a USD 200+ million global fraud case involving former employees in the company’s Thai operations. Among other things, we conducted employee investigations and interviews, advised on termination of employees, and liaised with the Crime Suppression Division of the Royal Thai Police, various embassies, the Anti-Money Laundering Office, and similar offices in other jurisdictions around the world.
  • Prepared anticorruption, anti-money laundering, and unfair competition compliance policies for a multinational corporation with operations in over 100 countries, including countries with extraterritorial anticorruption laws such as the FCPA. We also advised on the implementation of our client’s compliance program in Thailand, which involved tailoring our client’s global compliance concerns to the local Thai jurisdiction.
  • Worked with a leading multinational law firm, and acted as local counsel on an internal corporate anticorruption investigation at the Thai subsidiary of a global beverage manufacturer. We assisted the client in interviewing employees to gather crucial information, reviewed evidence, and advised on various issues of Thai law, including anticorruption, tax matters, property, and regulatory licenses, among others, to help the client identify if alleged bribes actually took place.
  • Assisted an industry-leading provider of computer storage technologies and solutions, with an internal investigation and review of claimed wrongdoing by a senior-level Thai administrative employee. We conducted a thorough review of preliminary investigative reports to assist in our conduct of on-the-ground employee interviews and assessments, and provided detailed summaries and reporting of our investigative findings and advice on Thai law.
  • Acted for the Thai subsidiary of a multinational plate glass manufacturer in a high-stakes criminal investigation by Thailand’s Department of Special Investigation (DSI) for allegedly purchasing black market minerals for use by its manufacturing facility.
  • Assisted a multinational project management company in conducting an internal investigation involving bid rigging on energy and infrastructure projects in Thailand and across Southeast Asia. Our investigations uncovered significant wrongdoing by an employee, which motivated the client to revamp their internal policies to avoid similar situations in the future.
  • Advised several pharmaceutical companies on anticorruption regulations related to their business dealings and procurement contracts with Thai government hospitals.
  • Advised a global food and beverage company on an extensive internal anticorruption investigation in Thailand.
  • Assisted a multinational energy services company on an internal bid-rigging investigation in Thailand.
  • Advised a European pharmaceutical company on an internal fraud and anticorruption investigation in Vietnam.
  • Assisted a global energy services firm on defending an anticorruption investigation brought by the Thai authorities.
  • Designed and implemented a compliance, ethics, and health care professional dealings program across a client’s Southeast Asia offices.

PROFESSIONALS

RELATED INSIGHTS

September 28, 2026
On July 22, 2026, the government of Vietnam issued Decree No. 292/2026/ND-CP detailing the implementation of the Law on Foreign Trade Management (Decree 292). Decree 292 came into effect on September 5, 2026, replacing Decree No. 69/2018/NND-CP, and introduces several important changes to Vietnam’s foreign trade regime. Of particular relevance is the addition to the list of goods prohibited from importation of “products and goods extracted, produced, or manufactured wholly or partly through forced labor by enterprises, countries, or territories in accordance with relevant international treaties to which the Socialist Republic of Vietnam is a party.” This new prohibition introduces forced-labor considerations into Vietnam’s import compliance framework and may have practical implications for how businesses manage related risks across their operations and supply chains. Implementation of the New Prohibition According to Decree 292, the minister or head of the relevant ministerial-level agency is responsible for publishing the detailed list and corresponding harmonized system (HS) codes for each category of goods prohibited from export or import under its purview. Goods involving forced labor fall under the purview of the Ministry of Home Affairs. However, as of the date of this article, no corresponding list has been published specifying the goods to which the forced-labor prohibition applies, leaving businesses without official guidance on how the prohibition will be applied or enforced in practice. Nevertheless, this absence does not suspend the prohibition’s application. As Decree 292 has already taken effect, goods involving forced labor remain subject to the general legal framework applicable to goods prohibited from importation. In particular, Decree 169/2026/ND-CP provides for administrative penalties for the importation or transportation of prohibited goods into Vietnam. Depending on the nature and circumstances of the violation, criminal liability may also arise under the Criminal Code. In practice, enforcement is likely to depend on the
August 20, 2026
As part of its membership in Lex Mundi, Tilleke & Gibbins has released the latest edition of its Guide to Doing Business in Thailand, providing an overview of the legal, regulatory, and commercial considerations for companies establishing or expanding operations in Thailand. The 2026 edition offers practical insight into the country’s business environment, investment framework, and operational requirements. The guide covers a wide range of topics relevant to foreign and domestic investors, including: Investment incentives and promotion schemes Financial facilities and banking regulations Exchange controls and money transfers Import and export regulations Business structures and incorporation options Requirements for establishing a business Operational and compliance considerations Business cessation and insolvency procedures Employment and labor laws Taxation Immigration and visa requirements Prepared by Tilleke & Gibbins lawyers across multiple practice areas, the publication outlines key aspects of doing business in Thailand, including foreign investment restrictions, regulatory compliance obligations, corporate structures, employment requirements, and recent legal and economic developments affecting investors. The publication forms part of Lex Mundi’s Country Guides series, a global collection of jurisdiction-specific reference materials prepared by member firms around the world. Together, these guides help companies evaluate opportunities, compare regulatory environments, and plan international business activities across multiple markets. The full Guide to Doing Business in Thailand 2026 is available through the button below.
August 18, 2026
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
July 14, 2026
Tilleke & Gibbins has contributed the Thailand and Vietnam chapters to Investigations in Southeast Asia, a comprehensive guide published by Drew Network Asia (DNA). The resource provides a practical overview of anticorruption laws, corporate investigations, and compliance frameworks across six key Southeast Asian jurisdictions. Designed for in-house counsel, compliance officers, and risk management professionals, the guide offers actionable insights for navigating complex cross-border regulatory challenges and establishing effective, regionally coordinated compliance and investigation strategies. The guide begins with a regional perspective on enforcement trends and cross-border cooperation initiatives. Jurisdiction-specific chapters follow a standardized structure—covering primary corruption offenses, enforcement authorities, corporate liability, investigation procedures and dawn raids, whistleblower protections, and recommended compliance measures. In addition to country-by-country analysis, the publication highlights best practices for conducting internal investigations, managing digital evidence, and handling parallel proceedings involving multiple regional or international regulators. The guide serves as a practical reference for organizations operating in Southeast Asia. Because legal and regulatory risks depend on specific industry sectors and operational contexts, readers seeking tailored advice are encouraged to contact the authors listed in each chapter. The full guide is available for download through the button below or directly from the DNA website.
AWARDS & RANKINGS
September 30, 2026
Tilleke & Gibbins has been named a finalist in two categories at the IFLR and International Tax Review (ITR) Asia-Pacific Awards 2026. The firm is shortlisted for Thailand National Firm of the Year at the IFLR Asia-Pacific Awards, which recognize innovative cross-border transactions and the firms, teams, and transactions shaping the region’s legal and financial landscape. Tilleke & Gibbins is also shortlisted for Thailand Tax Firm of the Year at the ITR Asia-Pacific Tax Awards. The awards recognize leading firms and practitioners across the region for their work in direct tax, indirect tax, tax disputes, and transfer pricing. The winners will be announced at a joint awards ceremony on November 12, 2026, at the Ritz-Carlton in Hong Kong. For more information, please see the full shortlists for the IFLR Asia-Pacific Awards 2026 and the ITR Asia-Pacific Awards 2026.
September 23, 2026
Tilleke & Gibbins has received 14 nominations for the Asialaw Awards 2026. The nominations span jurisdiction-level, practice-area, and individual categories across the region. At the jurisdiction level, Tilleke & Gibbins has been shortlisted in three categories: Cambodia Firm of the Year Laos Firm of the Year Thailand Firm of the Year The firm has also been shortlisted for four regional practice awards: Aviation and Shipping Firm of the Year Corporate and M&A Firm of the Year Dispute Resolution Firm of the Year Technology and Telecommunications Firm of the Year Seven individual nominations recognize lawyers from the firm’s offices in Laos, Thailand, and Vietnam: Prisna Sungwanna, Laos Female Lawyer of the Year Pimvimol Vipamaneerut, Thailand Female Lawyer of the Year Tram Ngoc Bich Nguyen, Vietnam Female Lawyer of the Year John Frangos, Aviation and Shipping Lawyer of the Year, Dispute Resolution Lawyer of the Year Pongpalin Chantrapirom, Dispute Resolution Rising Star of the Year Chusert Supasitthumrong, Labour and Employment Lawyer of the Year The winners will be announced at an awards ceremony in Kuala Lumpur on November 5, 2026. For more information on the Asialaw Awards 2025 and to browse a full list of the nominees, please visit the Asialaw website.
May 11, 2026
Tilleke & Gibbins has continued to show excellent performance in the recently released Benchmark Litigation 2026 rankings for dispute resolution firms in the Asia-Pacific region. The rankings include two jurisdictions where Tilleke & Gibbins is active: Thailand and Vietnam. Firm Rankings A full summary of the firm’s rankings is provided below: Thailand Commercial & Transactions – Tier 1 Government & Regulatory – Tier 1 Labor & Employment – Tier 1 Intellectual Property – Tier 1 Trade & Customs – Tier 2 Vietnam Commercial & Transactions (Foreign Firms) – Tier 1 Intellectual Property (Foreign Firms) – Tier 1 Labor & Employment (International Firms) – Highly Recommended (top tier awarded in this category) White Collar Crime – Recommended (top tier awarded in this category) Energy & Construction (Foreign Firms) – Tier 2 International Arbitration – Tier 2 Individual Rankings The 2026 edition also recognizes 12 Tilleke & Gibbins lawyers in Thailand—more than any other firm in the jurisdiction—and four in Vietnam. Thailand Alongkorn Tongmee – Trade & Customs Chitchai Punsan – Commercial & Transactions Chusert Supasitthumrong – Labor & Employment John Frangos – Commercial & Transactions Noppramart Thammateeradaycho – Shipping Nuttaphol Arammuang – Intellectual Property Piyawat Vitooraporn – Commercial & Transactions Pongpalin Chantrapirom – Commercial & Transactions Suebsiri Taweepon – Intellectual Property Suruswadee Jaimsuwan – Commercial & Transactions Thawat Damsa-ard – Commercial & Transactions Tiziana Sucharitkul – Commercial & Transactions, Government & Regulatory Vietnam Duc Anh Tran – Commercial & Transactions Linh Duy Mai – Intellectual Property Loc Xuan Le – Intellectual Property Tu Anh Tran – Commercial & Transactions Benchmark Litigation’s annual research is based on interviews with dispute resolution specialists and clients, as well as analysis of recent casework and market developments. To view the full results, please visit the Benchmark Litigation websites for Thailand and Vietnam.