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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

June 16, 2025
Thailand has amended its primary anticorruption law to provide robust new protections and direct assistance to whistleblowers. The Organic Act on Anti-Corruption (No. 2) B.E. 2568 (2025) was published in the Government Gazette on June 5, 2025, and came into force the following day. The amendment introduces a clear framework for safeguarding and supporting individuals who report graft. The amendment addresses a critical gap in the previous legislation by establishing formal mechanisms to protect and assist those who come forward with information. The key changes aim to shield whistleblowers from retaliatory legal and disciplinary actions, thereby encouraging more citizens to participate in exposing corruption without fear of reprisal. Key updates to the law are discussed below. Whistleblower Immunity The amendment clarifies and strengthens legal immunity by revising section 132 of Thailand’s original anticorruption law from 2018. Under the revised section, individuals who provide good-faith statements, information, evidence, or opinions to the National Anti-Corruption Commission (NACC) regarding offenses under its jurisdiction will be protected from civil, criminal, and disciplinary liability. This protection is explicitly extended to individuals who provide information to other state agencies tasked by the NACC to investigate corruption, such as the Public Sector Anti-Corruption Commission or the whistleblower’s own supervisors. Protection and Assistance A new section added to the law establishes a clear and swift process for activating protections. When the NACC learns that a whistleblower is facing legal complaints, criminal charges, or disciplinary action due to their report, the commission must review the matter and decide on providing protection within 15 days. If the NACC determines that the whistleblower acted in good faith, its office is required to provide immediate assistance. Legal and Financial Support Another newly introduced section outlines a wide range of assistance measures the NACC office can provide in civil and criminal cases
June 6, 2025
As from July 1, 2025, as part of its ongoing efforts to digitalize and streamline the delivery of public services, the Vietnamese government will officially conduct administrative procedures, both online and offline, only via electronic identity (“e-ID”) accounts on the VNeID platform. In particular: Online administrative procedures carried out via the National Public Service Portal or via information systems for administrative procedures at the ministerial or provincial level are required to be implemented by using e-ID accounts only. When receiving dossiers, authorities will be required to check and verify the e-IDs of companies or individuals responsible for conducting administrative procedures. Further, it is worth noting that to complete the registration of an e-ID account for a company, the legal representative of the company must hold a level-2 e-ID account. Compliance Considerations Vietnam’s first regulation of e-ID accounts for individuals and organizations was issued in Decree No. 59/2022/ND-CP dated September 5, 2022, on electronic authentication and identification. This decree was subsequently replaced by Decree No. 69/2024/ND-CP dated June 25, 2024, which governs the same matters. Registration and operation of e-ID accounts are centralized through VNeID, a digital ID app developed by the National Population Data Center under the Ministry of Public Security of Vietnam. Although the registration of e-ID accounts for companies is not explicitly mandated by law, the absence of an e-ID account may hinder companies from completing administrative procedures, including licensing and reporting obligations. Such non-compliance could consequently result in administrative penalties. To mitigate unexpected non-compliance and administrative fines due to the lack of an e-ID account, companies should be well prepared for and implement the registration of a company e-ID account as soon as possible.
May 28, 2025
Tilleke & Gibbins attorneys in Vietnam have contributed the 2025 edition of Doing Business in Vietnam, a comprehensive Q&A-style resource from Thomson Reuters Practical Law that provides essential insights for companies navigating business operations in Vietnam. The guide presents a detailed overview of the country’s legal framework and regulatory environment, reflecting recent updates in Vietnamese legislation and practice. This annually updated guide offers key information on the following areas: Legal system: Structure of the Vietnamese judiciary and the role of codified law. Foreign investment: Conditions for market access, licensing requirements, foreign ownership restrictions, and investment incentives. Business vehicles: Formation and operation of legal entities, including limited liability companies, joint-stock companies, and representative offices. Employment: Employment contracts, social insurance, labor rights, and procedures for hiring foreign nationals. Tax: Overview of corporate income tax, personal income tax, value-added tax, and other tax obligations. Intellectual property: Procedures for protecting and enforcing patents, trademarks, copyrights, and other IP rights. Data protection: Compliance requirements under Vietnam’s data privacy laws, including the Personal Data Protection Decree. Competition law: Antitrust rules and regulatory oversight under the Law on Competition. Anti-bribery and corruption: Legal framework and enforcement practices aimed at curbing corrupt activities. E-commerce and digital business: Regulations governing online platforms, digital content, and cross-border services. Marketing and advertising: Laws and guidelines on advertising standards and consumer protection. Product regulation and liability: Safety requirements, product liability issues, and roles of relevant authorities. Doing Business in Vietnam is part of Practical Law’s global series of legal guides designed to support international practitioners and businesses. To access the most recent edition of the Vietnam guide, visit the Practical Law website and sign up for a free trial.
May 2, 2025
Attorneys from Tilleke & Gibbins have updated the latest edition of Doing Business in Thailand, a Q&A-style guide from Thomson Reuters Practical Law that offers an overview of key legal considerations for companies operating in jurisdictions worldwide. The contribution outlines the country’s legal and regulatory framework for foreign investment and business operations and reflects the latest legislative developments. The chapter addresses the following core topics: Legal system: Structure of the courts and the codified nature of Thai law. Foreign investment: Business restrictions under the Foreign Business Act, sector-specific regulations, exchange control rules, and investment incentives. Business vehicles: Overview of partnerships, private and public limited companies, and other legal entities. Employment: Labor protections, employment contracts, foreign worker requirements, and termination procedures. Tax: Corporate and personal income tax, indirect taxes, and tax obligations for residents and non-residents. Intellectual property: Registration and enforcement of patents, trademarks, designs, and copyrights. Data protection: Key provisions of the Personal Data Protection Act and related compliance obligations. Competition law: Regulatory framework under the Trade Competition Act. Anti-bribery and corruption: Relevant legislation and enforcement mechanisms. E-commerce and digital business: Legal regime for online transactions and digital platforms. Marketing and advertising: Consumer protection laws and regulations affecting advertising and marketing practices. Product regulation and liability: Safety standards, liability regimes, and roles of enforcement authorities. Practical Law, a legal reference resource from Thomson Reuters, publishes a range of guides for hundreds of jurisdictions and practice areas. The insurance and reinsurance guide is a valuable resource for legal practitioners, covering numerous jurisdictions worldwide. To view the latest version of the guide, please visit the Practical Law website and enroll in the free Practical Law trial to gain full access.
AWARDS & RANKINGS
December 12, 2025
Tilleke & Gibbins has maintained its strong market position in the newly released Chambers Asia-Pacific 2026 rankings, with six Band 1 honors in core practices and consistently strong performance across the entire region. In addition to the exceptional practice-area rankings, 33 lawyers were recognized across 11 practice areas.
December 1, 2025
Tilleke & Gibbins is pleased to announce that the firm has been honored with two awards at the 2025 Lexology Index Awards in London, this time picking up both the Thailand and Vietnam Country Awards. Formerly known as the Who’s Who Legal Awards, the Lexology Index Awards celebrate outstanding achievements by firms and individuals identified through Lexology’s extensive global research process. Tilleke & Gibbins’ continued success in this forum reflects the exceptional expertise and dedication of its team, whose commitment to delivering the highest caliber of legal services continues to set a benchmark in the industry. The firm extends its gratitude to its talented professionals and valued clients for their continued trust and support. A full list of the winners of the 2025 Lexology Index Awards is available on the Lexology website.
November 20, 2025
Tilleke & Gibbins is pleased to share that Asia Business Law Journal (ABLJ) has released its A-List of Thailand’s Top 100 Lawyers and its exclusive Legal Icons list for 2025. This year, Darani Vachanavuttivong has again been named a Legal Icon, recognizing her as one of the most distinguished professionals in Thailand’s legal community. In addition, nine other Tilleke & Gibbins lawyers have been named among Thailand’s Top 100 Lawyers. The full list of honorees is: Alan Adcock Charunun Sathitsuksomboon Chusert Supasitthumron (new ranking) Athistha (Nop) Chitranukroh Darani Vachanavuttivong (Legal Icon) Kobkit Thienpreecha Nuttaphol Arammuang Pimvimol (June) Vipamaneerut Thawat Damsa-ard Tiziana Sucharitkul The ABLJ A-List is compiled through extensive research, including nominations and feedback from in-house counsel worldwide and international law firm partners who focus on Thailand. The editorial underscores the demand for lawyers with unmatched expertise, a dedication to quality, and a proven ability to deliver strategic, innovative solutions. To view the full list and the accompanying editorial analysis, please visit the ABLJ website.