Background
The Anti-Money Laundering Office (AMLO) has issued updated reporting guidelines that expand the obligations of Thai companies, particularly those with foreign ownership or complex corporate structures. The changes reflect Thailand's continued alignment with Financial Action Task Force (FATF) recommendations.
Who is affected
The updated guidelines apply to:
- Company directors and authorized signatories of Thai limited companies.
- Beneficial owners holding 25% or more of a company's shares, directly or indirectly.
- Foreign-controlled entities operating in Thailand through nominees or holding structures.
Key obligations
Affected parties must now:
- Maintain accurate beneficial ownership records and update them within 30 days of any change.
- File threshold transaction reports for cash transactions exceeding the prescribed amount.
- Cooperate with due diligence requests from AMLO, including the provision of source-of-funds documentation.
Practical steps
Company directors should review their corporate records, confirm that beneficial ownership information is current, and ensure that any foreign shareholder structures are properly documented. Failure to meet reporting obligations can result in administrative penalties and, in serious cases, criminal exposure for directors.
How we can help
Our corporate team assists with beneficial ownership reviews, AMLO compliance checks, and the structuring of foreign-controlled entities under the Foreign Business Act. We also advise on lawful alternatives to nominee arrangements, which remain a focus of regulatory enforcement.