Financial Crime World

Title: Thai Anti-Ponzi Law: A Stern Warning to Swindlers in the Land of Smiles

Background

  • Long-standing problem with Ponzi schemes in Thailand
  • Schemes target real estate and currency/stock investments
  • “Guaranteed” returns disproportionately higher than traditional financial institutions
  • Government response: the Anti-Ponzi Law (1991)

Ponzi Schemes and the Anti-Ponzi Law

  • Law targets schemes that publicly advertise guaranteed investments with returns over the regulatory maximum interest rate (3%)
  • Prosecution must prove diversion of payments to compensate earlier investors
  • At least 10 investors required to bring charges

Penalties

  • Fraud charges for each victim
  • Five to ten-year prison sentence
  • THB 500,000 to THB 1 million statutory fine
  • Additional fine of THB 10,000 per day, per defrauded investor

Transparency and Relevant Information

  • Intentionally refusing to disclose business information deemed a criminal offense

Strict Liability Offenses

  • Two additional offenses
    • Foreign exchange fraud targeting the public
    • Businesses exceeding THB 5 million in investments with returns over the regulatory maximum interest rate

Defenses Against Strict Liability Provisions

  • Unforeseeable economic downturns or other unforeseen circumstances, such as the Covid-19 pandemic, can provide a defense

Remaining Vigilant

  • Ponzi schemes can disguise themselves as secure investments or enticing business propositions
  • Anti-Ponzi Law serves as starting point in pursuit of restitution

Thai Proverb

  • “If it seems too good to be true, it probably is.”