On May 17, 2024, Thailand’s 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). This notification, which took effect the following day, updates the previous version of the notification from 2022 to cover cybercrimes listed under the Emergency Decree on Measures for the Prevention and Suppression of Technological Crimes B.E. 2566 (2023). The amended notification sets out the steps that all financial institutions in Thailand must take to manage money laundering risks and to comply with the AMLO’s mandatory Guidelines on Customer Due Diligence.
Under the new notification, 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.” The notification includes provisions for listing high-risk customers under two specific codes:
- HR-03-1: This code 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. The names of individuals in this category are received from responsible agencies according to the Criminal Procedure Code or the AOC and are documented in a publicly accessible online notification system.
- HR-03-2: This code 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. Names under this category are provided by agencies such as the Royal Thai Police, the Financial Investigation Division, the Cooperation and Standard Development Division, banks, or other sources in Thailand.
These updated rules aim to ensure that relevant individuals and their transactions are closely supervised, thus enhancing the efficiency of monitoring high-risk customers and preventing technological crimes.
For further information, please contact:
Chitchai Punsan, Tilleke & Gibbins
chitchai.p@tilleke.com
