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 licensed domestic digital asset business operator. AMLO will transfer them without delay to another licensed domestic provider or, if that proves impossible, to the office’s cold wallet. In either scenario, the seizing official must document the asset account details, asset type, quantity, and value as of the seizure date, and the identity of the responsible custodian.
All fees and expenses incurred in transferring seized digital assets will be deducted directly from the assets themselves. The custodian will be required to report these costs to the secretary-general of the Anti-Money Laundering Board and notify the seizing official.
Cold Wallet Security Standards
The regulation requires cold wallets to use encryption key storage methods that are not connected to the internet. While the text does not enumerate every technical specification, it establishes that offline storage is the baseline security standard and that only designated personnel may maintain custody of these keys. If obstacles prevent compliance with these prescribed methods, the responsible custodian must seek approval from the AMLO secretary-general for alternative storage that still provides adequate security.
Practical Implications
The regulation eliminates discretion over whether and how seized digital assets are moved into state custody. Digital asset businesses should expect that any assets seized from their platforms or their customers will be transferred swiftly to another licensed provider or into offline storage. Operators holding customer funds under investigation must be prepared to facilitate these transfers without delay and to cooperate with documentation requirements. Businesses and individuals who hold digital assets with foreign service providers should also understand that Thai authorities now have a clear legal pathway to compel repatriation of those assets during enforcement actions.
For victims of money laundering, these regulations offer new hope for asset recovery. The clear procedures for seizing and securing digital assets—whether held domestically or abroad—create a more effective enforcement framework that can help trace, freeze, and ultimately return stolen funds to those harmed by financial crimes.
