On December 31, 2025, the State Bank of Vietnam (SBV) issued Circular No. 72/2025/TT-NHNN (Circular 72), establishing a streamlined foreign exchange framework for Vietnam’s International Financial Center (IFC). Circular 72, which took effect on the same day, implements core provisions of Decree No. 329/2025/ND-CP and marks a fundamental shift from ex ante licensing to ex post supervision for IFC member enterprises and foreign investors. These changes are designed to accelerate capital flows, reduce compliance costs, and position Vietnam as a competitive regional financial hub by granting IFC members substantially greater autonomy in currency transactions, borrowing, lending, and investment activities. Key provisions for IFC members to note are discussed below. Use of Foreign Currency and Payments within the IFC Vietnam generally requires the use of Vietnamese dong for transactions within the country, with limited exceptions. This can be burdensome for foreign investors, who may be unfamiliar with all the foreign exchange rules they must comply with. Under the new regulation, IFC member enterprises and foreign investors gain the ability to transact, list prices, and settle obligations in foreign currency when dealing with other IFC members or offshore counterparties, avoiding currency risk and conversion friction. With respect to individuals and organizations located within Vietnam who are not IFC members, the use of foreign currency must continue to comply with general restrictions on foreign exchange usage within Vietnam. Dual-Track Account System for IFC Members The new regulation introduces a two-tier account structure that differentiates transactions by purpose and counterparty. IFC member enterprises must use a designated foreign currency capital account at an IFC member bank for four specified activities: Borrowing from offshore individuals and organizations Lending to offshore entities and domestic borrowers Outbound investing from the IFC Investing elsewhere in Vietnam from the IFC All other foreign exchange transactions—including operational receipts, vendor payments, currency conversion, and other investment—may be conducted through standard foreign currency payment

On December 10, 2025, Vietnam’s National Assembly enacted Law No. 139/2025/QH15 amending the Law on Insurance Business. The amendment, effective from January 1, 2026, introduces various changes in an effort to lift restrictions and hurdles for insurance businesses. Key points that may impact the activities of stakeholders in Vietnam’s insurance market are highlighted below. Management Personnel Qualifications To broaden the talent pool while ensuring competency standards, the amended law opens up the positions of director or general director to more candidates. Previously, candidates were required to hold either (i) a university degree or higher in insurance or (ii) a university degree in another discipline and an insurance certificate issued by a qualified insurance training institution. Now, candidates holding a university degree or higher in economics, finance, banking, law, business administration, accounting, or auditing, with at least one insurance‑related module, are also accepted. These changes are expected to mitigate the ongoing challenges faced by insurers in recruiting suitably qualified candidates for key executive positions, while still maintaining appropriate professional standards. Fewer Registrations for Insurance Businesses As part of the legislature’s broader initiative to reduce administrative burdens across all business sectors, the amended Law on Insurance Business relaxes registration requirements for the insurance industry, notably: Insurance enterprises and foreign non‑life insurance branches are no longer required to register and obtain prior approval from the Ministry of Finance (MOF) for their methodologies and bases for calculating premiums for motor vehicle insurance products (excluding compulsory civil liability insurance for motor vehicle owners). Instead, insurance enterprises are now only required to notify the MOF before applying or amending these methodologies. While life insurers must continue to register with the MOF their principles for separating owners’ equity from insurance premium funds, non‑life insurance enterprises and foreign non‑life insurance branches are now only required to notify (rather than register with) the MOF

On January 20, 2026, Vietnam’s Ministry of Finance (MOF) issued Decision No. 96/QD-BTC to formally launch pilot administrative procedures for licensing crypto asset trading market services in Vietnam. The decision took immediate effect and implements the government’s pilot crypto asset market program under Resolution No. 05/2025/NQ-CP. Notably, competent authorities have now begun accepting license applications, marking the first time Vietnam has operationalized a licensing pathway for crypto trading market operators. Administrative Procedures and Applications The decision stipulates procedures for (i) granting, (ii) adjusting, and (iii) revoking licenses to provide services for organizing crypto asset trading markets. It provides detailed, step-by-step guidance for each procedure, including dossier composition, internal review stages, coordination mechanisms, and statutory timelines. These procedures apply specifically to entities seeking to organize and operate crypto asset trading markets within Vietnam’s pilot regulatory framework. The MOF is the authority responsible for reviewing and deciding on the above procedures, with the State Securities Commission acting as the receiving, coordinating, and procedural focal point. For licensing applications, the MOF will coordinate with multiple authorities, including the State Bank of Vietnam and the Ministry of Public Security, particularly in relation to anti-money laundering, cybersecurity, system safety, and risk control requirements. Applications may be submitted in person, by post, or electronically via the National Public Service Portal or the administrative procedure information system, in line with applicable regulations. Statutory processing timelines vary depending on the specific procedure and stage involved. For applications to obtain a license to organize a crypto asset trading market, the process is conducted in multiple phases: The MOF will issue an initial written response within 20 working days from receipt of a complete and valid initial dossier, following which, upon submission of the full set of required documents, the MOF will complete substantive review and issue the license (or a refusal with stated reasons)

On January 16, 2026, Thailand’s Electronic Transactions Committee released for public comment a draft notification that would require social media platforms operating in Thailand to implement identity verification for all user accounts and advertisers, with enhanced scrutiny for high-risk advertising activities. If finalized in its current form, the Notification on Measures to Prevent Technology Crime for Social Media Service Providers would take effect 180 days after publication in the Government Gazette, fundamentally changing how platforms verify users and monetize advertising services. The public comment period is open through February 2, 2026. Mandatory User and Advertiser Identity Verification The draft establishes a universal requirement that all social media service providers implement identity verification measures for every user account. The draft imposes stricter verification obligations for advertisers than for general users. Before publishing any advertisement, platforms must verify the advertiser’s identity at a level sufficient to identify the advertiser, unless the advertiser has previously completed verification. Risk-Based Advertisement Verification The identification requirements for advertisers will be more stringent in the following cases: The advertiser has a history of user complaints or has previously violated the platform’s terms of service. The advertisement involves finance, investment, loans, sensitive personal data, or content flagged as potentially involving cybercrime. The advertisement specifically targets vulnerable groups, such as the elderly or other at-risk demographics. In such cases, platforms must conduct identity verification using government-issued identification documents and must confirm the accuracy, authenticity, and currency of these documents with the issuing government agencies. Alternatively, platforms may verify identity through an eligible digital identity verification and authentication system provider. Information Retention Platforms must retain specific information for each advertiser, including the name of the individual or juristic person and any representatives, government-issued identification documents such as ID cards, passports, or certificates of incorporation, and reachable contact information including addresses and telephone numbers. When a third party pays advertising fees

Spurred by global geopolitics and Canada’s Indo-Pacific Strategy, which aims to forge deeper ties with ASEAN, Canadian companies have been showing growing interest in Thailand and Southeast Asia in recent years. To understand the opportunities offered by the region, we sat down with Andrew Stoutley, a Toronto native and the chief operating officer of Tilleke & Gibbins, a leading Southeast Asian regional law firm with over 130 years of history in Thailand. Q: Why are Canadian companies looking at Thailand and Southeast Asia right now? A: Two reasons stand out. First, diversification has moved up the agenda. Many Canadian companies want options outside North America due to tariff volatility and policy uncertainty in the United States, as well as questions around the next Canada–United States–Mexico Agreement mandatory joint review. At the same time, the shift of global production from China to Southeast Asia is accelerating, driven by rising costs, geopolitics, and the need to avoid overreliance on a single market. As a result, Canadian companies are looking for a second production base or a regional hub, and Thailand and its neighbors are natural choices given their manufacturing depth, location, and established supply chains. Second, Canada’s own efforts in the region are gaining traction. The Indo-Pacific Strategy has led to more on-the-ground support, including larger trade missions, upgraded diplomatic posts, and new financing options. Export Development Canada (EDC) now has a presence in Bangkok, giving Canadian companies a direct line to financing and insurance in Thailand. There’s also steady progress on trade frameworks like the recently signed Canada–Indonesia Comprehensive Economic Partnership Agreement (which will come into effect pending domestic procedures), ongoing negotiations of a Canada–ASEAN FTA, and the exciting announcement about the launch of negotiations of a Canada–Thailand FTA. Together, these developments have the potential to make it much easier for Canadian

Arbitrations seated in Thailand are governed principally by the Arbitration Act B.E. 2545 (2002) and, where applicable, the rules of institutions such as the Thailand Arbitration Center (THAC) and the Thai Arbitration Institute (TAI). While these instruments set the core procedural structure, they are not comprehensive. To fill in these procedural gaps, arbitral tribunals often look to the Thai Civil Procedure Code (CPC) and apply its principles when the Arbitration Act or institutional rules are silent. This hybrid system is familiar to local practitioners but can surprise international parties who expect a more self-contained arbitral procedure. Examples of How CPC Principles Are Applied Evidence Management: Section 25 of the Arbitration Act requires equal treatment of the parties and guarantees each side a full opportunity to present its case. At the same time, it grants tribunals broad discretion to conduct proceedings “as it deems appropriate” and expressly suggests that arbitrators may apply the CPC evidence rules where appropriate. In practice, tribunals frequently apply CPC evidence rules when addressing: submission of evidence lists, late or additional evidence, questions of admissibility and relevance, and assessment of witness and expert testimony. Amendments to Pleadings: Because the Arbitration Act and institutional rules provide limited guidance on amending pleadings, tribunals often rely on CPC principles when parties seek to amend a statement of claim or defense. Amendments may be permitted if they are sought in a timely manner, do not unfairly prejudice the opposing party, do not cause undue delay, and do not alter the nature of the dispute. These conditions closely mirror the standards applied by Thai courts under the CPC. Subpoenas and Court Assistance: Arbitral tribunals seated in Thailand generally do not have inherent subpoena powers. Section 33 of the Arbitration Act fills this gap by permitting the tribunal, an individual arbitrator, or a party (with the tribunal’s approval) to request judicial

Thailand’s Board of Investment (BOI) has imposed new restrictions on foreign-majority shareholding and land ownership for companies in certain promoted activities. The changes took effect on September 1, 2025, but were not published in the Government Gazette until December 30, 2025, under Notification of the Board of Investment No. Sor. 7/2568 on the Amendment to List of Activities Eligible for Investment Promotion under Notification of the Board of Investment No. 9/2565, dated July 22, 2025. Foreign Land Ownership Restrictions Generally, foreign land ownership is one of the privileges granted to BOI-promoted companies, allowing them to own land to engage in the promoted activities. However, with these new restrictions, the BOI will no longer grant land-ownership privileges to foreign-majority-owned companies that conduct business activities in the following categories: Rolling, drawing, casting, or forging of nonferrous metals (category 5.4.9) Manufacturing of ferrous metal products or ferrous metal parts (category 5.4.11.2) Manufacturing of nonferrous metal products and/or nonferrous metal parts for industrial use (category 5.4.11.4) Manufacturing of other metal products, including other metal parts for industrial use (category 5.4.11.5) Manufacture of chemical products for industry (category 6.2) Manufacture of plastic products for industrial goods and parts (category 6.4.1) These restrictions do not apply to existing BOI-promoted companies that have at least three projects granted promotion under the same juristic person during the past 15 years (2011–2025) with total investment of at least THB 5 billion, excluding the cost of land and working capital. Foreign Shareholding Restrictions For companies to be eligible for BOI promotion in three other categories of business activities, at least 51% of the company’s registered capital must be held by Thai individual shareholders, unless the BOI-promoted activity is located within a special border economic zone as designated by the BOI. These three categories are: Manufacture of bags made of leather or artificial leather (category 9.8; not included in this restriction are

As the Thai stock market faces a downturn, Thai investors have shown increased interest in depositary receipts (DRs), which offer the same tax benefits as Thai stocks while providing access to foreign securities. However, recent speculation in the media has raised concerns among regulators and the market, raising questions about whether DR issuers actually hold the underlying foreign securities purported to be backing the DRs. This has brought the structural integrity of DR programs under scrutiny. Why This Question Matters In global practice, DRs are understood to be backed by the foreign securities they reference, giving investors economic exposure that closely mirrors direct ownership. When the issuer does not hold the underlying securities directly, the risk profile shifts to the strength of its custodial, hedging, and liquidity arrangements. Those arrangements determine whether DR holders receive equivalent economic and voting rights, how corporate actions are transmitted, and whether conversions or redemptions can be completed in full and on time. In Thailand, the standardized DR disclosure templates and the express allowance for global custodians indicate a regulatory focus on transparency and structural safeguards that preserve these outcomes, even if the issuer’s name does not appear on the foreign share register. Thai Rules for DR Offerings Thai DR offerings are governed by specific Securities and Exchange Commission (SEC) notifications and standardized prospectus forms. These instruments establish the disclosure regime for DR structures, risk factors, and the issuer’s arrangements to support the DR program. The framework expressly contemplates the use of a global custodian, indicating that DR issuers are not required to hold the underlying foreign securities directly in their own name if sufficient controls and operational arrangements are in place for the issuer to deliver economic benefits and, where applicable, underlying securities to DR holders when required. More broadly, the relevant SEC notifications and DR disclosure forms do