THAILAND LAW AND PRACTICE Contributed by: Wongsakrit Khajangson, Panupan Udomsuvannakul, Koraphot Jirachocksubsin and Pitchaya Roongroajsataporn, Chandler Mori Hamad a
due diligence, and report any suspicious transactions to the relevant authority. As most fintech companies carry out their businesses as Specified Operators, they must comply with the obligations specified under the law, as follows: • reporting transactions to the AMLO involving the use of cash or assets in an amount exceeding that prescribed in sub-regulations or any suspicious transactions; • identifying customers prior to making any transac - tions; • determining policies for customers, preventing money laundering, determining risk management policies and conducting due diligence on custom - ers when making the first transaction; and • recording all facts relating to any transaction that has been made. The obligations under the AML Act result in more procedures and steps for effectuating each transac - tion, and fintech companies may have to establish a compliance department to comply with anti-money laundering obligations. Also, fintech companies may have to prepare systems for storing information on transactions and customer data and ensure the secu - rity of such systems. The BOT’s Guidelines for Digi - tal Fraud Management took effect on 17 December 2025, imposing end-to-end fraud controls on banks and payment service providers under the Payment Systems Act. 2.15 Financial Action Task Force (FATF) Standards Thailand’s anti-money laundering and sanctions regu - lations generally conform to the standards established by the Financial Action Task Force. 2.16 Reverse Solicitation No authority in Thailand has officially endorsed reverse solicitation; however, it is a practice frequently adopted by foreign business operators. In this regard, it is recommended that service providers exercise heightened caution when offering services to Thai individuals by relying on this concept. Ensuring inde - pendent initiation by the client and maintaining clear
documentation is crucial to avoid regulatory scrutiny and potential legal consequences.
3. Robo-Advisers 3.1 Requirement for Different Business Models Thailand has not adopted regulations specifying which business operators or activities require the use of robo-advisers, although some Thai fintech opera - tors do utilise robo-adviser technology. Wealth advisers are encouraged to use fintech to generate financial solutions and to serve as an aid to financial planning under the SEC’s framework. According to SEC Notification No SorThor 31/2561 Re: Rules in Details on Wealth Advisory Service Busi - ness, wealth advisers must complete the process of client contact and services in five steps, as follows: • exploring and understanding clients; • constructing an investment portfolio; • implementing the portfolio according to the asset allocation plan; • monitoring and rebalancing the portfolio; and • providing consolidated reports for clients’ review. Wealth advisers must also have an electronic sys - tem supporting the actions under the third and fourth points above. 3.2 Legacy Players’ Implementation of Solutions Introduced by Robo-Advisers Legacy players must adhere to regulations relevant to their traditional business activities, including imple - menting robo-advisory services, and they have quick - ly adapted to and incorporated these robo-advisers into their operations over the last few years. Private sector banks use robo-adviser-based solu - tions to develop tools for customer satisfaction, new products and services, and improvements. The most widespread use of robo-advisers occurs in wealth management and developing custom-made trading and wealth solutions.
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