Search for:

In brief

In our previous article (link), we pointed out that, in addition to businesses in the financial sector, certain other businesses also have obligations under the Money Laundering Control Act, B.E. 2542 (1999) (“Act“).
In this article, we will highlight the first key legal obligation of these businesses, which is transaction reporting.


  1. We Can Help

Non-financial businesses that fall within the scope of the Act also have an obligation to report to the Anti-Money Laundering Office (AMLO) cash transactions that meet certain thresholds, varying according to the types of business.
There is also a more general requirement to report any transaction that could reasonably be regarded as suspicious, regardless of the method of payment. A suspicious transaction is one that could reasonably believe to have been made to avoid the applicability of the Act; is connected, or possibly connected, to the commission of a predicate offense under the Act (e.g., offense relating to public fraud under the Penal Code or smuggling under the custom law); or is to support terrorism. This is irrespective of whether the transaction is made one or more times, and includes attempts to make the transaction.
Businesses therefore need to educate their staff and establish processes for identifying suspicious transactions, and become familiar with the typical characteristics of these transactions, in order to comply with the transaction reporting obligations.
In our next article, we will discuss know-your-customer (KYC) and customer due diligence (CDD) procedures.

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