This document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Thailand from December 2017. It provides key findings, ratings, and priority actions. Thailand demonstrates a substantial understanding of ML/TF risks and international cooperation, but its preventive measures, supervision of businesses, and ability to prevent misuse of legal persons are rated as low. The report outlines Thailand's progress in AML/CFT reforms and coordination but identifies gaps in assessing sector and TF risks and applying risk mitigation measures. It recommends Thailand improve pursuit of ML investigations and targeting of key risk areas like corruption.

1. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017 1
Anti-money laundering and counter-
terrorist financing (AML/CFT)
measures in Thailand
Fourth Round Mutual Evaluation
Key findings, ratings and priority actions
December 2017
http://www.fatf-gafi.org/publications/mutualevaluations/documents/mer-Thailand-2017.html

2. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017
Ratings – Effectiveness (1/3)
2
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Thailand has
achieved this
objective
1. ML and TF risks are understood and, where appropriate,
actions co-ordinated domestically to combat ML and TF
Substantial
2. International co-operation delivers appropriate information,
financial intelligence, and evidence, and facilitates action
against criminals and their assets
Substantial
3. Supervisors appropriately supervise, monitor and regulate
financial institutions and designated non-financial
businesses and professions (DNFBPs) for compliance with
AML/CFT requirements commensurate with their risks.
Moderate
4. Financial institutions and DNFBPs adequately apply AML/CFT
preventive measures commensurate with their risks, and
report suspicious transactions.
Low

3. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017 3
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Thailand has
achieved this
objective
5. Legal persons and arrangements are prevented from misuse
for money laundering or terrorist financing, and information
on their beneficial ownership is available to competent
authorities without impediments
Low
6. Financial intelligence and all other relevant information are
appropriately used by competent authorities for money
laundering and terrorist financing investigations.
Substantial
7. Money laundering offences and activities are investigated
and offenders are prosecuted and subject to effective,
proportionate and dissuasive sanctions
Moderate
8. Proceeds and instrumentalities of crime are confiscated. Substantial
Ratings – Effectiveness (2/3)

4. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017 4
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Thailand has
achieved this
objective
9. Terrorist financing offences and activities are investigated
and persons who finance terrorism are prosecuted and
subject to effective, proportionate and dissuasive sanctions.
Moderate
10. Terrorists, terrorist organisations and terrorist financiers are
prevented from raising, moving and using funds, and from
abusing the non-profit sector.
Moderate
11. Persons and entities involved in the proliferation of weapons
of mass destruction are prevented from raising, moving and
using funds, consistent with the relevant United Nations
Security Council Resolutions.
Low
Ratings – Effectiveness (3/3)

5. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017 5
Ratings – Effectiveness
0
4
4
3
High
Substantial
Moderate
Low

6. 6
Ratings – technical compliance
(1/5)
AML/CFT POLICIES AND COORDINATION
1. Assessing risks & applying a risk-based approach Par Pa ParPa Partially Compliant
2. National cooperation and coordination LargLarLarLar Largely Compliant
MONEY LAUNDERING AND CONFISCATION
3. Money laundering offence LargLarLarLar Largely Compliant
4. Confiscation and provisional measures LargLarLarLar Largely Compliant
TERRORIST FINANCING AND FINANCING OF PROLIFERATION
5. Terrorist financing offence LargLarLarLar Largely Compliant
6. Targeted financial sanctions related to terrorism & terrorist LargLarLarLar Largely Compliant
24. Transparency and beneficial ownership of legal persons NonNo NonNo Non Compliant
8. Non-profit organisations Par Pa ParPa Partially Compliant

7. 7
Ratings – technical compliance
(2/5)
PREVENTIVE MEASURES
9. Financial institution secrecy laws LargLarLarLar Largely Compliant
Customer due diligence and record keeping
10. Customer due diligence LargLarLarLar Largely Compliant
11. Record keeping LargLarLarLar Largely Compliant
Additional measures for specific customers and activities
12. Politically exposed persons LargLarLarLar Largely Compliant
13. Correspondent banking Par Pa ParPa Partially Compliant
14. Money or value transfer services LargLarLarLar Largely Compliant
15. New technologies LargLarLarLar Largely Compliant
16. Wire transfers Par Pa ParPa Partially Compliant

8. 8
Ratings – technical compliance
(3/5)
PREVENTIVE MEASURES (continued)
Reliance, Controls and Financial Groups
17. Reliance on third parties ComCoCoCo Compliant
18. Internal controls and foreign branches and subsidiaries LargLarLarLar Largely Compliant
19. Higher-risk countries Par Pa ParPa Partially Compliant
Reporting of suspicious transactions
20. Reporting of suspicious transactions Par Pa ParPa Partially Compliant
21. Tipping-off and confidentiality LargLarLarLar Largely Compliant
Designated non-financial Businesses and Professions (DNFBPs)
22. DNFBPs: Customer due diligence NonNo NonNo Non Compliant
23. DNFBPs: Other measures Par Pa ParPa Partially Compliant

9. 9
Ratings – technical compliance
(4/5)
TRANSPARENCY AND BENEFICIAL OWNERSHIP OF LEGAL PERSONS
AND ARRANGEMENTS
24. Transparency and beneficial ownership of legal persons Par Pa ParPa Partially Compliant
25. Transparency and beneficial ownership of legal arrangements Par Pa ParPa Partially Compliant
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES
Regulation and Supervision
26. Regulation and supervision of financial institutions Par Pa ParPa Partially Compliant
27. Powers of supervisors LargLarLarLar Largely Compliant
28. Regulation and supervision of DNFBPs Par Pa ParPa Partially Compliant
Operational and Law Enforcement
29. Financial intelligence units LargLarLarLar Largely Compliant
30. Responsibilities of law enforcement and investigative authorities ComCoCoCo Compliant
31. Powers of law enforcement and investigative authorities LargLarLarLar Largely Compliant
32. Cash couriers Par Pa ParPa Partially Compliant

10. 10
Ratings – technical compliance
(5/5)
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES (continued)
General Requirements
33. Statistics LargLarLarLar Largely Compliant
34. Guidance and feedback LargLarLarLar Largely Compliant
Sanctions
35. Sanctions Par Pa ParPa Partially Compliant
INTERNATIONAL COOPERATION
36. International instruments LargLarLarLar Largely Compliant
37. Mutual legal assistance LargLarLarLar Largely Compliant
38. Mutual legal assistance: freezing and confiscation ComCoCoCo Compliant
39. Extradition LargLarLarLar Largely Compliant
40. Other forms of international cooperation LargLarLarLar Largely Compliant

11. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017 11
Ratings – technical compliance
3
22
13
2
Compliant
Largely compliant
Partially compliant
Non compliant

12. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017
Key findings
 There is strong political support for recent AML/CFT reforms and for ongoing
coordination and cooperation at policy and operational levels.
 Thailand’s statutory instruments demonstrate generally good compliance and
AML/CFT institutional arrangements have also developed significantly since the
2007 Mutual Evaluation Report (2007 MER).
 Thailand is subject to a large number of significant ML and TF threats and
authorities generally have a reasonable understanding of the risks. The 2012
National Risk Assessment (NRA) informed priorities for reform. The 2016 NRA
added to the deeper understanding of risk. That NRA adopted a robust
methodology and will provide a good basis for risk-based policy development.
 Authorities have assessed risks of domestic terrorism including many related
elements of TF, but transnational terrorism and TF are not as comprehensively
assessed. Relevant agencies demonstrate a good understanding of TF risk and
context and intelligence sharing structures support awareness of TF risk
amongst authorities.
 There are gaps with assessments of sector-specific risks or more detailed TF
risks assessments being available to the private sector. Findings of risk
assessments have not been well applied to consider exemptions or enhanced
measures for ML/TF risk mitigation.
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13. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017
Key findings
 The Anti-Money Laundering Office (AMLO) is Thailand’s central authority for
AML/CFT and plays a pivotal role in coordinating ML/TF risk assessments,
including the NRA, and the development of the national AML/CFT strategies.
AMLO is also the sole AML/CFT supervisor and a specialist asset recovery Law
Enforcement Agency (LEA). AMLO, in its FIU role, collects a very wide range of
data, and provides a financial analysis and intelligence capability that is highly
regarded by key agencies responsible for investigating and prosecuting
predicate crimes, ML and TF.
 Financial intelligence is integrated into predicate investigations, although key
LEAs tend to place an over-reliance on financial intelligence generated by
AMLO at the expense of developing in-house expertise. This also contributes
to less proactive analysis and under-resourced strategic analysis within AMLO.
 Thailand has achieved a reasonable number of successful outcomes from ML
investigations and prosecutions; however ML is not sufficiently pursued as a
policy objective and used to target key risk areas, particularly corruption.
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14. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017
Key findings
 Confiscation is actively pursued and AMLO plays a significant role in asset
tracing, restraint, seizure, management and confiscation. Comprehensive
provisional measures are well implemented. Successful confiscation is well
demonstrated in narcotics matters, but is not evident across the spectrum of
high-risk crime types in Thailand. The National Anti-Corruption Commission
(NACC) results reflect an emphasis on unexplained wealth proceedings rather
than financial investigations. Implementation of cross-border controls on cash
and related detections and confiscations does not reflect the risks Thailand
faces.
 Despite high-risks of TF, particularly in Thailand’s southern border provinces,
Thailand only had three cases of TF under investigation at the time of the onsite
and there had been no convictions for TF. A large number of security cases had
been pursued where other relevant criminal provisions were utilised to
prosecute offenders for conduct related to TF.
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15. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017
Key findings
 Thailand has made strategic use of domestic 1373 designations to combat
domestic terrorism threats, having made 83 domestic proscriptions. These
designations complement criminal justice measures. Implementation of
targeted financial sanctions (TFS) against terrorism is strong in the banking
and insurance sectors but there are challenges amongst other sectors of
Financial Institutions (FIs) and Designated Non-Financial Business and
Professions (DNFBPs). Some assets have frozen in relation to the 1373
designations, but no assets have been frozen pursuant to 1267/1989. The
results from TFS are largely in keeping with the risk profile.
 Thailand has made some assessments of Non-Profit Organisation (NPO)
sector risks however further assessments are required to more effectively
target risk-based measures and oversight. AMLO has undertaken outreach
to the sector and regulators on risk.
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16. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017
Key findings
 Thailand has strong policy coordination mechanisms to support implementation of
its new legal framework for implementing weapons of mass destruction (WMD)
related TFS and additional measures including criminalisation of proliferation
financing (PF). Thailand issued guidelines on PF ahead of the new legal framework
and conducted awareness raising, outreach and supervision to support
implementation by Reporting Entities (REs) from late 2016. The PF guidance
included information on vulnerabilities to PF and related sanctions evasion.
 AML/CFT preventive measures reflect a degree of technical compliance with the
FATF standards although significant gaps remained at the time of the onsite. There
are some gaps in clarity and consistency between the various notifications and
guidelines, in particular around enhanced due diligence, which may hinder
implementation. Local large commercial banks and foreign commercial banks
demonstrate a more developed understanding of their ML/TF risks and obligations,
followed by local banks. The implementation of controls on politically exposed
person (PEP) continues to be a priority and a challenge. The quality of suspicious
transaction reporting (STR) reporting has shown a strong improvement, but the
scope of sectors reporting requires further support. The role of AMLO and other
authorities in outreach is a strength, but more support is needed for FIs and DNFBPs
to understand their risk and obligations. Comprehensive customer due diligence
(CDD) obligations for most DNFBPs only entered into force in late 2016.
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17. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017
Key findings
 The structural framework for AML/CFT supervision has been
significantly strengthened in recent years. The transition of AMLO
to the role of primary AML/CFT supervisor was successful. AMLO
has a strong understanding of risk to support it taking a risk-based
approach to supervision. There are gaps in fit and proper controls
over some sectors to prevent criminals and their associates from
entering the market and checks do not extend to beneficial
ownership, with the exception of the securities sector. It is notable
that ownership of the banking sector has been very stable over a
long period. AMLO’s approach to supervision is generally robust
and is continuing to mature, however a greater allocation of
resources and more joint work with sectoral supervisors is required
to enhance effective risk-based supervision. Available sanctions for
AML/CFT failures are low and the process for application of fines
for breaches is limited to criminal prosecutions and related settling
mechanisms. This undermines effective enforcement.
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18. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017
Key findings
 Obligations on legal persons to register basic ownership details
assist with transparency. Thailand relies on FIs to obtain beneficial
ownership (BO) information as part of CDD, however the lack of
detailed CDD obligations for DNFBPs undermined the availability of
BO information. Filing obligations support the identification of BO
for public limited companies. Thailand has demonstrated
experience in requesting basic and BO information of legal persons
and arrangements formed abroad and information on foreign
natural persons who may own or control Thai legal persons.
 Thailand takes an open and flexible approach to international
cooperation supported by a legal framework that generally
conforms to international standards. Informal cooperation is used
as a tool to enhance investigations and discuss transnational
elements of predicate crimes. Thailand is very responsive to mutual
legal assistance (MLA) requests. However, the international
cooperation framework is not used in line with the risk profile nor
targeted to specific high-risk jurisdictions including Thailand’s
immediate neighbours.

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19. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017
Priority Actions for Thailand to
strengthen its AML/CFT System
 1. Risk: Prepare further detailed assessments of risks, including assessments of
key financial and non-financial sectors and stand-alone threat assessments of
key crime types. Share the findings of such assessments with all stakeholders,
including the private sector. Ensure such findings support risk-based exemptions
and enhanced requirements.
 2. ML investigation: LEAs should develop further in-house ML investigation
expertise and more actively pursue ML investigations to target key risk areas.
 3. Asset recovery: LEAs should more actively pursue asset seizure and
confiscation across the spectrum of high-risk crime types in Thailand.
 4. TF investigation: LEAs should more actively pursue TF investigations to target
key risk areas, including transnational TF threats and stand-alone financiers.
 5. NPO outreach: Share more risk information and conduct further outreach to
at-risk NPO sectors.
 6. PF: Further support implementation of the new legal framework to combat
PF.
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20. Anti-money laundering and counter-terrorist financing measures in Thailand – Mutual Evaluation Report – December 2017
Priority Actions for Thailand to
strengthen its AML/CFT System
 7. Update and consolidate regulations: Address various technical compliance
gaps with the scope of AML/CFT preventive measures and clarify and
consolidate obligations to assist REs to understand their responsibilities.
 8. Private sector outreach: Increase detailed risk information, outreach and
guidance to the private sector on a risk-based approach.
 9. Market entry & supervision: Enhance risk-based implementation of fit and
proper controls, offsite and onsite supervision. AMLO’s robust approach to
supervision requires a greater allocation of resources and more joint work
with sectoral supervisors to enhance effective risk-based supervision.
 10. Sanctioning non-compliance: Enhance and streamline the process for
applying sanctions for AML/CFT failures.
 11. Transparency of legal persons: Enhance the obligations for and
implementation of registration of legal persons and obligations in relation to
capturing beneficial ownership information.
 12. International cooperation: Focus the use of formal and informal
cooperation by LEAs to be more in line with the risk profile, i.e. target
specific high-risk jurisdictions including Thailand’s immediate neighbours.
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