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Fintech

Fintech

Key Contacts

Cambodia

Laos

Myanmar

Thailand

Vietnam

Jay Cohen

     +855 23 964 210

     [email protected]

Athistha (Nop) Chitranukroh

     +66 2056 5600

     [email protected]

Yuwadee Thean-ngarm

     +95 9 772 440 002

     [email protected]

Athistha (Nop) Chitranukroh

     +66 2056 5600

     [email protected]

Anh Hoai Nguyen

     +84 24 3772 5596

     [email protected]

Thao Thu Bui

     +84 24 3772 5532

     [email protected]

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.

Case Studies
Cambodia | Fintech | Banking and Finance

Full Range of Legal Services for Leading Banking Institution in Cambodia

Retained by a leading banking institution in Cambodia to assist in a wide range of matters related to their local product offerings including, among others, facility reports, online banking, payment gateways, data breaches, and KYC requirements.

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Thailand | Corporate/M&A, Fintech

Acted for Satang Corporation and Shareholders in Sale of 97% Stake to KBank

Acted for Satang Corporation and its shareholders in the sale of a 97% stake to Unita Capital, a wholly owned subsidiary of Kasikornbank PCL. This transaction is the largest successful and complete acquisition of a digital asset exchange operator licensed by the Thai Securities and Exchange Commission, marking an important milestone for the Thai digital asset industry.

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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

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
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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
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March 5, 2026
Thailand’s Securities and Exchange Commission (SEC) has filed a criminal complaint against a licensed digital asset broker, its overseas trading platform, and its executives for allegedly operating an unlicensed digital asset exchange targeting Thai customers. The case marks an escalation in the SEC’s enforcement efforts against unlicensed offshore platforms that attempt to serve Thai users through local licensed entities. Criminal Complaint On February 20, 2026, the SEC filed a criminal complaint with the Economic Crime Suppression Division against a local licensed digital asset broker, its overseas global trading platform, and its executives. The SEC alleges that the parties violated the Digital Asset Business Emergency Decree B.E. 2561 (2018) by cooperatively operating a digital asset exchange business on a cross-border basis since 2023 without the required SEC license. According to the SEC, the local broker promoted the overseas platform’s services to the public through Thai-language posts on social media channels, with services available exclusively to customers residing in Thailand. Access to the global platform was provided through the local broker’s website and mobile application. Customers who registered for the local broker’s services were automatically granted access to the global platform without having to undergo a separate identity verification process. The SEC also found that the local broker provided back-office system support services to the global platform. The SEC considers these activities to constitute joint operation of an unlicensed digital asset exchange. The former executives of the local broker are being held liable as the responsible persons during the relevant period. The SEC emphasized that the complaint initiates the criminal process, and the decision to prosecute or convict the accused parties will ultimately be made by law enforcement authorities and the criminal courts. Platform Blocking The SEC has also coordinated with the Ministry of Digital Economy and Society to block public
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February 27, 2026
The Bank of Thailand (BOT) has officially implemented a new regulatory framework supervising systemically important retail payment systems (SIRPS), effective February 21, 2026, with PromptPay being the first payment system designated as a SIRPS. Under this new set of regulations, the BOT may designate payment systems under the Payment Systems Act B.E. 2560 (2017) as SIRPSs based on quantitative and qualitative assessments. Once a system is designated as a SIRPS, the operator becomes subject to expanded supervisory obligations beyond the general requirements of the Payment Systems Act. Enhanced Supervisory Requirements SIRPS operators must comply with a heightened supervisory regime across three key areas, outlined below. 1. Governance SIRPS operators must maintain robust and transparent governance structures, including: Balanced board composition, with at least one-third of the board comprising independent directors who represent stakeholders in the system (such as payment service providers, consumers, and experts). Independent directors may serve for no more than two consecutive terms. Subcommittees to assist the board in overseeing compliance, policy implementation, and operational strategy. Clear separation between executives responsible for risk and information security and those overseeing day-to-day business operations. Risk Management and System SecuritySIRPS operators must implement comprehensive risk management frameworks, including: Clear service agreements between the SIRPS operator and its direct participants (payment service providers who connect directly to the SIRPS), defining roles and responsibilities among stakeholders. These agreements must include obligations for direct SIRPS participants to supervise any indirect participants they onboard to ensure compliance with service agreements and business rules. A business continuity plan covering both IT and non-IT aspects, with annual review. The SIRPS must target service availability comparable to international payment infrastructures, including the ability to recover operations within two hours of a disruption and to maintain scalable operational capacity. Tools and controls to monitor and manage material or
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AWARDS & RANKINGS
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.
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September 12, 2025
The 2025/2026 edition of the IFLR1000 Asia-Pacific rankings, released by International Financial Law Review (IFLR), highlights Tilleke & Gibbins’ continued excellence in financial and corporate transactional work. The firm has maintained its strong rankings across multiple jurisdictions and practice areas while achieving notable upgrades and new recognitions, reaffirming its position as a leading firm in the Asia-Pacific region. This year, Tilleke & Gibbins received firmwide rankings in key jurisdictions, including: Thailand Banking & Finance—Tier 3 Capital Markets: Debt—Tier 3 Capital Markets: Equity—Tier 3 M&A—Tier 2 Project Development—Tier 2 Restructuring & Insolvency—Tier 3 Vietnam Banking & Finance—Tier 4 M&A—Tier 3 Project Development—Tier 3 Cambodia Financial & Corporate—Tier 2 Project Development—Tier 2 Laos Financial & Corporate—Tier 2 In addition to these firmwide rankings, Tilleke & Gibbins had several standout individual recognitions, with 12 lawyers honored in the 2025/2026 individual rankings—an increase from last year’s 10. This year’s results include upgraded rankings for John Frangos and new rankings for Charupat Boon-Long, Derrick Khoo, Prisna Sungwanna, and Saravut Krailadsiri. The full list is as follows: Charunun Sathitsuksomboon—Highly Regarded, M&A, Thailand; Women Leader Charupat Boon-Long—Rising Star, M&A, Thailand (new ranking) David Mol—Rising Star, Corporate and M&A, Cambodia Derrick Khoo—Rising Star (Partner), Financial and Corporate, Thailand (new ranking) Jay Cohen—Highly Regarded, Banking, Cambodia John Frangos—Highly Regarded, Restructuring & Insolvency, Thailand (upgraded ranking) Niti Muangkote—Rising Star, Financial & Corporate and Project Development, Laos; Highly Regarded, Banking & Finance, Thailand Prisna Sungwanna—Highly Regarded, Financial & Corporate, Laos (new ranking) Saithong Rattana—Notable Practitioner, Project Development and M&A, Laos Santhapat Periera—Highly Regarded, Banking & Finance and M&A, Laos; Highly Regarded, Banking & Finance, Thailand Saravut Krailadsiri—Notable Practitioner, Thailand (new ranking) Tram Ngoc Bich Nguyen—Highly Regarded, M&A, Vietnam To see the full set of IFLR1000 rankings for Tilleke & Gibbins’ jurisdictions, please see the Cambodia, Laos, Thailand, and Vietnam pages
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