Thailand Nominee Crackdown Tracker: 2024-2025 Enforcement Wave

Enforcement Overview

Thailand has launched its most aggressive enforcement campaign to date against illegal foreign nominee structures. Beginning in earnest in 2024, authorities have dramatically increased investigations, raids, and prosecutions targeting foreigners who use Thai nominees to circumvent the Foreign Business Act (FBA) and Land Code restrictions.

The crackdown involves coordinated efforts between multiple agencies including the Department of Special Investigation (DSI), Central Investigation Bureau (CIB), Department of Business Development (DBD), Anti-Money Laundering Office (AMLO), and provincial police forces.

Active Enforcement Warning

Authorities are now using AI-powered detection systems to identify suspicious company structures. Cross-referencing between DBD records, tax returns, work permits, and bank accounts is happening in real-time. If your company structure relies on passive Thai shareholders who cannot demonstrate genuine investment and involvement, you face significant criminal exposure.

Key Enforcement Agencies

Agency	Abbreviation	Role in Enforcement
Department of Special Investigation	DSI	Criminal investigation of complex nominee cases
Central Investigation Bureau	CIB	Major coordinated raids and arrests
Department of Business Development	DBD	Company registration oversight, initial screening
Anti-Money Laundering Office	AMLO	Asset seizure, money laundering investigations
Economic Crime Suppression Division	ECSD	Police economic crime unit
Department of Lands	DOL	Land ownership verification, forced disposal orders

Geographic Enforcement Hotspots

Enforcement has concentrated in tourist-heavy provinces where foreign investment and nominee structures are most prevalent. The following areas have seen the most intensive crackdown activity:

Phuket 1,600+ Companies

Primary target zone. 231 arrests in May 2024 "Operation Nominee Sweep." Russian-linked companies primary focus.

Koh Samui / Koh Phangan 7,000+ Flagged

Multi-agency task force formed Oct 2024. "Operation Pithak Samui" ongoing. 89 companies raided Oct-Nov 2025.

Pattaya / Chon Buri Active Zone

Tour operator crackdowns. Russian businesswoman arrested after 3 years hiding. Whistleblower system launched Dec 2024.

Chiang Mai Growing Focus

Chinese land purchase investigations. Tourism and e-commerce sectors targeted for 2025 inspections.

2025 Inspection Plan - 7 Target Provinces

The DBD has announced an expanded inspection plan for 2025 targeting 46,918 companies across seven provinces in high-risk sectors:

Phuket
Chon Buri (Pattaya)
Surat Thani (Koh Samui, Koh Phangan)
Krabi
Chiang Mai
Prachuap Khiri Khan (Hua Hin)
Bangkok

Priority targets include approximately 1,000 companies with foreign shareholdings between 0.001% and 49.99% in real estate, tourism, hotels, e-commerce, logistics, and agriculture.

Major Enforcement Actions Timeline

October-November 2025

Koh Phangan - "Operation Pithak Samui" Intensification

Multi-agency raids across 4 locations simultaneously. DSI, DOL, DBD, AMLO, Immigration, and Tourist Police involved. 89 companies identified as suspected nominee structures. Investigators discovered 5 Thai shareholders listed across 256 companies. Estimated tax evasion: THB 152 million+.

89 Companies 256 Linked Entities 152M+ THB Tax Evasion

October 2024

Koh Samui - Task Force Formation

Provincial Police Region 8 and Surat Thani Police formed inter-agency task force after identifying 7,000+ companies as at-risk entities. Focus on real estate, hotels, restaurants, tourism services, and villa operations.

7,000+ Flagged Companies

September 2024

Criminal Court - Landmark Conviction

23 defendants convicted in major nominee case orchestrated by Phuket law and accounting firm. Approximately 60 companies implicated. Initial 10-year sentences reduced to 5 years (suspended for 2 years) due to cooperation. THB 200,000 fines per defendant. Companies ordered dissolved.

23 Convicted 60 Companies 5yr Sentences

May 2024

Phuket - "Operation Nominee Sweep"

Largest single operation to date. CIB and ECSD coordinated province-wide crackdown. 231 total arrests including 98 foreign suspects (mostly Russians) and 37 Thai nationals acting as nominee agents. Assets seized valued at THB 1.5 billion including 245 land documents, 225 bank accounts, and 800 company registration documents.

231 Arrests 1.5B THB Seized 96 Entities Charged

April 2024

Phuket - Initial Raids

Crime Suppression Division raided 8 locations targeting 17 companies suspected of Russian ownership using Thai nominees. Investigation triggered by phone scam that uncovered shell company network. Key finding: Russian woman and two Thai women were directors/shareholders in 38+ companies.

April 2024

Pattaya - Tour Operator Crackdown

Crackdown on illegal foreign-nominated tour operators and bogus travel agents. License revocations issued, directors summoned for investigation. Focus on tourism industry transparency.

February 2025

Phuket - Continued Enforcement

23 individuals arrested including 2 Chinese nationals. Several million baht in cash seized. Ongoing focus on firms operating through nominees.

Criminal Penalties and Sentences

Landmark Case: Phuket Law Firm (September 2024)

10 Years

Initial Sentence

5 Years

Reduced (Suspended)

200,000

THB Fine Each

Statutory Penalties Available

FBA Section 36

Up to 3 years + 1M THB fine

FBA Section 37

Up to 3 years + 1M THB + dissolution

Land Code Section 111

Up to 2 years + 20,000 THB fine

Daily Violation Fine

10,000-50,000 THB per day

Additional Consequences

Company Dissolution: Courts routinely order nominee companies to be dissolved
Asset Seizure: AMLO can freeze and seize assets linked to nominee structures
Land Forfeiture: Illegally held land must be disposed within 180 days to 1 year; no compensation under proposed amendments
Immigration Consequences: Deportation, blacklisting, visa revocation
Director Liability: Directors and authorized representatives face personal criminal liability under FBA Section 41

Red Flags That Trigger Investigations

Authorities are using sophisticated detection methods including AI-powered analysis and real-time cross-referencing of multiple databases. The following patterns trigger investigation:

Inadequate Capital Sources

Thai shareholders cannot prove legitimate funds for share subscriptions. No verifiable income source for claimed investments.

Passive Thai Shareholders

Same Thai individuals appearing in multiple unrelated companies. Shareholders unable to explain business operations.

Dividend Anomalies

No proportionate dividend income to Thai shareholders. Profits not matching equity positions.

Suspicious Payment Patterns

Disguised management fees to foreigners. Consulting fees that leak profits back to foreign parties.

Foreign Control Signals

Foreigners signing contracts, authorizing payments, setting policy. Email trails showing foreign decision-making.

Filing Inconsistencies

Discrepancies between DBD records and tax returns. Mismatches in payroll data and work permits.

Sudden Ownership Changes

Ownership transfers before applying for FBL. Restructuring in anticipation of enforcement.

Registration Pattern Spikes

Rapid increase in company registrations. Shell companies with no genuine business activity.

DSI Investigation Methodology

The DSI examines four key streams when investigating nominee structures:

Funding Trail: Whether Thai shareholders have verifiable, independent sources for share subscriptions
Control Signals: Who authorizes payments, signs contracts, sets policy (email trails, board minutes, mandates)
Benefit Flow: Whether profits are distributed to Thais proportionate to equity, or leak back to foreign side via fees
Filing Consistency: Cross-referencing DBD records, tax returns, payroll data, immigration/work-permit files, UBO/AML disclosures

Nationalities and Sectors Under Scrutiny

Nationalities Most Affected

Russians: Primary focus in 2024 operations. 59,717 Russians entered Phuket since Ukraine conflict. 1,600+ suspicious business registrations identified. 98 arrested in May 2024.
Chinese: Growing focus on land purchases and agriculture. 21 Chinese nationals + 51 Thais arrested in ECSD operation. Investigations into complexes for Chinese residents.
Other Nationalities: Iranians, Australians, Europeans also targeted. Enforcement targets nominee structures regardless of nationality.

High-Risk Business Sectors

Sector	Focus Areas	Risk Level
Real Estate	Land trading, property development, villa operations	Critical
Tourism	Tour operators, travel agencies, related services	Critical
Hotels/Resorts	Accommodation businesses, boutique hotels	Critical
E-commerce/Logistics	Online retail, warehousing, transportation	High
Agriculture	Land-based operations, durian farms	High
Construction	General construction businesses	High

Proposed Legal Reforms (2024-2025)

Thailand is strengthening its legal framework to close loopholes and increase penalties for nominee arrangements:

Anti-Money Laundering Act Amendments

Status: Passed legislative process, submitted to Cabinet for House approval (August 2024)
Nominee as Predicate Offense: Acting as or assisting nominee structure = money laundering
Expanded AMLO Powers: Asset seizure from both direct offenders and facilitators
15-Year Prescription Period: Allows prosecution of older violations

Proposed Nominee Transactions Act

Criminalize indirect control of companies
Allow confiscation of land without compensation
Clearer definitions of "nominee" and "nominee transaction"

Foreign Business Act Amendments

Redefine "foreigner" to include those controlling companies through Thai representatives
Close loopholes allowing indirect foreign ownership