BANGKOK, Thailand – Thailand has launched its most aggressive crackdown on nominee structures in years, with over 850 companies already prosecuted and more than 46,000 under surveillance.
Thailand Tightens Controls: What the New DBD Orders Mean
The Department of Business Development (DBD) has issued two orders since the start of the year that fundamentally change how foreign-controlled firms are handled. Order No. 2/2568, effective January 1, 2026, requires Thai shareholders in companies with foreign directors to submit three months of bank statements with a traceable payment flow. Anyone who made a one-time payment to a Thai partner shortly before incorporation is immediately exposed.
Since April 1, 2026, Order No. 1/2569 adds another layer: registering a foreign director in an existing company now requires an affidavit stating that all shareholders are genuine investors, share capital has been correctly paid, and no hidden agreements exist. A false statement is no longer a regulatory offense — it establishes personal criminal liability for the signatory.
April 29, 2026: 21 Agencies Join Forces
What sets the current crackdown apart is the scale of inter-agency coordination. This afternoon, 21 state agencies — including AMLO, the Central Investigation Bureau, the Bank of Thailand, and the Revenue Department — will sign an agreement at Government House for nationwide real-time monitoring of suspicious money flows. Prime Minister Anutin Charnvirakul will personally preside over the ceremony.
Running since August 2025, the Intelligence Business Analytics System (IBAS) automatically cross-references databases from multiple agencies. It searches for specific patterns: a Thai shareholder appearing in dozens of unrelated companies, shareholders with no visible capital, or firms without dividends or business activity.
Dormant companies that only hold land are a particular focus. The system detects them reliably and automatically triggers a review.
Pattaya and the EEC: Why These Regions Are in the Crosshairs
In March 2026, DBD officers conducted three-day inspections of tourism and real estate businesses in Pattaya, together with the DSI, tourism police, and immigration authorities. The result: 146 foreign companies in Chon Buri province are suspected of operating in prohibited business sectors. They are on a blacklist, and ongoing financial audits trace every baht of startup capital back to its source. Nationwide, the DBD is checking 21,459 suspected cases in 2026.
In the Eastern Economic Corridor (EEC), the sums are even larger. Opaque corporate networks are suspected of concealing ownership of land plots ranging from hundreds to over a thousand rai. The Quick Big Win program is showing early results: according to government spokesperson Rachada Dhnadirek, the number of newly registered risk firms dropped by 60 percent in the first quarter of 2026 — from 3,511 to 1,373.
“The number of newly registered risk firms dropped by 60 percent in the first quarter of 2026,”
said government spokesperson Rachada Dhnadirek.
Penalties and Who Is at Risk
Nominee structures have never been legal in Thailand. What has changed is the technical capability and resolve of the authorities. The Foreign Business Act provides for prison terms of up to three years and fines between 100,000 and 1 million baht, with possible daily fines as long as the violation continues. Section 36 targets both sides: the Thai nominee and the foreign principal.
For foreigners holding land through nominee companies, an additional risk looms: the government is currently reviewing an amendment to the Land Code that would allow the state to confiscate such land without compensation. Anyone over 60 holding a house in Chiang Mai through an inactive firm, assuming nobody will notice — exactly such dormant structures are the first flagged by IBAS.
Legal Alternatives: What Actually Works
Those who want to review or restructure their holdings have legal options. The simplest is buying a condominium in one’s own name — up to 49 percent of a building’s total area may be foreign-owned. For houses, a registered 30-year leasehold combined with a superficies right (separating building and land ownership) is available.
Those wishing to run an active business should check if BOI promotion is possible: BOI-promoted firms can, under certain conditions, be 100 percent foreign-owned and directly acquire land. In the EEC, extended lease terms of up to 50 years apply. An experienced lawyer specializing in Thailand can help find the right structure — before the authorities knock.
What to Do Now
Anyone holding a Thai company over which they exercise factual control without being a genuine co-shareholder should have the structure reviewed by an independent lawyer — and do so promptly. The authorities work data-driven and are not looking for major criminals; they are looking for patterns. Those flagged by the system will receive a letter — or a visit. The DBD has also announced unannounced on-site inspections at law firms that set up such structures.
For residential property: anyone consulting a real estate expert in Thailand should explicitly ask for legal structures — leasehold, superficies, or condo freehold. The era when lawyers sold nominee packages as a standard solution is over. Anyone still offering that now has a problem themselves. Those who act quickly still have room to restructure — those who wait risk having the authorities make the decision for them.
Editorial Notes
This article is for general information only and does not replace individual legal advice. The legal situation regarding nominee structures in Thailand is complex and depends on individual circumstances. For evaluating existing company structures, a lawyer licensed in Thailand should be consulted. All information reflects the status as of April 2026.