Evolving Compliance Procedures in Thai Banking Sector

Bangkok, July 5, 2024

The Thai banking sector continues to face evolving regulatory requirements aimed at enhancing compliance and mitigating financial risks. Recent developments include updates to anti-money laundering rules and the introduction of a new law on credit institutions.

Anti-Money Laundering Rules Updated

In April 2024, the Anti-Money Laundering Office (AMLO) issued an amended notification concerning the rules for designating or reviewing the list of high-risk customers who require close monitoring under the Ministerial Regulation on Customer Due Diligence B.E. 2563 (2020).

High-Risk Customers Classification

The updated notification includes provisions for listing high-risk customers under two specific codes:

• HR-03-1: applies to individuals who are the subject of either a petition or a complaint related to a predicate offense accepted by the relevant inquiry officer and recorded as a criminal case. It also covers individuals whose bank accounts are suspected of being used to conduct transactions related to crimes under the Emergency Decree on Measures for the Prevention and Suppression of Technological Crimes B.E. 2566 (2023), with victims seeking prosecution.
• HR-03-2: is for individuals involved in the commission of a predicate offense or those whose bank accounts are suspected of being used in such offenses, but whose cases have not been accepted or numbered by the relevant inquiry officer.

Guidelines on Customer Due Diligence

The updated notification requires all financial institutions in Thailand to take steps to manage money laundering risks and comply with the AMLO’s mandatory Guidelines on Customer Due Diligence. Account holders suspected of engaging in or facilitating technological crimes, as recorded by the Anti Online Scam Operation Center (AOC), are to be classified as “high-risk persons.”

New Law on Credit Institutions in Vietnam

Meanwhile, Vietnam’s new Law on Credit Institutions will take effect on July 1, 2024, replacing the current Law on Credit Institutions issued in 2010. The new law aims to strengthen banking operations and enhance transparency in this sector.

Comprehensive Overview of Regulations

Fintech operators and service providers in Southeast Asia can access a comprehensive overview of relevant regulations across all full-service jurisdictions - Cambodia, Laos, Myanmar, Thailand, and Vietnam - through Tilleke & Gibbins’ Fintech Law in Southeast Asia.