Thailand AML and Accountants: Are Accountants Covered by the Anti-Money Laundering Act?

Thailand's main anti-money laundering (AML) statute is the Anti-Money Laundering Act B.E. 2542 (1999), administered by the Anti-Money Laundering Office (AMLO). A common question for accountants is whether the Act's reporting duties apply to them. On the English translation of the Act that AMLO publishes, consolidated through Amendment No. 6 of B.E. 2565 (2022), accountants do not appear in the list of reporting professions. This guide explains what we found, why it still matters, and what we could not confirm. It is general information, not legal advice.

Who has reporting duties under the Act

Section 3 of the Act defines financial institutions to include commercial banks, finance companies, securities companies, insurers and certain cooperatives. Section 16 then lists professions with reporting duties. In the consolidated translation, the list covers investment advisers, traders in precious stones and gold, car trading and hire-purchase businesses, real estate brokers and agents, antique traders, supervised personal loan businesses, electronic money card providers, credit card providers, electronic payment service providers, and certain exchange-control financial businesses assessed as high risk. Accountants, auditors and lawyers are not in the list we read. The Act also refers to a Ministerial Regulation that was not included in the translation.

What those covered persons must do

To understand the regime, it helps to know what the listed professions do, because that is what accountants would face if they were added:

• Sections 13 and 16 require reports of cash transactions above a Ministerial Regulation threshold and of suspicious transactions.
• Section 20 requires customers to identify themselves before a transaction, and section 20/1 adds customer acceptance policies and due diligence for financial institutions and for certain listed professions.
• Section 22 sets a five-year retention period for customer identification records, running from account closure or the end of the relationship, and for transaction records, running from the transaction or recording date. Due diligence records under section 22/1 are kept for ten years.
• Section 21/1 prohibits revealing or acting in any way that may cause a customer or third party to know about a report.

For the general method of checking who your client is, see our guide to KYC and customer due diligence in accountancy practices.

Penalties for covered persons

Section 62 sets a fine of up to one million baht, plus up to 10,000 baht per day until the failure is rectified, for failing to comply with provisions including sections 13, 14, 16, 20, 20/1, 21 and 22. Section 63 provides imprisonment of up to two years, a fine of 50,000 to 500,000 baht, or both, for reports containing false statements or concealed facts. These apply to the persons the Act binds, so on the text we read they do not fall on accountants as such.

Proposals to add accountants

A September 2020 article by the law firm Tilleke and Gibbins reported a draft amendment that would expand the professions covered to include accounting, auditing and legal consulting, after a public hearing that ended on 15 June 2020. A later article by the law firm DFDL, published on 18 October 2024, described a newer draft that would add trustees, motorcycle dealers, certain leasing and hire-purchase businesses and dealers in relics and art objects. It did not mention accountants. A third commercial summary says two major amendments were approved by the Cabinet on 25 February 2025, including expanded reporting entities. We could not establish whether either amendment has been enacted, or whether it covers accountants.

Why it still matters to accountants

Even where accountants are not directly covered, they work with clients that are. Banks, securities firms and other listed businesses must identify customers and, as the Act requires, verify who they are, so a practice should expect due diligence requests from them. Practices with clients or staff in other jurisdictions may also be covered elsewhere: Indonesia, for example, names accountants as reporting parties, as our guide to Indonesia's AML obligations for accountants explains. The Tilleke and Gibbins article described the 2020 draft as recommended by the Financial Action Task Force (FATF), so the position may change; our explainer on the FATF Recommendations and grey list covers how that body works.

What we could not confirm

• Whether any amendment after Amendment No. 6 of 2022 has been enacted, and whether it adds accountants, auditors or lawyers.
• The contents of the Ministerial Regulation that the Act refers to for section 16 professions.
• The text of sections 61 and 66 and how penalties for money laundering itself apply to professionals.
• Whether AMLO or a professional body has issued guidance for accountants.

Suggested next steps

These are our suggestions, not requirements. Check the current text of the Act and any Ministerial Regulation with AMLO or a Thai lawyer before concluding that your practice is outside it. Apply sensible due diligence anyway, since your clients' banks will. Keep records for at least the five-year period that the Act sets for covered persons. For team training, see our CPD courses.

Frequently asked questions

Are accountants covered by Thailand's Anti-Money Laundering Act?

Not in the section 16 list of the consolidated English translation we read, which runs to Amendment No. 6 of 2022. A draft amendment proposed adding accounting and auditing, and we could not confirm whether it has been enacted.

What does Thailand require of covered professions?

Reports of cash and suspicious transactions, customer identification, and record keeping for five years or, for due diligence records, ten years.

Who administers the Act?

The Anti-Money Laundering Office, which publishes an English translation of the Act on its website.