In a significant step toward strengthening its financial integrity, Thailand has approved two major legislative amendments to combat money laundering and align its legal framework with international standards. On February 25, 2025, Prime Minister Paetongtarn Shinawatra chaired a cabinet meeting where the Draft Act on Anti-Money Laundering (No.) B.E. …. and the Draft Act on the Repeal of Legal Provisions Defining Predicate Offenses under the Anti-Money Laundering Law B.E. …. were officially approved. These drafts, which underwent comprehensive review by the Office of the Council of State (OCS), introduce stricter regulations and expanded definitions to enhance financial oversight.
Key Amendments in the Draft Act on Anti-Money Laundering (No.) B.E. ….
Expanded Definition of Predicate Offenses
The revised law broadens the scope of predicate offenses by integrating crimes under various statutes, including the Narcotics Act, the Customs Act B.E. 2560 (2017), and the Act on the Prevention and Suppression of Participation in Transnational Organized Crime B.E. 2556 (2013). Key additions include:
✓ Tax evasion and fraudulent tax schemes within criminal networks under the Revenue Code.
✓ Financing of terrorism and the proliferation of weapons of mass destruction.
✓ Participation in transnational organized crime.
✓ Forced labor and human trafficking-related offenses.
✓ Child pornography under the Penal Code.
✓ Financial fraud involving digital assets and futures trading.
✓ Usury (excessive interest rates).
✓ Collusion in government contract bidding.
Conversely, offenses related to unfair trading in agricultural futures markets have been removed to ensure regulatory relevance.
Expanded Scope of Financial Institutions
The updated legislation extends regulatory oversight to a wider range of financial institutions, including:
✓ Banks, finance companies, securities firms, and life insurance providers.
✓ Savings cooperatives and credit unions with share capital exceeding 50 million baht.
✓ Credit card companies, foreign exchange services, digital asset platforms, and fintech providers.
New Definition of Criminal Networks
A criminal network is now defined as a group of three or more individuals collaborating in unlawful activities for financial or material gain, whether directly or indirectly. This definition strengthens law enforcement’s ability to dismantle organized crime operations.
Stronger Reporting Requirements
Financial institutions and professionals are now subject to enhanced reporting obligations under the Anti-Money Laundering Office (AMLO). Key measures include:
✓ Mandatory updates on material changes to previously reported information.
✓ Agricultural cooperatives with share capital of at least 100 million baht must now comply with financial reporting standards.
✓ Customs officers must report cross-border cash and monetary instrument transfers in compliance with exchange control regulations.
✓ Increased transparency for trustees under capital market trust laws, vehicle leasing businesses, and antique/artwork dealers.
✓ Non-profit organizations receiving significant foreign funds must disclose financial details to prevent misuse.
✓ AMLO will implement stricter guidelines for high-risk transactions and record-keeping requirements.
New Asset Management and Forfeiture Provisions
Legitimate property owners unaware that their assets were used in illicit activities may now petition for immediate return of their property. Conversely, AMLO can seek court-ordered confiscation of assets, including mortgaged properties, if it is proven that the buyer knowingly facilitated money laundering. If non-criminal assets are not claimed within ten years, they will be transferred to the Anti-Money Laundering Fund.
Revised Penalties
Penalties for non-compliance have been adjusted to reflect proportional enforcement:
✓ Failure to provide requested documents or testimony without a valid excuse carries a maximum penalty of one year in prison or a fine of up to 20,000 baht.
✓ Penalties for failing to assist AMLO officers in their duties have been removed.
The Draft Act on the Repeal of Legal Provisions Defining Predicate Offenses under the Anti-Money Laundering Law B.E. ….
To simplify Thailand’s regulatory framework, this act eliminates redundant predicate offense definitions from multiple laws, including:
✓ Tax evasion (Revenue Code, Section 37 Ter), which previously applied to fraud involving at least 10 million baht per year or fraudulent tax refunds exceeding 2 million baht per year.
✓ Forced labor (Anti-Trafficking in Persons Act, Section 14), covering cases of labor exploitation through intimidation, document withholding, and unlawful debt bondage.
✓ Participation in transnational organized crime (Act on Prevention and Suppression of Participation in Transnational Organized Crime, Section 22).
✓ Financing of terrorism (Act on Prevention and Suppression of Financing of Terrorism, Section 25, Paragraph 6), which criminalizes financial assistance to known terrorists or designated organizations.
Implications for Thailand’s Financial Security
These legislative updates mark a significant milestone in Thailand’s ongoing efforts to combat money laundering, terrorist financing, and financial fraud. By aligning with international best practices, the new laws enhance transparency, regulatory enforcement, and financial stability while reinforcing Thailand’s commitment to global anti-money laundering (AML) and counter-terrorist financing (CTF) initiatives.
Businesses, financial institutions, and professional service providers must now adapt to the updated compliance landscape to avoid penalties and ensure adherence to the strengthened regulatory framework. As Thailand continues to enhance financial oversight, these reforms are expected to bolster investor confidence and safeguard the integrity of the nation’s financial system.