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, a relatively small portion result in further investigation for violation of the Act. That

Thailand’s Securities and Exchange Commission (SEC) has amended its digital asset regulations to permit the offering, trading, and provision of services related to tokenized environmental commodities by licensed digital asset exchanges, brokers, and dealers. This regulatory development is aimed at facilitating Thailand’s green economy and net-zero goals while diversifying the products available in the regulated digital assets market. The environmental commodities currently being traded on certain market platforms and via over-the-counter channels include: Carbon credits: Tradable certificates representing a reduction of CO₂ emitted into the atmosphere. Renewable energy certificates (RECs): Tradable proof of electricity generated from renewable energy sources. Carbon allowances: Tradable permits to emit a capped amount of greenhouse gases. The tokenization of these instruments is essentially the process of converting them into digital tokens, making it possible to list them on blockchain exchanges for trading purposes. Background Tokenized carbon credits, RECs, and carbon allowances fall under the category of utility tokens for consumption purposes or tokens representing entitlement certificates—that is, group 1 utility tokens, which are not considered financial products. The offering, trading, and provision of secondary-market services of this type of token are exempted from licensing requirements for regulated digital asset businesses under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018). Under the previous regulatory framework, licensed digital asset business operators were not allowed to provide services involving such unregulated tokens, as it was deemed to be engaging in “other businesses,” which digital asset operators generally cannot engage in without prior SEC approval. Regulatory Amendment Under the amended digital asset regulations, licensed digital asset exchanges, brokers, and dealers may now apply for SEC approval to offer services related to these tokenized assets as “other businesses,” including listing them for trading on digital asset exchanges. Apart from requiring operators to comply with the general conditions for operating “other businesses,” the SEC has imposed the following additional

Under Thai law, authorized directors stand as a company’s mind and will and, as such, may incur personal criminal liability for acts or omissions committed in the course of company business. When allegations surface, directors must be prepared for the practical reality that, before guilt or innocence is ever adjudicated, they could be deprived of liberty unless bail release is promptly achieved through the competent legal authority. When Bail Can Be Granted Two procedural moments trigger the need to consider bail. The first arises during the investigative phase, when a claim is lodged against a director with the competent law enforcement authorities. Upon receipt of a complaint, the assigned inquiry officer summons the director for questioning, compiles evidence, and ultimately forwards a prosecution or nonprosecution recommendation to the public prosecutor. Although the public prosecutor retains ultimate discretion to indict an accused director, the police or prosecutor may conclude that pretrial detention is necessary and may therefore apply to the court for an order to hold the director in court custody. The second moment occurs after a criminal case is filed directly with the court. This occurs once a court accepts a criminal case filed by a prosecutor against a director or, alternatively, when the court accepts a case filed by an individual for trial. For cases filed by individuals, the plaintiff presents prima facie evidence at the preliminary hearing, and the court will accept the complaint if it finds sufficient grounds, thereby conferring upon the director the status of a criminal defendant. Upon acceptance of the criminal case, the court then has the inherent authority to order custody pending trial unless the defendant secures bail release. Procedural Considerations Experienced litigants typically prepare bail security in advance and submit a bail petition at the earliest possible time. While there are guidelines for setting the amount

On September 1, 2025, Myanmar’s Directorate of Investment and Company Administration (DICA) issued Directive No. 106/2025 to remind all companies and organizations registered under the Myanmar Companies Law of their obligation to strictly comply with the DICA registrar’s orders, directives, and procedures. This directive highlights the importance of legal and procedural compliance in corporate filings, governance changes, and operational conduct. It also signals increased scrutiny over documentation submitted during annual returns, share transfers, and director appointments or resignations. Public companies will be subject to closer regulatory attention, and new company registrations will involve vetting of proposed directors to ensure prior compliance with applicable laws. Compliance The directive emphasizes the following points: Companies must ensure full compliance with the Myanmar Companies Law and all directives issued by the registrar. This includes the proper submission of annual returns and adherence to updated requirements for share transfers and changes in directors. Companies and organizations must comply with all applicable laws, rules, directives, and procedures issued by relevant ministries and departments. If any authority takes action due to noncompliance, the registrar may also take appropriate measures. Noncompliance may result in regulatory sanctions, including restrictions on future company participation and vetting under anti–money laundering and counter–terrorism financing protocols. Prospective directors of newly registered companies will be vetted to confirm no prior violations of applicable laws. Entities must respond promptly and accurately to document requests from the registrar, both during initial registration and in subsequent filings. Companies are strongly advised to review their internal compliance frameworks and ensure readiness to meet DICA’s documentation and procedural expectations. In particular, companies must respond promptly and accurately to document requests from the registrar, whether during initial registration or in subsequent filings. For more information on this DICA announcement, or on any aspect of corporate registration, or assistance with corporate secretarial matters in Myanmar, please contact Tilleke & Gibbins at [email protected].

The Indonesian government has implemented mandatory halal certification to protect its predominantly Muslim population. To ensure halal standards, the government has issued several key regulations, including Law No. 33 of 2014 concerning Halal Product Assurance, Government Regulation No. 42 of 2024 concerning Implementation of Halal Product Assurance, and specifically for imported products, Decision of the Head of Halal Product Assurance Agency (BPJPH) No. 90 of 2023 concerning Procedures of Implementing Foreign Halal Certificate Registration. Compliance Deadlines The government has established statutory deadlines for products and services to obtain halal certification under Government Regulation No. 39 of 2021 concerning Implementation of Halal Product Assurance. The deadline for imported food, beverages, and slaughtering products and services to comply with halal certification was extended to October 17, 2026 (from October 17, 2024, originally) with the issuance of Government Regulation No. 42 of 2024. Other product categories have varying deadlines: October 17, 2026: Natural drugs, quasi-drugs, health supplements, cosmetics, chemical products, genetically engineered products, clothing and accessories, household supplies, prayer equipment, stationery, and class A medical devices October 17, 2029: Over-the-counter drugs and class B medical devices October 17, 2034: Prescription drugs (excluding psychotropics) and class C medical devices SHLN Registration for Imports To simplify the halal certification process for imported products, BPJPH offers a foreign halal certificate registration (Registrasi Sertifikat Halal Luar Negeri, or SHLN registration) pathway. This allows eligible imported products to obtain halal certification without filing the standard national halal certification procedure. Under the Halal Law, imported products are not required to apply for national halal certification if their halal certificate is issued by a foreign halal institution that has entered into a mutual recognition agreement (MRA) with BPJPH. Currently, 89 foreign halal institutions from countries (including the United States, South Korea, Thailand, and the United Kingdom) have entered into MRAs with BPJPH, with an additional 29 institutions in the

With advancements in health technology, telemedicine has taken on a wider online presence in Thailand. Under the Medical Facility Act, licensed clinics and hospitals may now diagnose, prescribe, and issue electronic prescriptions during a video call, provided they maintain patient confidentiality and proper recordkeeping. As a complementary concept, a telepharmacy allows a pharmacist to verify prescriptions, counsel patients, and dispense medication from a remote site. Hospitals, clinic chains, and some retail pharmacy groups have adopted “drive-thru” or “locker” pick-up points where drugs are bagged only after a real-time video consultation with a registered pharmacist. The clear benefits of telehealth include shorter waiting times and broader access to specialists, which is in the public interest. Drug Distribution and Advertising in Thailand The online pharmacy ecosystem creates a legal bridge in that once a teleconsulting doctor issues an e-prescription, a licensed pharmacy can lawfully dispense and deliver the medicine prescribed to the patient’s door. Nonetheless, the critical compliance component remains the advertising of medicinal drugs. It is still not allowed to advertise prescription/pharmacy-dispensed drugs to the public in Thailand. Although Thailand’s Drug Act of 1967 was written more than half a century ago, it still governs the trading of every medicinal drug that makes its way to consumers in Thailand—whether bought at a pharmacy or delivered with a few taps on a smartphone. First and foremost, the pharmacy must hold a license to sell medicinal drugs as a retailer. It is also mandatory that arrangements be made for a pharmacist to be on duty during opening hours. Drugs are classified into three main categories: prescription drugs, pharmacy-dispensed drugs, and over-the-counter (OTC) drugs. The listing of OTC drugs with their prices via an online platform is allowed, as only OTC drugs may be advertised directly to the public. However, naming or showing a prescription drug or pharmacy-dispensed drug

On June 6, 2025, the Superior People’s Court in Hanoi overturned a non-use cancellation decision by the Intellectual Property Office of Vietnam, a rare and impactful occurrence. In a ruling that may help clarify the enforcement of Vietnam’s IP Law, the court held that valid trademark use can be established through commercial arrangements where the brand owner maintains actual control over the use of the mark, and is not confined to relationships governed by a so-called “formal license agreement. Background: Cross-Border Use, Local Challenge A Singapore company owns a well-known brand of consumer products that has gained recognition across Southeast Asia. In recent years, the brand has been targeted by several unauthorized trademark filings in Vietnam. In one such instance, a local Vietnamese trading company—previously linked to the production and export of counterfeit goods to neighboring countries—filed a non-use cancellation against the Singapore company’s mark and sought to register it under its own name. If the cancellation had been upheld, it would have enabled a complete hijacking of the brand. The IP holder operates in Vietnam through a structured cross-border supply chain. Under an agreement between two related foreign entities, one of which managed regional operations, production orders were placed through a designated Vietnamese company. While the Vietnamese manufacturer was not a party to the agreement, its role in using the mark was recognized and governed by internal and commercial documentation. The Vietnamese manufacturer lawfully obtained the necessary permits, regulatory approvals, and customs clearances for producing the goods in Vietnam. These activities were supported by banking records and internal communications, evidencing active, continuous use of the mark in Vietnam. However, the IP Office concluded that this use did not meet the statutory criteria because the Vietnamese manufacturer did not have a direct license agreement with the brand owner, as outlined in provisions on trademark

Liberal cannabis access in Thailand is officially over. On June 26, 2025, the Ministry of Public Health brought the inflorescence of cannabis back under tight control through its new Notification on Controlled Herbs (Cannabis) 2025 (“Notification 2025”). The message is that cannabis may stay in the marketplace, but only if strictly supervised under a cannabis prescription from a medical professional. Two main pillars now define compliance: (1) prescription requirements and mandatory reporting, and (2) Good Agricultural and Collection Practices (GACP). This article aims to summarize each essential element for the relevant parties. 1. Getting a Prescription: Digital Diagnosis vs. Real-World Paperwork? Dispensaries, even those with a license to sell cannabis, can no longer sell cannabis to walk-in customers who don’t have a valid prescription. Sales are lawful only when the buyer duly presents a cannabis prescription issued by one of seven recognized professional practitioners, including medical doctors, Thai traditional medicine doctors, applied Thai traditional medicine doctors, folk healers, Chinese medicine practitioners, pharmacists, or dentists. Notification 2025 does not mention teleconsultations or online prescriptions. Nonetheless, policymakers at this stage opine that an online chat or casual consultation, with the prescription sent via a social media platform or e-mail, would not comply with this latest regulation. In order to be eligible to issue cannabis prescriptions, medical doctors should be working in a clinic or hospital and should issue paper-based prescriptions. The official prescription form, called a PT 33, must be used. The prescriber has the discretion to indicate the cannabis strain (or product type), dosage, and intended duration of use, which cannot exceed 30 days per prescription. This ensures that the product matches the patient’s medical needs and aligns with professional treatment guidelines. In practice, each prescription will be valid for one-time use only and cannot be refilled; a new prescription will be required