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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

April 28, 2026
Thailand’s Anti-Corruption Cooperation Committee has issued a major update to the anticorruption standards required for private entities engaging in high-value state projects. The update, titled “Announcement re: Procurement Limits and Minimum Anticorruption Standards (No. 2),” replaces and amends key provisions of the original announcement dated September 25, 2024. Published in the Government Gazette on April 10, 2026, the new rules take effect on May 10, 2026, and apply to projects valued at more than THB 300 million (approximately USD 9.3 million). The key amendments to the anticorruption standards are detailed below. Expanded Definition of Conflict of Interest The 2026 regulation significantly broadens the scope of what constitutes a conflict of interest compared to the 2024 version, which focused primarily on basic kinship and business ties. Under the new rules, a conflict of interest includes using one’s position or authority to seek benefits for oneself, a group, close associates, or business, including through business relationships, kinship ties, or relationships with spouses or individuals living together as partners without marriage registration. The 2026 announcement also introduces specific examples that were largely absent from the 2024 text, such as holding shares in similar businesses that submit proposals for the same project, or submitting proposals for projects in which a relative, spouse, or unregistered partner is an “involved party” in that procurement. Continuous Compliance: The “Final Payment” Rule Under the 2024 rules, the coverage period for anticorruption policies was less strictly defined. The new regulation mandates a continuous timeline: policies or certifications must remain effective from the date of bid submission until the contractor receives the final payment installment under the contract. If a certification or policy is set to expire before the final payment, the contractor must submit a new self-audit form and supporting evidence to the state agency before the original
January 8, 2026
Doing business in Thailand means operating under a strict regulatory framework. From time to time, companies may receive unexpected administrative orders from government authorities that restrict their operations, impose new compliance obligations, or levy fines and penalties. When this happens, a business may challenge the order under Thailand’s administrative law system. The primary concern in pursuing administrative litigation is timing, as strict statutory deadlines apply and missing them can permanently affect a company’s rights. First Step: Administrative Appeal Many companies assume the first step is to immediately bring the matter before the Administrative Court to seek revocation or suspension of the order. Some even attempt to request an interim injunction to stop the order from taking effect. However, Thai law generally requires that the company first challenge the order through an administrative appeal with the same agency that issued it. Only after this process is complete can the matter be taken to court. Seeking an interim injunction at this stage is also not possible. This is because Thai law does not allow a standalone application for an interim injunction; an injunction can only be requested together with the underlying complaint filed with the Administrative Court. Since a court complaint cannot be filed until the administrative appeal process has been exhausted, an injunction is usually not available at the early stage. What Are the Timeframes for Administrative Appeal? Thailand applies a two-stage administrative appeal process. The appeal must first be submitted to the same authority that issued the order, which will review its own decision. If that authority affirms its decision, the appeal is then escalated to the relevant higher authority for further review. In most cases, both stages must be completed before a company is allowed to proceed to court. The timeframe for filing an administrative appeal is very
December 3, 2025
Recent high-profile corporate fraud and accounting scandals have brought increased scrutiny to governance, compliance, and enforcement practices in Thailand, highlighting the legal and practical challenges facing companies operating in the country. As regulators and law enforcement authorities sharpen their focus on financial misconduct, cybercrime, and corruption, businesses must navigate a complex and evolving investigative landscape. Tilleke & Gibbins’ investigations and compliance team examines these issues in the Thailand chapter of The Practitioner’s Guide to Global Investigations – Tenth Edition, published by Global Investigations Review (GIR). The chapter provides a detailed overview of Thailand’s legal framework for corporate investigations, offering practical guidance for companies and counsel responding to regulatory and criminal scrutiny. The Thailand chapter covers key topics including corporate criminal liability, enforcement priorities, internal investigations, data protection considerations, dawn raids, whistleblowing, cyber-related investigations, and cross-border cooperation. It also addresses emerging issues such as cybersecurity enforcement, economic sanctions compliance, and anticipated developments affecting investigations in Thailand. The chapter is authored by John Frangos, Chitchai Punsan, Alongkorn Tongmee, Michael Ramirez, Piyawat Vitooraporn, and Michelle McLeod. The Thailand chapter is available as a PDF below, and the full guide can be accessed on the GIR website.
September 11, 2025
Thailand traditionally has had a reputation as a “crossroads” for numerous illegal activities and of the laundering of significant sums of tainted money. Member of the Financial Action Task Force (FATF)? No. Any Egmont members? Yes. Thailand’s Anti-Money Laundering Office (AMLO) is a member of the Egmont Group. Regulation The relevant law, known as the Anti-Money Laundering Act (the Act), was passed in March 1999 with the aim of combating not only the drug trade but also other illicit activities, such as corruption, criminal fraud and prostitution. There have been a number of changes and updates to the Act, the most recent one in late 2015, in which the Act was amended to include: Additional predicate offences such as offences relating to human trafficking, online gambling and offences relating to unfair practices relating to derivatives and agricultural commodity futures. Broader scope of money laundering offence. Non-disclosure obligations to applicable financial institutions and reporting entities. Compulsory training to financial institutions and reporting entities’ employees responsible to monitor and ensure compliance with the Act. Retention period. Enhanced penalties Additionally, discussions did take place mooting further changes to the Act, set out in 2020 and 2021 drafts. Proposed changes included suggestions to expand the definitions of financial institutes, predicate offences and professions, as well as to impose greater reporting and due diligence responsibilities on companies subject to the Act. However, recent amendments to the Act in 2022 only included minor procedural and substantive changes that did not materially alter or expand the Act. The most notable amendments were changes to an injured party’s rights to claim damages caused by a predicate offence and the rights of beneficiaries claiming assets seized by the government in connection with a predicate offence. Financial intelligence unit Of the total number of transactions reported to AMLO annually,
AWARDS & RANKINGS
March 19, 2026
Tilleke & Gibbins has been recognized in 17 categories at the 2026 Thailand Law Firm Awards from Asia Business Law Journal (ABLJ), up from 10 categories in 2025. The awards highlight leading law firms in Thailand across a broad range of practice areas, as well as overall firm performance. This year, Tilleke & Gibbins was named a co-winner in the Best Overall Law Firm category as well as in the following practice-specific categories: Artificial Intelligence Aviation Blockchain & Digital Assets Competition & Antitrust Data Compliance & Cyber Security E-Commerce, Digital Trade & Platform Regulation ESG (Environmental, Social, and Governance) Fintech Healthcare & Life Sciences Insurance & Reinsurance IP Litigation IP Prosecution Labour & Employment Private Equity & Venture Capital Shipping & Maritime Technology, Media & Telecommunications The awards are determined through ABLJ’s independent research, which considers recent work, client feedback, and market standing. The annual Thailand Law Firm Awards recognize firms demonstrating strong performance and breadth of expertise across key practice areas. For more details and the full list of winners, please visit the ABLJ website.
March 9, 2026
Tilleke & Gibbins has been shortlisted in multiple firmwide and individual categories at the Legal 500 Southeast Asia Awards 2026, including Regional Firm of the Year, reflecting the firm’s work across Southeast Asia and the continued development of its regional practices. In the individual categories, Aye Thuzar Hlaing has been shortlisted for Myanmar Associate of the Year (Corporate and M&A), and Linh Duy Mai has been shortlisted for Vietnam Associate of the Year (Intellectual Property). Tilleke & Gibbins has also been shortlisted in the following firm categories: Regional Firm of the Year Thailand – Law Firm of the Year Thailand – Law Firm of the Year (Litigation) Myanmar – Law Firm of the Year Vietnam – Law Firm of the Year Vietnam – Law Firm of the Year (Labor and Employment) Laos – Law Firm of the Year The winners will be announced on April 30, 2026, at the Legal 500 Southeast Asia Awards ceremony in Singapore. To browse the full shortlist for the Legal 500 Southeast Asia Awards 2026, please see the Legal 500 website.
March 2, 2026
Tilleke & Gibbins has been shortlisted for two prestigious recognitions in the Chambers Asia-Pacific and Greater China Region Honours 2026. The firm received nominations for both Thailand Firm of the Year and Vietnam Firm of the Year. The Chambers Asia-Pacific and Greater China Region Honours recognize preeminent law firms demonstrating outstanding work, impressive strategic growth, and excellence in client service across the region. The Thailand nomination marks the firm’s sixth consecutive shortlisting and twelfth since 2010. For Vietnam, this is the third consecutive year the firm has been recognized. The winners will be announced at an awards ceremony in Hong Kong on May 28, 2026. To learn more about the Chambers Asia-Pacific and Greater China Region Honours 2026 and browse the full list of nominations, please visit the Chambers and Partners website.