BOT: Bank of Thailand Introduces Stricter Rules on Large Cash Transactions to Combat Illicit Flows

The Bank of Thailand (BOT) is set to implement enhanced oversight on significant cash movements as part of efforts to address gray-area financial activities, reduce risks of money laundering, and promote greater transparency in the financial system.

Under the upcoming regulations, financial institutions will soon be required to perform detailed customer due diligence for any cash withdrawal exceeding 5 million baht in a single transaction. Customers must clearly explain the source of the funds and the intended purpose of the cash. If the explanation is unsatisfactory or unverifiable, banks may restrict or decline to process the transaction.

This measure primarily targets unusual or high-risk cash usage that could be linked to informal, unregulated, or illicit activities. In a later phase, similar requirements will apply to cash deposits of 5 million baht or more, where the origin of the funds must also be justified.

The BOT has indicated that legitimate needs—such as those of small and medium-sized enterprises (SMEs), individuals conducting regular business operations, or other verifiable purposes—will continue to be accommodated, provided appropriate documentation and explanations are provided. However, the rules aim to make large-scale cash handling more accountable and discourage reliance on physical currency for questionable purposes.

Looking ahead, after an initial implementation period and evaluation of impacts (including any effects on ordinary users), the threshold may be lowered to 3 million baht for both withdrawals and deposits to further strengthen controls.

These changes form part of broader initiatives to tackle structural economic vulnerabilities, encourage electronic payments where practical, and limit opportunities for crime or opaque transactions.

Impact on the Public:

Most everyday individuals and small businesses will remain largely unaffected, as transactions below the 5 million baht threshold face no new requirements, and legitimate large needs can proceed with proper justification.

People or entities accustomed to handling large cash amounts (e.g., for property deals, business purchases, or other high-value activities) will need to prepare explanations and supporting evidence in advance, potentially adding time and documentation steps at the bank.

Those involved in informal or gray-area dealings may find it significantly harder to move large sums in cash without scrutiny, increasing the risk of restrictions or reporting to authorities.

Overall, the shift promotes safer, more traceable financial habits while aiming to reduce crime risks associated with large cash volumes and ease burdens through related reviews of common banking fees.

Key Takeaways:

Implementation is expected in the near future (early to mid-March timeframe), giving the public time to adjust to more accountable cash handling practices.

Cash withdrawals over 5 million baht will require clear justification of purpose and source; unsatisfactory explanations may lead to restrictions.

The rules will later extend to large cash deposits and could lower the threshold to 3 million baht after review.

Legitimate users (e.g., SMEs and individuals with valid reasons) can continue transactions by providing details—no outright ban is intended.

Author: Panisa Suwanmatajarn, Managing Partner.

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BOT: Draft Regulations on Enhanced Customer Due Diligence and Risk Management for Customer Use of Financial Services, Including Cash-Related Transactions

The Bank of Thailand (BOT) has issued draft regulations aimed at strengthening the framework for customer due diligence (CDD), know-your-customer (KYC) processes, and risk management practices among financial institutions (FIs) and specialized financial institutions (SFIs). These proposals establish a comprehensive, risk-based, end-to-end approach to prevent the financial system from being exploited for financial crimes, enhance public confidence in financial services, and provide equitable protection for customers affected by such activities.

The drafts address evolving risks, particularly those associated with abnormal transaction patterns and the inherent challenges of cash-based operations, which remain vulnerable to misuse due to their anonymity and traceability limitations. Key obligations include governance oversight, robust identity verification, continuous transaction monitoring, enhanced due diligence (EDD) for suspicious cases, secure record-keeping, and mandatory reporting of abnormal activities to the BOT.

1. Draft Criteria for Practices and Risk Management Arising from Customers’ Use of Financial Services

This regulation requires FIs and SFIs to implement and continually refine processes throughout the customer relationship lifecycle, proportionate to identified risks.

•  Governance: The board of directors and senior management must establish and approve risk-based CDD/KYC policies, ensure adequate resources, and conduct periodic reviews. Significant policy amendments require board approval. Institutions must maintain clear structures for roles, responsibilities, and the three lines of defense to support effective risk controls.

•  KYC and CDD: Institutions must verify customer identity and authenticity using reliable sources, identify beneficial owners, and prevent identity fraud. For savings accounts (high-risk products), specific verification methods apply:

       •  Thai individuals: Primary use of national smart cards via readers and electronic government systems, with defined alternatives for exceptional cases.

       •  Foreign individuals: Passports and verifiable residency documents, preferably using technologies such as Near Field Communication (NFC), along with evidence of purpose of stay.

       •  Legal entities: Official registration documents to determine ownership, control, and business nature.

•  Monitoring and Enhanced Due Diligence: Continuous systems must detect abnormal transactions or behaviors. Upon identification of anomalies, EDD is required, including inquiries into source of funds, financial status, and transaction purpose. Transactions must be rejected if EDD cannot be satisfied or if criminal indicators are evident.

•  Customer Support: Fair and prompt procedures must assist customers impacted by risk management actions who are not involved in suspicious conduct.

•  Record-Keeping and Reporting: Customer and transaction data must be securely retained for prescribed periods to support regulatory oversight. Suspicious transactions and abnormal patterns must be reported to the BOT in specified formats.

2. Draft Criteria for Practices and Risk Management of Cash-Related Transactions

This regulation imposes heightened controls on cash activities—including deposits, withdrawals, cashier’s cheques, and currency exchanges—conducted through branches or electronic channels, recognizing cash’s role in facilitating illicit flows.

•  Strengthened Identity Verification: Customers must present themselves or complete verified authentication before engaging in any cash-related transaction to eliminate anonymous or proxy movements.

•  Monitoring Abnormal Cash Movements: Institutions must monitor for patterns inconsistent with customer profiles or lacking economic rationale, including excessive high-value or frequent transactions.

•  Enhanced Due Diligence for High-Value Cash Transactions: Abnormal patterns trigger EDD. If purpose or legitimacy cannot be verified, transactions must be refused, with mandatory reporting to the BOT.

•  Support for Affected Customers: Processes must ensure timely and equitable assistance for victims of financial crimes, particularly in cash-related contexts.

These draft regulations represent the BOT’s ongoing commitment to bolstering anti-money laundering measures, improving transparency, and safeguarding the integrity of Thailand’s financial system through stricter oversight of customer onboarding, verification, and high-risk transactions.

Key Takeaways:

•  Financial institutions and specialized financial institutions will be required to adopt comprehensive risk-based CDD/KYC frameworks across the full customer lifecycle.

•  Governance responsibilities rest with boards and senior management to ensure effective policies, resources, and controls.

•  Cash transactions face particular scrutiny, mandating identity verification, monitoring of unusual patterns, and refusal of unverified high-risk activities.

•  Enhanced monitoring, EDD, secure record retention, and regulatory reporting aim to detect and mitigate financial crime risks promptly.

•  Institutions must balance risk management with fair treatment of legitimate customers impacted by these measures.

Author: Panisa Suwanmatajarn, Managing Partner.

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BOI: Accelerates Implementation of Thailand FastPass to Unlock Over 480 Billion Baht in Strategic Investments

The Board of Investment of Thailand (BOI) continues to advance the Thailand FastPass mechanism as a central tool for expediting large-scale private investments. As outlined in the detailed overview titled “Thailand FastPass: Implementation Details for Expediting Strategic Investments” BOI’s FastPass: Implementation Details for Expediting Strategic Investments – The Legal Co., Ltd., the mechanism was established to address regulatory and operational delays affecting high-priority projects, initially targeting approximately 70 initiatives valued at around 300 billion baht.

Recent developments indicate that the scope has expanded significantly. The BOI is now focusing on unlocking investments exceeding 480 billion baht across roughly 80 stalled or pending projects. These initiatives span critical sectors including data centers, renewable and clean energy facilities, electric vehicle production and component manufacturing, advanced electronics, printed circuit boards, and industrial estate expansions. Delays have primarily stemmed from challenges in electricity grid capacity allocation, land acquisition and zoning approvals, environmental impact assessment processes, visa issuance, and work permit procedures.

The FastPass framework retains its core structure while scaling to meet the increased volume:

•  Projects are selected according to minimum investment thresholds, alignment with national strategic industries, and capacity to generate substantial economic benefits such as employment, domestic supply-chain integration, and technology transfer.

•  Participants are required to commit to accelerated disbursement schedules—typically at least 20 percent of the total investment value within a short, defined period (e.g., six months or within the current fiscal year)—to demonstrate immediate economic contribution and justify expedited processing.

•  Inter-agency coordination, supported by dedicated subcommittees and formalized service-level agreements, continues to target a 20–50 percent reduction in approval and licensing timelines for electricity provisioning, land development, immigration services, labor permits, and environmental clearances.

This intensified application of FastPass aligns with the government’s broader Big Win economic strategy, which prioritizes structural transformation in three key domains:

1.  Smart Agriculture: Deployment of technology to lower production costs and position Thai agricultural products at premium global market levels.

2.  Modern Industries: Sustained investment momentum in electric vehicle ecosystems and intelligent electronics manufacturing.

3.  Premium Services: Elevation of tourism and hospitality toward high-value segments, including wellness tourism and advanced experiential offerings.

The BOI is ensuring continuity of these efforts across potential changes in administration. Preparations are also underway for complementary measures, including an enhanced version of the Half-Half Plus program that incorporates mandatory reskilling and upskilling components for participants, with the aim of significantly increasing incomes for small retailers while maintaining focus on equitable distribution to micro and small enterprises in provincial areas.

By channeling substantial private capital without additional public expenditure, the Thailand FastPass mechanism supports immediate economic activation, job creation, industrial upgrading, and Thailand’s long-term positioning within global high-technology value chains.

Key Takeaways:

•  Thailand FastPass now targets the realization of over 480 billion baht across approximately 80 strategic projects in sectors such as data centers, clean energy, and electric vehicles.

•  Qualifying projects must commit to rapid investment disbursement (e.g., minimum 20 percent within a short timeframe) to access expedited approvals.

•  Inter-agency collaboration aims to reduce processing times by 20–50 percent for electricity, land, visa, permit, and environmental requirements.

•  The mechanism supports the Big Win priorities of smart agriculture, modern industries, and premium services while maintaining policy continuity.

•  The approach delivers prompt private-sector stimulus and contributes to sustainable, long-term economic competitiveness.

Related Article: BOI’s FastPass: Implementation Details for Expediting Strategic Investments – The Legal Co., Ltd.

Author: Panisa Suwanmatajarn, Managing Partner.

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BOT: Strengthening Financial Oversight to Address Baht Pressures and Enhance Stability

The Thai baht continues to face pressures stemming from global monetary policy divergences, volatile capital movements, and heightened risks associated with financial crime. Despite robust macroeconomic fundamentals and record-high foreign exchange reserves, the Bank of Thailand (BoT) has implemented a multifaceted strategy that extends beyond traditional monetary policy tools. This approach addresses vulnerabilities in financial transparency, misuse of cash, flows through alternative assets such as gold, and cross-border digital fraud.

Key initiatives include intensified monitoring of large cash withdrawals to disrupt grey funds, enhanced regulatory scrutiny of gold transactions, deepened collaboration with international organizations such as the International Monetary Fund (IMF) and the World Bank to combat digital fraud, and targeted foreign exchange interventions to ensure orderly market conditions.

1. Enhanced Monitoring of Large Cash Withdrawals and Grey Funds

The BoT is advancing stricter oversight of substantial cash withdrawals via commercial banks. Institutions will be required to identify and report transactions exceeding a designated threshold—anticipated to range between THB 3 million and THB 5 million—and to document the customer’s declared purpose. This measure targets the use of cash in illicit or opaque activities, including mule accounts, which are increasingly difficult to reconcile with modern payment preferences favoring electronic transfers. These efforts complement strengthened customer due diligence (CDD) and know-your-customer (KYC) protocols, while aligning with parallel controls on gold as an alternative channel for fund movements outside conventional banking systems.

2. International Collaboration to Counter Digital Fraud

In recognition of the cross-border and technology-driven nature of financial crime, the BoT has intensified partnerships with the IMF and World Bank. These collaborations focus on developing supervisory frameworks, sharing intelligence, and aligning domestic regulations with global standards to mitigate online scams, mule networks, and technology-enabled money laundering. The strategy emphasizes three core elements: reducing digital fraud incidence, bolstering cybersecurity resilience, and enhancing the readiness of Thailand’s digital financial ecosystem to safeguard societal financial well-being.

3. Baht Stabilization and Record Foreign Exchange Reserves

The BoT maintains a managed float regime, intervening only to moderate excessive volatility and preserve orderly conditions without pursuing a specific exchange-rate target. Recent baht appreciation—reaching near five-year highs and breaching 31 baht per US dollar—has been partly attributed to gold-related inflows rather than underlying economic fundamentals. To mitigate such pressures, the BoT is reinforcing oversight of gold transactions to curb short-term baht volatility from synchronized large-scale sales and to limit risks from grey capital flows via gold as a conversion or transfer mechanism.

4. Regulatory Updates on Gold and Foreign Exchange Transactions

On 26 January 2026, the Royal Gazette published Exchange Control Notifications No. 35 and No. 36, issued by the Competent Officer for Rules and Practices Relating to Foreign Exchange. These instruments refine the framework for gold trading and foreign exchange operations to promote transparency and audit-ability among high-value participants.

•  Notification No. 36 (effective from 27 January 2026) introduces stricter requirements for major gold traders—those involved in importing or exporting gold and averaging at least THB 10 billion per year in domestic gold transactions over the preceding five calendar years (or equivalent at market rates). Such entities must:
(i) submit transaction data electronically via BoT-designated systems or methods;
(ii) ensure the accuracy and completeness of reported information, with the Competent Officer retaining authority to request supplementary details as necessary; and
(iii) retain relevant records and supporting documentation for a minimum of three years for inspection purposes.

•  Notification No. 35 modernizes foreign exchange rules to reflect prevailing economic conditions. It relaxes certain obligations for foreign currency acquisitions below USD 10 million (or equivalent), permits individuals to execute direct overseas payments up to USD 5 million per person annually, and mandates licensed entities to verify investor compliance, secure required reports through BoT systems, maintain documentation for at least five years, and prevent misuse for speculation, unlicensed cross-border payments, or regulatory circumvention.

Potential Implications:

These measures will impose greater compliance and reporting obligations on banks, gold traders, digital platforms, corporate entities, and high-net-worth individuals. Cross-border operations may experience increased alignment with international norms, potentially reducing flexibility while enhancing predictability and transparency.

In summary, the BoT’s integrated response underscores the interconnected nature of contemporary financial risks across cash, alternative assets, digital channels, and international flows. By addressing both immediate pressures and underlying vulnerabilities, these policies aim to reinforce systemic resilience and sustain confidence in Thailand’s financial framework.

Key Takeaways:

•  The BoT is prioritizing transparency in gold and cash transactions to mitigate baht volatility and curb illicit flows.

•  Notification No. 36 mandates reporting and record-keeping for major gold traders (THB 10 billion+ average annual domestic volume).

•  Notification No. 35 eases certain foreign exchange thresholds while strengthening compliance safeguards.

•  International partnerships and domestic oversight enhancements target digital fraud and grey funds.

•  Market participants should prepare for heightened scrutiny, robust documentation, and proactive adaptation to ensure regulatory alignment.

Author: Panisa Suwanmatajarn, Managing Partner.

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Updates to Thailand’s Investment Promotion Regime

Overview of Recent Amendments to Investment Promotion Measures in Thailand

Pursuant to the Investment Promotion Act B.E. 2520 (1977), as amended, Thailand has established a comprehensive framework and institutional mechanisms for promoting investment. The primary objectives are to create an investment-friendly environment, foster industrial development, and promote equitable income distribution by granting investment incentives to business activities deemed significant and prioritized.

In furtherance of these objectives, the Board of Investment (BOI) issued Notification of the Board of Investment No. 9/2565 regarding Measures for the Promotion of Industries Critical to National Development (“BOI Notification No. 9/2565“). This notification establishes the categories of business activities eligible for investment promotion, together with the applicable conditions, criteria, and privileges granted to promoted projects, as detailed in the Schedule of Investment-Promoted Activities annexed thereto.

To align with Thailand’s evolving economic development policies and strategic direction, accommodate the rapid expansion of industrial activities, and enhance incentives for investors, the BOI issued two notifications dated 5 June B.E. 2568 (2025), which were published in the Royal Gazette on 22 January B.E. 2569 (2026). These notifications revise and update the investment promotion framework to reflect current economic and industrial conditions by amending certain categories of business activities eligible for investment promotion as prescribed in the Schedule of Investment-Promoted Activities. The key amendments are summarized below:

1. Notification of the Board of Investment No. Sor. 5/2568

Amendment to the List of Activities Eligible for Investment Promotion under BOI Notification No. 9/2565

This notification is issued pursuant to BOI Notification No. 9/2565, which prescribes the categories of business activities and conditions eligible for investment promotion as set forth in the Schedule of Investment-Promoted Activities. Certain categories have been amended to focus on investments that create added value, promote the adoption of modern technologies in the manufacturing sector, enhance the development of supply chains to ensure Thailand’s export-oriented production attains international recognition and delivers maximum benefits, and accommodate the rapid expansion of data center businesses by supporting Thailand’s advancement toward becoming a digital hub of the ASEAN region.

This notification revises the categories of business activities and conditions eligible for investment promotion with respect to 32 categories under the Schedule of Investment-Promoted Activities. The majority of these are activities that generate added value for the national economy, including the machinery and automotive industry, electrical appliances and electronics industry, metals and materials industry, public utilities, digital industry, and creative industry. Additionally, investment promotion for metal cutting activities (Category 5.4.10) has been discontinued and removed from the list of promoted activities. This notification applies to business operators who submit applications for investment promotion on or after 1 July B.E. 2568 (2025).

2. Notification of the Board of Investment No. Sor. 6/2568

Investment Promotion Measures for Tourism-Related Businesses in Secondary Cities

The public sector has provided support for tourism development in secondary cities, which are provinces that are not widely known but possess high tourism potential. To promote tourism, distribute income equitably, and sustainably expand economic opportunities to local communities, investment promotion measures have been introduced for tourism-related businesses located in designated secondary cities.

This notification revises the criteria and conditions for investment promotion applicable to certain categories of tourism-related businesses (including cruise terminals, hotels, international exhibition centers, and similar establishments), totaling 12 items under the Schedule of Investment-Promoted Activities. The location of the establishment serves as a key criterion for granting enhanced and more beneficial investment promotion privileges, such as extended periods of corporate income tax exemption, to create incentives for both domestic and foreign investors to invest in secondary cities and extend investment promotion benefits to tourism businesses located therein. This notification applies to business operators who submit applications for investment promotion on or after 5 June B.E. 2568 (2025).

Key Observations

1. Discontinuation of Metal Cutting Activities (Category 5.4.10)

Business activities previously eligible for investment promotion under Category 5.4.10 (metal cutting activities) are no longer entitled to apply for BOI promotion, as the BOI has formally discontinued investment promotion for this category. Businesses operating in the affected sectors should conduct a careful review of their current operations to determine whether they may qualify under other eligible promoted activities. Where necessary, they should consider restructuring their investment structures or business operations to ensure ongoing compliance with the revised BOI investment promotion framework.

2. Enhanced Incentives for Tourism-Related Businesses in Secondary Cities

Tourism-related businesses located in secondary cities, whether newly established or existing, may have opportunities to receive investment promotion incentives at a higher level than previously available, including longer and more favorable tax incentives, which may serve as a catalyst for increased investment. Conversely, businesses located in primary cities may not be entitled to the same level of preferential treatment as those located in secondary cities, which may result in heightened competitive pressure regarding operational costs.

Status and Legal Effect

These two notifications are issued pursuant to Section 16 of the Investment Promotion Act B.E. 2520 (1977), as amended, and shall be applied in conjunction with the Investment Promotion Act B.E. 2520 (1977) and BOI Notification No. 9/2565. In the event of any inconsistency or conflict between the conditions or criteria, the provisions of these two notifications shall prevail and be applied on a case-by-case basis to the relevant promoted businesses, taking into account the prevailing economic circumstances at the relevant time.

Furthermore, additional or amending notifications concerning investment-promoted activities may be issued in the future to reflect Thailand’s evolving economic conditions. Investors are therefore advised to closely monitor regulatory developments in order to formulate, review, and adjust their investment strategies in a timely and appropriate manner.

Conclusion

These two BOI notifications constitute a significant component of Thailand’s current legal and policy framework governing investment promotion. They clearly reflect the government’s policy orientation toward enhancing national competitiveness, promoting targeted high-value industries, supporting regional economic development, and refining the investment promotion regime to ensure its alignment with rapidly evolving economic and technological landscapes.

Related Article: Thailand BOI Launches New SME Efficiency Enhancement Measures (Notification No. 5/2568) – The Legal Co., Ltd.

Author: Panisa Suwanmatajarn, Managing Partner.

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Thailand BOI Launches New SME Efficiency Enhancement Measures (Notification No. 5/2568)

The Thailand Board of Investment (“BOI”) has issued BOI Notification No. 5/2568 Re: Measures to Enhance the Efficiency of Small and Medium-Sized Enterprises (“SMEs”), introducing a comprehensive incentive framework aimed at strengthening the competitiveness of SMEs. The measures are designed to encourage SMEs to modernize their operations through technological upgrades, enhanced operational efficiency, digital transformation, improved energy efficiency, and diversification into new industries.

This notification took effect on 5 June 2025 and applies to all investment promotion applications submitted on or after that date.

Purpose of the Measure

This measure aims to strengthen the resilience and long-term competitiveness of SMEs by promoting investments that enhance operational efficiency, elevate business practices to internationally recognized sustainability standards, and facilitate the transition into emerging industries. These initiatives are intended to enable SMEs to better align with global production requirements and environmental expectations.

Eligibility Requirements

To be eligible for the incentives under this measure, an applicant must satisfy all of the following conditions:

  • The company must have at least 51% Thai shareholding, and more than half of its authorized directors must be Thai nationals.
  • The company’s total revenue, calculated on a consolidated basis and inclusive of both BOI-promoted and non-promoted activities, must not exceed THB 500 million in aggregate over the preceding three fiscal years.
  • The company must be registered under the SME ONE ID system prior to the submission of the investment promotion application.

Conditions

The BOI permits existing SME projects to apply for incentives under this measure, subject to the following conditions:

  • This measure applies to existing SME projects, irrespective of whether they currently receive BOI investment promotion, provided that the project falls within an activity category eligible for promotion at the time of application. Projects classified under the BOI’s excluded activities or policies shall not be eligible.
  • Projects that have previously been granted BOI promotion may reapply under this measure upon the expiry of their existing corporate income tax (CIT) exemption or reduction period, or in cases where no CIT exemption was granted at the time of the original promotion.

Required Efficiency Improvement or Transition Activities

To be eligible under this measure, applicants must implement one or more of the following efficiency enhancement or business transition activities, subject to approval by the BOI:

  • Upgrading or replacing machinery and automation systems to enhance operational efficiency;
  • Adoption of digital technologies, including system integration software, artificial intelligence (AI), machine learning (ML), big data analytics, and electronic payment systems;
  • Upgrading production processes or operational systems to align with Industry 4.0 standards;
  • Improving energy efficiency or adopting renewable energy solutions within business operations;
  • Obtaining internationally recognized sustainability or quality certifications (e.g., GAP, FSC, PEFC, ISO 22000, ISO 14064); and
  • Transitioning business operations into new industries or activity categories eligible for BOI investment promotion.

1. Submission and Approval of the Investment Plan

  • Applicants are required to submit a comprehensive investment plan detailing the proposed improvement measures or transition activities.
  • Investment plans involving Industry 4.0 upgrades must be reviewed and approved by the National Science and Technology Development Agency (NSTDA).

2. Minimum Investment Requirement

  • The investment in efficiency improvement must be no less than THB 500,000, excluding the cost of land and working capital.

Rights and Benefits

Eligible SME projects are entitled to the following incentives:

  • Import duty exemption on machinery
  • Corporate income tax (CIT) exemption for up to five (5) years, equivalent to 100% of the qualifying investment amount (excluding land and working capital)
  • The CIT exemption period commences once the project generates revenue and must be utilized within three (3) years from the date of the promotion certificate.

Conclusion

BOI Notification No. 5/2568 represents a significant policy initiative to strengthen Thailand’s SME sector. By promoting modernization, digital transformation, energy efficiency, and sustainability, the measure supports SMEs in enhancing productivity and aligning with international standards.

Overall, the scheme is expected to accelerate the long-term competitiveness and resilience of SMEs while contributing to Thailand’s broader industrial transformation.

Author: Panisa Suwanmatajarn, Managing Partner.

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BOI Unveils Draft National Semiconductor Roadmap Aiming to Attract Over 2.5 Trillion Baht in Investments

The Board of Investment (BOI) has presented the draft National Strategy for the Development of the Semiconductor and Advanced Electronics Industry to the National Semiconductor and Advanced Electronics Policy Committee. This comprehensive roadmap, prepared since April 2025 with the assistance of a leading global consulting firm, outlines a long-term vision to position Thailand as a leading hub for semiconductor production in the region.

The strategy builds upon Thailand’s existing strengths in downstream activities, such as outsourced semiconductor assembly and testing (OSAT) and integrated circuit design, while advancing capabilities across the full value chain—from upstream wafer fabrication to high-value design and production. The ultimate objective is to achieve “Made-in-Thailand Chips” by 2050, fostering a complete and integrated semiconductor ecosystem.

Strategic Focus and Targets:

The roadmap targets investments exceeding 2.5 trillion baht over the 25-year period from 2026 to 2050. It also aims to develop more than 230,000 highly skilled personnel to support industry growth.

Emphasis is placed on five product categories where Thailand demonstrates strong potential and alignment with domestic industries:

•  Power chips

•  Sensor chips

•  Photonics chips

•  Analog chips

•  Discrete chips

These segments are closely linked to key sectors including automotive, electronics, telecommunications, data centers, artificial intelligence, automation, and medical applications.

Phased Development Approach:

In the initial five-year phase (2026–2030), efforts will concentrate on leveraging current advantages in OSAT, IC design, and advanced electronics, while initiating investments in wafer fabrication and nurturing domestic enterprises to emerge as leading players. Subsequent phases will progressively expand the value chain toward full self-reliance in high-value production.

Five Key Driving Mechanisms:

To realize these ambitions, the strategy proposes action across five critical areas:

1.  Investment Incentives — Provision of financial support, including grants and long-term low-interest loans, to attract priority projects.

2.  Human Capital Development — Establishment of specialized curricula, industry-academia collaborations (both domestic and international), and vocational training programs to build expertise in semiconductor engineering and advanced research.

3.  Technology Advancement — Upgrading national research centers and fostering partnerships among government, private sector, and academic institutions for research and development.

4.  Infrastructure Enhancement — Development of dedicated clusters, reliable utilities (including clean energy), water systems, and robust disaster management capabilities.

5.  Business Environment Improvement — Streamlining approvals and permits, negotiating international trade agreements, and implementing government procurement mechanisms to support local enterprises.

Competitive Positioning and Supporting Context:

Although, Thailand’s semiconductor industry remains in its early stages compared to regional leaders such as Singapore and Malaysia, or competitors including Vietnam and the Philippines, the country possesses competitive advantages in infrastructure, workforce quality, business environment, and downstream industries.

From 2018 to November 2025, the electrical and electronics sector attracted 1,748 investment promotion applications totaling 1.17 trillion baht, representing 19% of all promoted investments and underscoring its status as the leading sector. The global semiconductor market is projected to reach 1 trillion U.S. dollars by 2030, presenting significant opportunities for strategic growth.

Key Takeaways:

•  Thailand’s national semiconductor roadmap targets over 2.5 trillion baht in investments and the development of more than 230,000 skilled professionals by 2050.

•  Focus is directed toward five high-potential chip categories that align with the country’s established industrial strengths.

•  A five-pillar approach addresses incentives, talent, technology, infrastructure, and business facilitation to build a complete ecosystem.

•  The strategy emphasizes transitioning from assembly-focused activities to high-value design and fabrication, aiming for “Made-in-Thailand Chips” and regional leadership in the sector.

•  This initiative positions the semiconductor industry as a key driver of long-term economic competitiveness amid rapid global technological and supply chain evolution.

Author: Panisa Suwanmatajarn, Managing Partner.

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Penal Code Amendment (No. 30): Criminalizing Sexual Harassment and Implications for Workplace Policies

On December 30, 2025, the Royal Gazette published the Penal Code Amendment Act (No. 30), B.E. 2568 (2025), marking a significant advancement in Thailand’s legal framework for addressing sexual offenses. This amendment introduces “sexual harassment”  as a distinct criminal offense, refines existing provisions to reflect contemporary societal dynamics, and emphasizes protection for individuals across all genders, ages, and identities. By elevating such acts from minor infractions to criminal liability, the law seeks to deter perpetrators, enhance victim support, and foster a safer society. The changes address limitations in prior legislation, which often treated harassment merely as a petty offense causing annoyance, insufficient for the severity and diversity of modern incidents.

Key Changes Introduced by the Amendment:

The amendment encompasses several pivotal modifications to the Thai Penal Code:

1.  Expanded Definition of “Rape”: The definition is broadened to include emerging forms of sexual violation, ensuring inclusivity for diverse gender identities and modern contexts.

2.  Abolition of the Offense of “Indecent Act by Intrusion”: This provision is repealed to modernize and streamline the legal structure.

3.  Establishment of Sexual Harassment as a Criminal Offense: A new, dedicated section defines sexual harassment broadly as any act—physical, verbal, auditory, gestural, communicative, involving stalking, or conducted via computer systems—with sexual connotations that causes another person distress, annoyance, embarrassment, or a sense of insecurity. This encompasses:

       •  Physical actions or contact.

       •  Verbal remarks, sounds, or displays.

       •  Persistent communication, following, or monitoring.

       •  Digital interactions, such as through emails, social media, or online platforms.

These updates recognize the evolving nature of sexual offenses, including those affecting individuals of all ages, genders, and sexual orientations, and account for the psychological and physical harm inflicted.

Penalties Under the New Provisions:

Penalties are structured progressively to reflect the offense’s severity, context, and impact:

•  General Cases: Imprisonment not exceeding 1 year, a fine not exceeding 20,000 baht, or both.

•  Repeated or Continuous Acts (disrupting the victim’s normal life): Imprisonment not exceeding 2 years, a fine not exceeding 40,000 baht, or both.

•  Acts in Public Places or Via Computer Systems: Imprisonment not exceeding 3 years, a fine not exceeding 60,000 baht, or both.

•  Acts Against Children (under 15 years): Imprisonment not exceeding 5 years, a fine not exceeding 100,000 baht, or both.

•  Acts by Persons in Authority (e.g., supervisors, employers, or those with power over the victim): Imprisonment not exceeding 3 years, a fine not exceeding 60,000 baht, or both.

This graduated approach underscores heightened accountability in cases involving vulnerability, repetition, public exposure, digital means, or power imbalances, particularly relevant in professional settings.

Broader Implications for Society and Business Operations:

The amendment responds to the increasing prevalence and complexity of sexual offenses in Thai society, where traditional laws proved inadequate. By criminalizing a wider array of behaviors, it aims to improve enforcement, provide stronger deterrence, and offer more effective remedies for victims. For businesses, the law has profound implications, especially given the elevated penalties for acts committed by authority figures. Organizations must adapt to avoid criminal liability for individuals, potential vicarious responsibility, reputational harm, or related civil claims.

Businesses, particularly those with employee hierarchies, customer interactions, or digital operations, should undertake the following preparations:

•  Policy Revision and Development: Update or create comprehensive anti-harassment policies that explicitly incorporate the new legal definition, including workplace-specific examples such as inappropriate comments during meetings, unwanted advances by supervisors, or harassing digital messages.

•  Training Initiatives: Implement mandatory, regular training programs for all employees, with specialized sessions for managers highlighting their increased responsibilities and risks under the law.

•  Robust Reporting and Investigation Frameworks: Establish multiple confidential reporting channels (e.g., HR contacts, anonymous hotlines) and impartial investigation procedures with clear timelines, ensuring protection against retaliation.

•  Risk Mitigation Strategies: Conduct assessments in high-exposure areas, such as supervisory roles or public-facing positions, and integrate policy references into employment contracts and handbooks.

•  Victim Support Measures: Provide resources like counseling, accommodations, and legal referrals to support affected individuals.

•  Ongoing Monitoring: Perform annual reviews of policies and maintain detailed records of compliance efforts as evidence of due diligence.

Consultation with legal and human resources experts is recommended to ensure alignment with complementary laws, such as the Labour Protection Act and the Gender Equality Act.

Developing Effective Workplace Harassment Policies:

In light of the amendment, workplace policies must be thorough and proactive. Essential components include:

1.  Precise Definitions and Illustrations: Mirror the statutory definition while providing contextual examples relevant to the organization’s environment.

2.  Comprehensive Scope: Extend coverage to employees, contractors, clients, and visitors, including remote work and work-related events.

3.  Accessible Reporting Mechanisms: Offer diverse, secure options with prompt acknowledgment and anti-retaliation safeguards.

4.  Fair Investigation Processes: Detail impartial, timely procedures involving trained personnel and thorough documentation.

5.  Disciplinary Measures: Outline consequences proportionate to the offense, up to termination, while addressing power dynamics.

6.  Preventive Education: Require ongoing training to promote awareness and cultural change.

7.  Support Services: Ensure access to assistance for complainants and respondents.

8.  Regular Evaluation: Commit to periodic audits and updates in response to legal or societal developments.

Leadership endorsement and cultural commitment are crucial for effective implementation.

Key Takeaways:

•  The 2025 amendment represents a landmark progression in Thailand’s approach to sexual offenses, criminalizing harassment in its various forms and imposing substantial penalties, effective from December 30, 2025.

•  It particularly heightens risks for those in positions of authority, necessitating urgent workplace adaptations.

•  Organizations that prioritize robust policies, training, and procedures will not only achieve compliance but also cultivate safer, more inclusive environments.

•  This reform aligns with global standards for victim protection and societal safety, encouraging proactive measures across all sectors.

•  Employers are advised to stay informed through official sources, such as the Royal Gazette and relevant ministries, for any additional guidance or interpretations. Prompt action will mitigate risks and contribute to a more equitable professional landscape in Thailand.

Author: Panisa Suwanmatajarn, Managing Partner.

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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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Reforming Thailand’s License Renewal System: Fee-Based Extensions and Broader License Coverage

Maintaining valid licenses is essential for uninterrupted business operations. However, the longstanding requirement to submit renewal applications each cycle has created procedural delays and unnecessary administrative burdens. To modernize and streamline the system, Thailand introduced the Royal Decree Requiring Licensees to Pay Renewal Fees Instead of Submitting Applications for License Renewal B.E. 2564 (2021) (the “Decree”), issued under the Licensing Facilitation Act B.E. 2558 (2015).

The Decree allows designated licenses to be renewed automatically upon payment of the prescribed fee—eliminating the need for repeated applications and marking a significant step toward reducing compliance complexity and improving regulatory efficiency.

Current Scope of the Decree

Under the existing framework, 11 categories of licenses qualify for renewal by fee payment, including:

  • Cosmetic notifications for the sale, import for sale, and manufacture of cosmetic products
  • Licenses for the operation of health establishments
  • Licenses for product standards inspection services

Expansion of Licensing Oversight

To further broaden the scope of eligible licenses and strengthen regulatory governance, on 25 September 2025, the Thai Cabinet approved the Draft Royal Decree Requiring Licensees to Pay Renewal Fees Instead of Submitting Applications for License Renewal (No. ..) B.E. .… (“Draft Royal Decree”).

The Draft Royal Decree expands the list of licenses subject to automatic renewal and authorizes regulatory officials to conduct operational inspections. These inspections are limited to monitoring purposes and do not impose additional substantive conditions on license renewal, which continues to be completed through fee payment alone.

Expanded License Categories

The Draft Royal Decree adds 23 additional license categories, significantly broadening regulatory coverage across various industries. Notable examples include:

  • Petty patent licenses – Licenses related to the registration and protection of inventions
  • Trademark registration – Licenses for registering trademarks and managing associated rights
  • Food production licenses – Licenses for manufacturing food products within the country
  • Food import licenses – Licenses for importing or bringing food products into Thailand

Multiple Fee Payment Channels

Regulatory authorities must provide accessible payment methods to facilitate compliance, including:

  • Service counters
  • Banks
  • Electronic payment platforms

These channels support faster renewals and promote broader adoption of the streamlined mechanism.

Expected Benefits

The Draft Royal Decree is expected to:

  • Expand the categories of licenses eligible for simplified renewal
  • Reduce administrative burdens and processing times
  • Ensure uninterrupted business operations
  • Improve efficiency in government revenue collection
  • Promote domestic and foreign investment by supporting continuous business activity
  • Enhance certainty and predictability for license-dependent businesses

Conclusion

The Draft Royal Decree represents a significant evolution in Thailand’s licensing framework. By expanding the range of license types and strengthening regulatory oversight while preserving a simplified renewal mechanism, the measure strikes an effective balance between rigorous governance and practical convenience. This reform ultimately contributes to a more transparent, predictable, and business-friendly regulatory environment.

Author: Panisa Suwanmatajarn, Managing Partner.

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