Roles of the Bank of Thailand and the Financial Sector under the Framework

The Collaboration

Illicit activities within the financial sector are increasingly complex and can undermine public confidence in the financial system. Addressing these challenges requires coordinated efforts among multiple stakeholders, with each organization playing a distinct role under the Framework, as outlined below.

The Bank of Thailand's Commitments under the Framework

  • The Bank of Thailand (BOT) will enhance regulations and minimum standards, as well as relevant supervisory oversight, to foster consistent execution standards across the system, ensuring that business competition among participating entities does not lead to a race to the bottom in risk management standards, as follows:

(1) Prevent deposit accounts and e-Money from being used as channels for moving illicit funds, by strengthening Know Your Customer (KYC), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) standards and end-to-end mule account controls to ensure that accounts are used only by their legitimate holders. These controls will be reinforced through additional minimum guidelines on mule account management, together with ongoing quality assessments of regulatory compliance.

(2) Prevent merchant payment acceptance services from being used as a channel to collect funds on behalf of merchants engaged in unlawful activities, by strengthening KYM (Know Your Merchant) standards and oversight of high-risk merchants so that such merchants are denied access to payment acceptance and digital fund-receiving channels. This oversight will be supported by dedicated Merchant Fraud Management regulations, together with ongoing monitoring of service providers to ensure compliance with the prescribed standards.
(3) Prevent the financial sector from being used to convert the proceeds of illicit activity into assets that are difficult to trace, such as cash, gold, and digital assets, including conversion of such assets into Thai financial system to disguise their origin. Additional measures will include regulations covering cash deposits and banknote exchanges of THB 5 million or more, together with restrictions on cash-settled gold transactions exceeding THB 10 million. 
(4) Strengthen the standards and quality of non-bank operators including lending, payment, and money exchange businesses, in a manner commensurate with their respective risk levels, with emphasis on selecting qualified operators and maintaining continuous supervision. This will be complemented by enhanced oversight of financial products and services, in line with evolving risk profiles and market developments, such as Buy Now Pay Later (BNPL).
(5) Protect service users from becoming victims of, or being unwittingly used to facilitate, illicit activities by strengthening security standards across digital financial service channels, including internet banking and mobile banking, to prevent impersonation and account takeover. These standards will be extended to non-bank operators, alongside measures to prevent the unauthorized use of consumers' payment card information (card fraud).
 

  • The BOT will analyze linkages and share insights, risk patterns, and best practices to support monitoring, screening, the detection of suspicious transactions, and further risk-based investigations. Such information may include unusual transaction patterns and financial behaviors that could indicate financial sector misuse, as well as lists of individuals, juristic persons, and merchants identified as high risk.
  • The BOT will coordinate with relevant regulatory authorities, law enforcement agencies, and other government bodies, as well as foreign central banks and international organizations, to strengthen the prevention, detection, and disruption of financial sector misuse. This will be supported through enhanced information sharing and data utilization, including corporate registration, shareholder, and director information from the Department of Business Development (DBD), as well as information from the Royal Thai Police on individuals, juristic persons, and networks linked to illicit activities. The BOT will also promote data sharing and collaborative analytics with the Anti-Money Laundering Office (AMLO) and the Securities and Exchange Commission (SEC). In addition, the BOT will strengthen cross-border cooperation through the exchange of information, intelligence, and typologies with foreign regulatory authorities and international organizations to address increasingly sophisticated cross-border risks.

Thai Bankers' Association’s Commitments under the Framework

  • The Thai Bankers' Association (TBA) will strengthen customer identity verification, including KYC/CDD/EDD practices, in accordance with anti-money laundering and other relevant legal requirements, by promoting greater connectivity with and utilization of government data sources.
  • The TBA will establish industry-wide standards for preventing and managing high-risk accounts, leveraging agreed behavioral data and shared intelligence to design measures commensurate with risk level thereby reducing the likelihood of bank accounts being used to facilitate illicit activities.
  • The TBA will strengthen the monitoring of high-value cash transactions by working with the BOT to establish common standards for assessing transaction purpose, size, patterns,  source of funds verification documents, and other information commensurate with risk level, with the objective of enhancing the detection of suspicious cash transactions and reducing the risk of cash being used in illicit activities.
  • The TBA will leverage data and technology to strengthen proactive monitoring and prevention of high-risk accounts and transactions. By integrating banks' internal data with trusted external sources and leveraging technology, using Profile, Behavior, and Inflow/Outflow principles, member banks will enhance their ability to identify links between accounts, transactions, and suspicious behaviors, improving the speed and accuracy of anomaly detection while helping prevent losses before they escalate.
  • The TBA will serve as a coordinating platform for collaboration and information sharing among banks, government agencies, and other private-sector stakeholders to enhance the monitoring, detection, and prevention of financial sector misuse.

Association of International Banks’ Commitments under the Framework

  • Strengthen industry collaboration via Association of International Banks (AIB) by convening regular forums (both peer bank sessions and multi stakeholder engagements) with relevant authorities (e.g. BOT Monthly Fraud Working Group) to address priority fraud/financial crime issues and emerging risk.
  • Enable structured knowledge exchange with authorities and the wider financial services industry, sharing international best practice, proven approaches, and success stories in fraud and financial crime management, including the effective use of tools and capabilities.
  • Leverage advanced technology (e.g. AI) or monitoring tools, where appropriate, to proactively protect customers by strengthening fraud and anti-money laundering monitoring, scam detection, and payment safeguards (e.g., anomaly detection, mule-account indicators, and real-time interdiction where feasible) to combat illicit financial activity and reduce online fraud losses across the financial sector.
  • Strengthen KYC/CDD/EDD standards and execution by promoting consistent, rigorous adherence to relevant regulatory requirements and internal policies, including ongoing monitoring and timely refreshing based on risk.
  • Support public-private partnership models (e.g., Fraud and Money Laundering Intelligence Taskforce) to accelerate joint intelligence-led disruption of fraud and money laundering, while recognizing that data-sharing constraints may require regulatory/legal enablement to broaden impact.
  • Each AIB member bank will implement the applicable actions in line with its own business model. All commitments and actions under this Framework and AIB Operational Guidelines are voluntary, non-legally binding, and intended to be applied proportionately, as appropriate.

Government Financial Institutions Association’s Commitments under the Framework

  • The Government Financial Institutions (GFIs) will leverage its community networks to strengthen financial and digital resilience among the public, particularly elderly people, farmers, and other vulnerable groups. Through continuous financial education and public awareness initiatives, GFA members will help protect individuals from fraud, exploitation, and being used to facilitate illicit activities. These efforts will include promoting key awareness messages such as the “3 Don’ts and 1 Beware” campaign[1] to encourage safer financial behavior.
  • The GFIs will strengthen KYC/CDD/EDD practices through collaboration with the TBA, government agencies, and other relevant stakeholders. This will include the exchange of knowledge, experience, and best practices through relevant working groups and committees e.g. the Compliance Subcommittee and the Fraud Management Subcommittee, as well as information sharing through established channels, to enhance the ability of participating institutions to identify and respond to unusual financial behaviors and emerging risks.

    [1] “3 Don’ts and 1 Beware” refers to a public awareness campaign that encourages individuals to (i) Don’t open bank accounts on behalf of others, (ii) Don’t transfer funds at the instruction of unknown persons or individuals recently contacted online, (iii) Don’t disclose personal information to others, and (iv) Beware of scams, fraud, and illicit schemes that exploit promises of easy financial gain.

Thai E-Payment Trade Association and Payment Service Providers under the Supervision of the Bank of Thailand’s Commitments under the Framework

  • Payment service providers (PSPs) will strengthen Know Your Merchant (KYM) for merchant payment acceptance services throughout service lifecycle to prevent onboarding, or continuing to serve, merchants that facilitate or support illicit activities. This will include enhanced merchant screening, behavioral monitoring, and ongoing oversight, covering both Master Merchants (payment facilitators or merchant aggregators that hold the primary merchant account) and Sub-Merchants (merchants that accept payments under a Master Merchant's account).
  • PSPs will strengthen KYC/CDD/EDD standards for e-Money accounts and electronic fund transfer services, to prevent these channels from being used to move illicit funds.
  • PSPs will provide regulators with information that supports linkage analysis for the detection and investigation of financial sector misuse, such as merchant data and unusual transaction or behavioral patterns.
  • TEPA will serve as a central hub for disseminating and exchanging knowledge among both member and non-member PSPs on a regular basis. The Association will also designate a primary liaison with the BOT on matters relating to the prevention of financial sector misuse and establish an operational-level Fraud and Risk Working Group to promote consistent industry practices and ensure that PSPs remain responsive to evolving fraud typologies and emerging threats.

The Thai Association of Foreign Exchange and Financial Services’ Commitments under the Framework 

  • The Thai Association of Foreign Exchange and Financial Services (TAFEXS) will develop a Database for Risk and PEP Screening that incorporates data from the Central Fraud Registry (CFR), consolidating information on high-risk individuals and suspects in online fraud cases. Members will be given access to the platform at a cost commensurate with their business size, supporting stronger risk-based customer screening and due diligence (KYC/CDD/EDD).
  • TAFEXS will develop an AML/CFT Industry Guideline setting common standards for customer screening, the refusal to process suspicious transactions, and the reporting of suspicious transactions, to ensure a consistent, unified approach to financial crime prevention.
  • TAFEXS will support and advance AML/CFT risk management practices through the following initiatives:
    (1) Conducting regular training, knowledge transfer, and exchange of AML/CFT best practices;
    (2) Developing a Business Risk Assessment tool to help operators review and strengthen their internal controls in line with evolving risks; and
    (3) Providing an advisory channel to help operators comply effectively with applicable laws and regulatory requirements.

Non-bank lenders’s Commitments under the Framework

  • Non-bank lenders will strengthen the detection and review of high-risk transactions through enhanced assessment of customer profiles, relevant parties, and sources of funds, to prevent credit facilities or assets under hire-purchase and leasing arrangements from being used to facilitate illicit activities.
  • Non-bank lenders will work with the BOT, within the boundaries of applicable laws, to enhance the sharing of unusual transactions and financial behavior patterns that may indicate financial sector misuse with regulators and relevant stakeholders, thereby supporting more timely and effective monitoring and detection of shared risks.
  • Non-bank lenders will promote regular training and knowledge-sharing initiatives among relevant industry associations to enhance personnel capabilities in customer due diligence, risk monitoring, and the detection of behaviors that may be linked to illicit activities.

Note: For the purposes of this Framework, the term “non-bank lenders” comprises: (1) Credit Card Club-The Thai Bankers’ Association (2) Personal Loan Club (3) Vehicle Title Loan Trade Association (4) Thai Hire-Purchase Association (THPA) (5) Thailand Leasing Association and (6) Thai Motorcycle Hire-Purchase Association (TMEA).