AMLO orders nationwide scrutiny of financial transactions by Politically Exposed Persons
Thailand’s Anti-Money Laundering Office issues a sweeping announcement identifying Politically Exposed Persons (PEPs) nationwide, requiring enhanced due diligence from financial institutions to strengthen anti-corruption and anti-money laundering safeguards.
On December 4, 2025, an important announcement from the Anti-Money Laundering Office (AMLO) was published in the Royal Gazette, formally identifying Politically Exposed Persons (PEPs)—a term recognised internationally to refer to individuals holding significant public positions.
The announcement is issued under the Ministerial Regulation on Customer Due Diligence (CDD) B.E. 2563 (2020) and will take effect on February 2, 2026.
This comprehensive listing reflects the government’s commitment to advancing anti-corruption and anti-money laundering efforts, in line with global standards set by the Financial Action Task Force (FATF) and the UN Convention Against Corruption (UNCAC). The principal objective is to prevent Thailand’s financial system from being exploited for money laundering by persons holding state power and to strengthen transparency in financial transactions.
AMLO stressed that being identified as a PEP does not imply wrongdoing, nor does it constitute an accusation. Instead, the designation serves solely as a risk-classification mechanism, as individuals with political influence are considered higher-risk customers for potential money-laundering activities.
Accordingly, financial institutions and reporting entities must conduct Enhanced Due Diligence (EDD) when dealing with PEPs. EDD measures include:
• verifying whether a customer is a PEP,
• requesting additional information on Source of Funds/Source of Wealth,
• obtaining approval from senior management before commencing a business relationship, and
• maintaining ongoing and close monitoring of transactions.
PEPs may still conduct transactions normally and are not subject to additional burdens unless their activity falls under existing legal reporting thresholds—such as large-value transactions or those deemed suspicious.
Defined categories of Politically Exposed Persons (PEPs)
The announcement outlines the following key groups:
- Senior officials in the Executive Branch, including the Prime Minister, Deputy Prime Ministers and Ministers
- High-ranking civil servants and police officers
- Members of the Legislative Branch
- Senior members of the Judiciary and Public Prosecutors
- Independent constitutional bodies and political parties
- Senior military and defence officials
- Senior officials in state agencies and state-owned enterprises
- Local government officials at all levels
- Foreign public officials and individuals in international organisations
- Former office-holders (within one year of leaving the post) and individuals closely associated with PEPs
The announcement also extends to family members and close associates of PEPs—particularly where there are indications that these persons may participate in significant decisions or benefit from the PEP’s influence. However, financial institutions may exempt such individuals from EDD if they determine that the risk is low.
This detailed and wide-ranging classification demonstrates Thailand’s renewed effort to align its anti-money-laundering framework with international best practices, reinforcing financial integrity and enhancing transparency among those who wield public power.
