Tackling Nominee Businesses and Ensuring Compliance in Thailand


Following an extensive investigation by the Department of Business Development (DBD) into businesses using Thai nominee structures in key sectors such as tourism, real estate, hospitality, and logistics, the DBD plans to inspect an additional 26,830 businesses in 2025. This expanded scrutiny will now include e-commerce and warehousing sectors.
To identify nominee structures where foreign nationals use Thai nominees to circumvent the ownership restrictions under Thai laws, particularly the Foreign Business Act and the Land Code, the DBD is developing an Intelligence Business Analytic System (IBAS). This system will analyze the names of individuals flagged by other organizations or those with investments in multiple businesses, comparing their investments with their financial capabilities.
The DBD is collaborating with the Royal Thai Police to tackle nominee businesses and mule accounts often used for illegal activities. The key actions include data sharing, joint inspections, and utilizing the IBAS to identify and analyze high-risk entities.
A Sub-Committee for the Prevention and Suppression of Nominee Businesses has been established, comprising of representatives from various government agencies, such as the DBD, Immigration Office, Employment Department, Land Department, Revenue Department, and Anti-Money Laundering Office. This committee will focus on achieving concrete results in three phases:
  1. Short-term (within 3 months): Sharing information, conducting joint fieldwork, and holding press conferences to alert the public about nominee-related crimes.
  2. Medium-term (within 12 months): Developing an electronic system to link data across agencies, facilitating faster work by officials and enforcing strict legal action against offenders.
  3. Long-term (over 1 year): Updating and clarifying laws concerning violations related to foreign business operations under Anti-Money Laundering Office (AMLO) regulations.
These plans aim to effectively address nominee structures, ensuring public and investor confidence by safeguarding legitimate business practices and preventing fraud. A complaint center for nominee-related issues will be established for better resolution. The Ministry of Commerce will continue to monitor and collaborate with relevant agencies to ensure the success of these initiatives.
Businesses are encouraged to perform due diligence and ensure compliance with Thailand’s laws. Companies that fail to comply risk legal penalties and reputational damage, which can affect their long-term operations in Thailand, including potential block listing.