In August 2026, the Bank of Thailand (BOT) released a draft Notification amending the rules on customer identification and customer due diligence (CDD) for cash-related transactions.
The draft notification is undergoing public consultation until 3 September 2026. If adopted as proposed, the main provisions will go into effect on 15 October 2026, with Enhanced Due Diligence (EDD) requirements for certain categories of legal entities to follow on 15 April 2027.
The draft would supersede BOT Notification No. 16/2569, which dealt principally with cash withdrawals. The new proposal is considerably broader, covering cash deposits, banknote exchanges, and foreign banknote transactions. It also requires identity verification before every cash-related transaction, regardless of channel.
For financial institutions, the immediate impact falls on workflows, transaction monitoring systems and staff procedures. Businesses and individuals that routinely move large sums in cash will face more questions and more documentation. This applies particularly to real estate, gems and jewellery, gold, and luxury goods. Institutions may also refuse transactions where satisfactory answers are not provided.
What is changing?
The existing framework focuses on cash withdrawals and uncrossed cheques. The draft Notification extends KYC and CDD obligations to a wider set of transactions, including:
- Cash deposits;
- Exchange of Thai baht banknotes;
- Cash received for the issuance of cheques, drafts or similar instruments; and
- The purchase, sale or exchange of foreign banknotes.
The draft also requires institutions to verify the customer’s identity before every cash-related transaction. This applies across all delivery channels, and covers walk-in transactions at branches, transactions conducted at electronic branches or through electronic devices, and transactions carried out through banking agents.
The obligation under the draft attaches to the transaction rather than the relationship, meaning institutions cannot rely on onboarding checks performed at account opening.
The THB 5 million threshold and enhanced due diligence
Where an institution detects an unusual transaction, or where a customer’s cash-related transactions across all channels total THB 5 million or more in a single day, the institution must collect and record additional information. This includes:
- the purpose of the transaction, for withdrawals; and
- the source of funds, for deposits and for transactions involving Thai baht or foreign banknotes.
The institution must then assess whether the stated purpose or source of funds is consistent with what it already knows about the customer, including their profile, the nature of their business and their transaction history. Where the assessment produces red flags, or where the information provided is incomplete or unconvincing, the institution must apply EDD.
Moreover, threshold applies to a customer’s cash-related transactions across all channels in a single day. Institutions will therefore need to aggregate activity close to real time across branches, electronic channels and agent networks. Institutions relying on end-of-day batch processing risk identifying a breach only after the transaction has been completed.
Refusal and reporting to AMLO
Where a customer cannot provide satisfactory information, or cannot demonstrate a reasonable necessity for the transaction, the draft requires the institution to refuse it. The institution must then report the matter to the Anti-Money Laundering Office (AMLO) in accordance with Thailand’s AML/CFT framework.
Institutions should also expect to defend refusal decisions with documented reasoning. This may have practical implications for escalation procedures, record-keeping, and consistency of decision-making across branches and staff. Front-line personnel will also need clear scripts and escalation paths.
On the institutional side, the draft will apply to commercial banks, specialised financial institutions (SFIs), non-bank lenders, payment service providers and other regulated entities under BOT supervision. Institutions operating extensive branch or banking agent networks face the greatest implementation burden, given the number of front-line touchpoints that must be brought into line.
For legal entities operating in these sectors, and where cash is deposited on behalf of third parties, institutions may need to collect information going beyond the immediate purpose of the transaction. This extends to source of funds, assets, income and overall wealth.
Foreign investors and businesses that make or receive large cash payments in Thailand should anticipate more detailed questioning. They should prepare supporting documentation in advance, particularly for property acquisitions and high-value purchases.
Next steps and consultation
The consultation period closes on 3 September 2026, and the draft may be revised before adoption. The BOT may also issue further guidance or implementing regulations on the practical application of the requirements. Institutions should monitor developments over the coming weeks and avoid finalising implementation plans until the terms of the final Notification are confirmed.
This article is intended for general informational purposes only and does not constitute legal advice. For advice on how these proposals may affect your institution or business, please contact us.
