DBD Intensifies Crackdown on Illegal Businesses: Public Urged to Avoid Nominee Arrangements and Mule Accounts
As of December 2025, the Department of Business Development (DBD)’s Division for the Prevention and Suppression of Illegal Businesses continues to ramp up its efforts to combat unlawful practices, particularly the use of nominee shareholders and juristic person mule accounts. Following the Division’s establishment in October 2025 and the subsequent rollout of stricter measures, the public and business operators are strongly advised to strictly comply with Thai laws to avoid severe legal consequences.
The DBD has emphasized that certain high-risk groups must exercise extra caution when involved in company registrations or shareholding. Registering a company or holding shares in circumstances that raise red flags—such as links to suspicious networks or lack of genuine business intent—can lead to suspicions of acting as a nominee or facilitating mule accounts, both of which are serious violations.
Furthermore, the Department is closely monitoring cases where companies appear to lack real operational substance, such as those without proper financial trails, active business activities, or verifiable capital sources. Foreign nationals or entities attempting to control Thai companies through hidden ownership structures are particularly at risk of investigation.
In cases where discrepancies arise—such as mismatches between reported shareholders and actual control, or unusual transaction patterns—companies and individuals involved may be required to clarify their positions promptly. Failure to demonstrate legitimate business operations could result in legal action, including fines, company dissolution, or criminal charges.
The DBD reiterates that nominee arrangements, where Thai nationals hold shares on behalf of foreigners to bypass foreign ownership restrictions, undermine economic fairness and national security. Similarly, registering juristic persons primarily to open bank accounts for fraudulent purposes erodes public trust and facilitates crime.
To protect yourself and ensure compliance:
- If you are a shareholder or director, actively participate in the company’s operations and maintain proper records.
- Avoid agreeing to hold shares or register companies on behalf of others without a full understanding and genuine involvement.
- Businesses should regularly review their structures for transparency and report any suspicious approaches immediately.
The Division is committed to fostering a transparent and equitable business environment. Violations not only harm the economy but also carry heavy penalties. Citizens are encouraged to correct any irregular arrangements voluntarily and seek guidance from the DBD to align with the law.
For our earlier article on the establishment of the Division, refer to https://thelegal.co.th/2025/10/14/department-of-business-development-establishes-division-to-combat-illegal-business-practices/ : Department of Business Development Establishes Division to Combat Illegal Business Practices.
Related Article: https://thelegal.co.th/2025/10/14/department-of-business-development-establishes-division-to-combat-illegal-business-practices/
Author: Panisa Suwanmatajarn, Managing Partner.
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