26/07/2026
# # 📌Thailand Intensifies Nominee Crackdown, Orders Financial-Trail Checks in 16 High-Risk Provinces # # D-DAY August 1 ‼️
New company-registration rules requiring proof of funding will take effect on August 1, 2026, as authorities examine nearly 120,000 foreign-linked companies and warn lawyers, accountants and business advisers against facilitating nominee arrangements.
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# ⚠️⚠️⚖️ Legal Warning for Foreign Investors ⚠️⚠️ #
Thailand’s tougher nominee crackdown means authorities may look beyond company registration documents and examine the actual source of funds, real control, voting rights, and economic benefits. Thai shareholders must be genuine investors using their own funds—not merely lend their names to foreign investors. From August 1, 2026, bank statements and financial records may be requested where a company’s ownership or funding structure raises concerns.
Foreign investors should review their company structure, shareholder funding, loan agreements, voting arrangements. A company registration approval does not guarantee that the structure is lawful if the financial trail or actual control suggests nominee ownership.
📌 Anyone currently under investigation or facing nominee-related proceedings should cooperate with the authorities and obtain legal advice promptly. Avoid changing shareholders, transferring assets, destroying records or restructuring the company without advice, as such actions may create "Additional Allegations" or complicate the case.
💢💢 "A nominee prosecution does not automatically mean that all assets or a foreign investor’s money will be confiscated‼️" 💢💢
The investor may still have rights in "Invested Funds", but those rights must be supported by clear evidence and will depend on the facts, applicable laws and any court order.
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📰 Original source: Thansettakij
Thailand’s Department of Business Development is stepping up its investigation into suspected nominee arrangements by examining company-registration records, shareholder structures, financial statements and the movement of investment funds.
The intensified measures will focus on businesses in 16 provinces considered to have comparatively high levels of foreign investment and an increased risk of Thai nationals being used as nominee shareholders.
The department will also introduce stricter company-registration requirements from August 1, 2026, allowing officials to request bank statements and other financial evidence to verify where investment funds originated and whether the amount invested corresponds with the company’s declared shareholding structure.
# 🔎 Nearly 120,000 Companies Identified for Further Examination #
Poonpong Naiyanapakorn, Director-General of the Department of Business Development, said the department had analysed business-registration information, shareholder records, financial statements and information obtained from accounting firms.
The examination identified nearly 120,000 companies requiring further scrutiny. These businesses have foreign shareholdings ranging from 0.01% to 49.99%.
Authorities will pay particular attention to businesses in which foreign shareholders hold between 40% and 49.99% of the shares. This level is close to the maximum foreign shareholding generally permitted before a company may no longer be treated as a Thai juristic person for certain legal purposes.
However, the fact that a company has foreign shareholders or falls within a risk category does not automatically mean that it has violated the law. Authorities must still investigate the company’s actual ownership, financial transactions and business operations.
# 📍 Authorities Focus on 16 High-Risk Provinces #
The Department of Business Development identified 16 provinces where foreign investment and nominee-related risks are considered particularly significant.
The first group consists of ten major tourism and investment destinations: Chonburi, Surat Thani, Phuket, Krabi, Phang Nga, Prachuap Khiri Khan, Chiang Mai, Chiang Rai, Mae Hong Son and Rayong.
Within these ten provinces, officials identified 18,720 companies classified as very high risk and another 14,118 companies classified as high risk.
The second group covers Bangkok and five surrounding provinces: Bangkok, Samut Prakan, Samut Sakhon, Nakhon Pathom, Nonthaburi and Pathum Thani.
Authorities identified 7,579 very high-risk companies and 1,752 high-risk companies in Bangkok and the surrounding metropolitan area.
The investigation is expected to focus on businesses operating in sectors that are popular among foreign investors, including tourism, hotels, restaurants, real estate, property development and other service-related businesses.
# ⚠️ More Than 3,000 Newly Registered Companies Considered at Risk #
The department also reviewed company registrations completed during the previous six months.
More than 18,246 new companies were reportedly registered during this period. Of these, approximately 3,270 companies were considered at risk of having ownership or management structures that could facilitate nominee arrangements.
Foreign nationals appearing within the identified risk groups included people from several countries, including China, the United Kingdom, India, France, Singapore, Russia, Japan and South Korea.
The authorities emphasised that the nationality of a shareholder alone is not evidence of wrongdoing. Further examination is required to establish whether Thai shareholders genuinely invested their own money and exercised their rights as shareholders, or whether they merely held shares on behalf of foreign beneficial owners.
# 🕵️ Officials Detect More Sophisticated Evasion Methods #
The Department of Business Development has reportedly discovered increasingly sophisticated methods used to avoid scrutiny under previous company-registration procedures.
One method involves initially registering a company as being entirely owned by Thai nationals. Because the company has no foreign shareholders at the time of registration, it may avoid certain documentary checks that normally apply to foreign-linked businesses.
After the registration process has been completed, the company may gradually change its ownership or management structure by adding foreign shareholders, replacing Thai directors with foreign nationals or granting signing authority to foreign directors.
The new measures are intended to close this regulatory gap. Officials will be able to examine not only newly registered companies but also companies that were originally Thai-owned and later became connected with foreign shareholders, directors or authorised signatories.
# 📑 Bank Statements May Be Required from August 1, 2026 #
The enhanced requirements will take effect on August 1, 2026, under Central Partnership and Company Registration Office Order No. 2/2026.
The order strengthens the documents and evidence that may be required when registering or amending partnerships and limited companies involving foreign shareholders, foreign investors or foreign authorised directors.
Under the new procedure, registrars may ask Thai shareholders who invest jointly with foreign nationals to submit bank statements or other financial documents showing the source of their investment funds.
Company directors responsible for receiving investment funds or share-capital payments may also be required to provide financial evidence.
Officials will examine whether the money was genuinely transferred, whether the transferred amount matches the shareholder’s declared investment and whether the funds were transferred within the relevant period.
Where the financial records are inconsistent with the company-registration documents, the registrar may reject the registration application or refuse to record the proposed amendment.
The government has clarified that financial documents will not necessarily be demanded from every company with foreign involvement. Registrars will consider the facts, evidence and risk factors of each case before requesting additional documents.
🏢 Changes to Previously Thai-Owned Companies Will Also Be Examined
The new requirements will also cover companies that were originally registered as entirely Thai-owned but later changed their ownership or management structure.
Further scrutiny may be applied where a company adds foreign shareholders, appoints foreign directors, grants signing authority to foreign nationals or otherwise changes from a Thai-owned business into a foreign-linked business.
This approach is intended to prevent companies from avoiding examination by registering under a Thai-only structure before transferring control or economic benefits to foreign parties after incorporation.
# ⚖️ Accountants, Lawyers and Legal Advisers Warned ⚠️ #
Poonpong Naiyanapakorn also issued a warning to professional service providers who may assist clients in establishing nominee arrangements.
The warning was directed particularly at more than 80,000 accountants and over 90,000 lawyers and legal consultants operating in Thailand.
He urged professional advisers to stop supporting, preparing or recommending structures intended to conceal foreign ownership or circumvent Thai laws restricting foreign participation in certain businesses.
Company-registration documents and related legal documents in Thailand are generally prepared in the Thai language. Foreign investors therefore commonly require assistance from Thai accountants, lawyers, consultants or company-registration service providers.
Authorities are consequently examining whether professional advisers have knowingly assisted in arranging nominee shareholdings, preparing misleading documents or concealing the actual source of investment funds.
# 🤝 Government Agencies Coordinate Investigations #
Several government and law-enforcement agencies are coordinating their investigations and exchanging information concerning suspected nominee businesses.
The agencies involved include the Department of Business Development, the Revenue Department, the Department of Lands, the Royal Thai Police and the Department of Special Investigation.
The Department of Special Investigation and the Department of Business Development have previously cooperated in examining suspected nominee structures in major tourism destinations, including Koh Samui, Koh Phangan, Phuket, Krabi, Phang Nga, Pattaya and Hua Hin.
The investigations may include examining corporate records, tax information, land ownership, property transactions, shareholder funding and the identities of individuals who exercise actual control over the businesses.
# 📌 Government Says Legitimate Foreign Investors Are Not the Target #
The government has stressed that the measures are not intended to treat every foreign investor or foreign-linked company as suspicious.
The objective is to distinguish genuine investment and legitimate Thai shareholders from arrangements in which Thai individuals merely hold shares on behalf of foreign nationals to avoid legal restrictions.
Officials said lawful foreign investors who maintain transparent financial records, comply with company-registration requirements and operate within the limits of Thai law should not be adversely affected.
The enhanced scrutiny is intended to protect legitimate Thai and foreign businesses, ensure fair competition and prevent illegal structures from being used to conceal the true ownership or control of businesses operating in Thailand.
#ทนายบ้านและคอนโด
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# 📰 Source Credit #
This English-language article is based on the Thai report:
“กรมพัฒน์ฯ ไล่บี้นอมินี สั่งเช็ก Statement สอบเส้นเงิน เล็ง 16 จังหวัดเสี่ยง ดีเดย์ 1 ส.ค.”
https://www.thansettakij.com/economy/664127
Additional information was cross-checked against announcements and reports from the Royal Thai Government, the Ministry of Commerce, the Department of Special Investigation and The Nation Thailand.
📖 Original article: Thansettakij – Economy News
Related official and supporting sources: Royal Thai Government, Ministry of Commerce, Department of Special Investigation, The Nation Thailand
