Search for:

In brief

In our previous newsletters, we explored the first two key legal obligations of non-financial businesses under the Money Laundering Control Act, B.E. 2542 (1999) (the “Act“): reporting obligations and know-your-customer (KYC) and customer due diligence (CDD) procedures.

In this article we will discuss the third and fourth key legal obligations: implementing internal policies and procedures to address the risk of money laundering, and coordinating with the Anti-Money Laundering Office (AMLO) to provide training for personnel.

Internal policies and procedures

The Act requires that businesses in question must develop and implement a set of internal policies and procedures to assess, manage, and mitigate the risk of money laundering. These must be in writing, be approved by the board of directors or high-level management, and their importance must be communicated to all relevant staff.

The internal policies and procedures must establish a framework regarding such things as the products and services offered, the location of the business, sales channels, and customers and suppliers. They must also set out clear procedures to manage and mitigate the risk of money laundering activities in these areas, and to comply with the reporting, KYC, and CDD obligations discussed in earlier bulletins. Mitigation measures might involve policies and procedures regarding customer acceptance, employee screening and training, internal audit activities, or the appointment of specific personnel to take responsibility for anti-money laundering efforts.

AMLO approved training arrangements

The Act requires that non-financial business operators falling under the scope of the Act must coordinate with the AMLO to prepare training for employees whose responsibilities relate to anti-money laundering efforts. This may involve individuals at all levels of an organization, from management responsible for setting and overseeing the anti-money laundering policy, to front-line staff interacting with customers and processing transactions on a daily basis. Businesses that fail to implement the approved training may be subject to substantial penalties. We will be very pleased to provide you with further information or advice on anti-money laundering matters.

We Can Help

Baker McKenzie has the experience and international coverage to help you devise and implement a compliance program or fill in the gaps of your existing program. Our compliance team is prepared to work with all the critical participants in your corporate compliance effort. We take pride in our ability to work together with clients to anticipate, manage and resolve issues, to provide practical advice and to serve as the “trusted advisor” to management and boards of directors of a wide variety of corporate clients. We work with clients to help ensure their brand, reputation and enterprise are protected and positioned to create additional value.

With a renowned global network and professionals on the ground in 17 cities in Asia Pacific alone, we can handle all your compliance needs, regardless of whether they require a local, regional or global perspective.


Yuthana Sivaraks joined Baker & McKenzie in 1995 and became a partner in 2004. Prior to working with the Firm, he served as a judge advocate in the Royal Thai Navy. He is currently a member of various practice groups in the Bangkok office, including those for IT/Communications, Intellectual Property and Corporate & Commercial. In addition to practicing law, Mr. Sivaraks is an active visiting lecturer on IT, telecommunications, intellectual property and trade competition law for a number of Thai universities and institutions.


Praween Chantanakomes is an associate at Baker & McKenzie’s Bangkok office. He was admitted in 2008. He is currently active in the Corporate & Commercial, Mergers & Acquisitions, Environment, Natural Resources, and Pharmaceuticals practice groups.


Haruthai Chaisanee is an Associate in Baker McKenzie Bangkok office.


Mallika Tubtim is an Associate in Baker McKenzie Bangkok office.


Pongtorn Jittapinijmas is an Associate in Baker McKenzie Bangkok office.

Write A Comment