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Fintech

Fintech

Key Contacts

Cambodia

Laos

Myanmar

Thailand

Vietnam

OVERVIEW

We offer unrivaled legal services for fintech and payment product offerings in the region.

Leveraging our market-leading legal expertise in the technology sector, Tilleke & Gibbins advises the world’s foremost financial institutions and innovative technology companies on the offering of fintech products and services in Southeast Asia. Our advice covers all local laws and regulations related to cross-border money transfer and remittance services, e-payment services, virtual account and card issuance, crowdfunding, digital assets and cryptocurrencies, online lending services featuring peer-to-peer (P2P) mechanisms, operating agreements, and data protection matters.

We assist fintech clients in establishing partnerships with local banks, securing licensing and registration for their local operations, and obtaining approval from the Bank of Thailand (BOT) and other regulators across Southeast Asia for product offerings. We also offer strategic advice on market entry and all related legal and regulatory concerns, including foreign investment, investment promotion, anti-money laundering (AML), and know-your-customer (KYC) requirements. Our legal experts across our Cambodia, Laos, Myanmar, Thailand, and Vietnam offices bring an in-depth understanding of the relevant technology and business to help clients present complex and innovative products to local regulators.

Experience

  • Assisted a multinational financial services provider on the Thai legal elements of its acquisition of Citibank’s merchant acquiring business in Asia Pacific, including conducting due diligence, advising on deal structuring, novating 800+ merchant accounts, and advising on transitional service arrangements and BOT regulatory and licensing requirements.
  • Advised Coda Payments on the regulatory framework applicable to e-money businesses in Thailand, as well as on exemptions under Thailand’s Payment Systems Act.
  • Engaged on a retainer/secondment basis to provide legal and regulatory advice to a world-leading online payment processing company to support its operations and services in the Thai market, including applying for and operationalizing payments licenses from the BOT.
  • Advised one of the world’s largest cryptocurrency exchanges on laws and regulations, licensing requirements, and restrictions applicable to its proposed launch of a copy trading product in Cambodia, Laos, Myanmar, and Vietnam.
  • Advised an Asian mobile phone manufacturer on fourth-party payment services that enable online merchants to carry out cross-border settlements and currency exchange in Vietnam.
  • Advised Visa International on a range of matters related to their local operations in Thailand, including advice on compliance with Thailand’s Payment Systems Act.
  • Assisted a commercial bank with the preparation of a full suite of contracts for the launch of an online B2C marketplace for the Cambodian market via the client’s mobile application.
  • Assisted a leading shopping, rewards, and payments platform in preparing and submitting a payment license application to the BOT, as well as in applying for a Foreign Business License to operate a foreign majority-owned business in Thailand.
  • Assisted a New Zealand payment provider engaging in highly scalable real-time e-money payment processing, digital payments, and point-of-sale platforms to enter the Vietnam market.
  • Advised a Thai financial services company on local licensing and regulatory requirements in relation to nanofinance and personal loans; buy now, pay later (BNPL) structures; and invoice financing.
  • Advised a Thai commercial bank on card payment acquiring services in Vietnam and reviewed the terms and conditions and privacy policy for its related mobile app.
  • Advised an international online payment platform on Thai licensing and regulatory requirements for its products and the establishment of a mobile payment partner.
  • Assisted a Greek payment processor providing airtime credit and airtime advance services, digital financial platforms, big data analytics, mobile financial services, and handset loans in entering the Vietnam market.
  • Provided comprehensive legal advice to the payment arm of a multinational tech company in connection with its collaboration with a leading Thai bank.
  • Advised a client on cybersecurity regulations, laws, and guidance issued by the supervising authorities as they relate to payment systems, payment products and solutions, and infrastructure security.
  • Retained to assist a Thai fintech company with applying for and obtaining a license from the Bank of Thailand to operate a personal loan program in Thailand.
  • Assisted a global merchant services technology company on all legal matters in connection with the offshore provision of e-payment services in the Thai market, including advising on licensing requirements and regulations, analyzing business models, and handling consultations and applying for a ruling from the BOT.
  • Engaged to assist a client with preparing and submitting an application to the BOT to obtain a payment license for the Thai market.
  • Advised a mobile e-payment application on establishing operations to provide e-payment and e-wallet services in Thailand. We assisted the client in a full range of corporate formation and regulatory matters, including consultations with the BOT and the Ministry of Commerce to obtain approval for their innovative products.

PROFESSIONALS

RELATED INSIGHTS

July 17, 2026
On July 11, 2026, media reports conveyed key messages from Bank of Thailand (BOT) Governor Vitai Ratanakorn’s announcement of a sweeping regulatory crackdown on grey capital activities. The measures target high-value cash transactions, gold trading, and stablecoin flows, with new requirements set to take effect in the fourth quarter of 2026. The initiative aims to prevent financial institutions from facilitating shadow economy activity, money laundering—particularly through stablecoins—and capital flight, through enhanced compliance obligations on commercial banks across multiple transaction channels. Expanded Cash Controls Close the Deposit–Withdrawal Circuit New fourth-quarter guidelines will require individuals depositing THB 5 million or more in cash to formally verify the source of their funds. This builds on restrictions introduced in April 2026, which required anyone withdrawing 5 million baht or more in cash to provide their bank with verified commercial justification for why electronic transfers or checks could not be used. That initial measure caused high-value physical cash withdrawals to drop by 35 percent nationwide. The upcoming deposit-side requirement closes the circuit on large cash movements. The BOT is also assessing tracking mechanisms for high-value banknote swaps, specifically targeting individuals seeking to exchange large volumes of THB 1,000 notes into smaller THB 100 or THB 500 denominations without clear business justification. Governor Vitai emphasized that these measures require continuous deployment of multiple parallel strategies rather than short-term fixes. Tightened Bullion Reporting Frameworks Restrict Money Laundering Channels The BOT has also tightened reporting frameworks for gold trading to close money laundering loopholes and shield the Thai baht from speculative bullion volatility. Regulators identified a recurring pattern in which buyers purchased large quantities of gold through digital applications in the morning and then made same-day physical withdrawals from retail gold shops in the afternoon. Gold shops are reminded of their duties to flag and report cash
June 23, 2026
On May 14, 2026, Thailand published a ministerial regulation in the Government Gazette to prescribe measures for prevention and suppression of technology crimes. The regulation creates a comprehensive procedural framework for returning money and digital assets to victims of technology crimes. It will take effect 90 days after publication (in mid-August 2026), giving affected entities a limited window to prepare. Mandatory Reporting Obligations for Financial Institutions When a deposit account, e-money account, or digital asset wallet is frozen in connection with a technology crime, the relevant financial institution or business operator must report transaction data to the Anti-Money Laundering Office (AMLO) via AMLO’s designated electronic system. Required data elements include account numbers (sender and receiver), names, identification or passport numbers, legal entity registration numbers, phone numbers, remaining balance, damage amount, transaction reference numbers, and the bank case ID. Institutions that already share data through the information-sharing system under the emergency decree are deemed to have satisfied this reporting obligation, creating an incentive for platform participation. When the Royal Thai Police or the Department of Special Investigation seize or freeze assets related to technology crimes, they must provide AMLO with investigation reports, complaint evidence, money-trail data, and account statements. Notification and Claims Process Once the AMLO secretary-general approves verified reports of a technology crime, the account information of persons connected to the crime will be published in the Government Gazette, triggering a 90-day window for victims to file claims and for related persons to file objections. Officers will also publish details on AMLO’s electronic media and send registered mail to identified victims, which will be deemed received after 7 days domestically or 15 days internationally. Victims have 90 days from the date the crime is published in the Government Gazette to file claims through AMLO’s electronic system. Claims must include
May 25, 2026
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
April 23, 2026
Vietnam has progressively positioned blockchain as a strategic technology within its broader digital transformation agenda over the past decade. From early policy orientations to more recent legislative developments, the regulatory approach has gradually shifted from high-level recognition to more concrete legal integration. Against this backdrop, a new draft decree regulating activities relating to product and goods identification, authentication, and traceability (the “Draft Decree”) marks a notable turning point. Rather than merely referencing blockchain as a policy priority, the Draft Decree incorporates blockchain directly into a nationwide regulatory system, positioning it as part of the underlying infrastructure for data governance and public administration in relation to the management, verification, and traceability of product-related data. Evolution of Vietnam’s Blockchain Legal Framework: The Draft Decree in Context Vietnam’s blockchain legal framework has developed in several distinct phases. The first phase, beginning around 2019, was characterized by high-level policy recognition in several resolutions of the Party Central Committee. Particularly, blockchain was identified as part of the broader category of digital technologies critical to industrial modernization and participation in the Fourth Industrial Revolution. These resolutions did not regulate blockchain directly, but established its strategic importance at the national level. The second phase (2023 to 2025) saw the introduction of national strategies and technology policies that more explicitly recognized blockchain as a priority technology. Those policies collectively signaled a clear policy commitment to developing blockchain infrastructure and applications. However, these instruments remained largely at a policy-level and did not establish binding regulatory frameworks. The third phase (from 2025) involves the gradual integration of blockchain into sectoral legislation. Laws such as the Law on Digital Technology Industry (2025), the Law on Personal Data Protection (2025), and the Law on Science, Technology, and Innovation (2025) have introduced concepts such as digital assets, crypto assets, and even specific
AWARDS & RANKINGS
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.
April 3, 2026
Tilleke & Gibbins is pleased to announce that the firm has been shortlisted in two categories at the Financial Times (FT) Innovative Lawyers APAC 2026 awards: Innovative Lawyers in Cyber and Data Privacy – “Digital Identity & Cryptocurrency Compliance” Innovative Practitioner – Athistha (Nop) Chitranukroh The FT Innovative Lawyers APAC Awards recognize law firms and practitioners who are driving innovation in legal services and delivering innovative client solutions across the Asia-Pacific region. This recognition marks our third acknowledgment in the Innovative Lawyers category and, notably, our first-ever nomination in the Innovative Practitioner category at the FT Innovative Lawyers APAC awards. It reflects our team’s continued ability to support clients on groundbreaking, forward-looking projects across the region. The awards ceremony will take place on May 14, 2026, in Hong Kong. To learn more about the FT Innovative Lawyers APAC 2026 awards and to view the full list of shortlisted organizations, please visit the FT website.