Key takeaways
- Choose traceable payment channels first. A wire transfer with supporting evidence suits foreign buyers, and a domestic bank transfer suits Thai buyers.
- Large cash payments from foreign buyers are high risk. Rejection should be the default policy.
- AMLO thresholds and report forms must be checked against the current announcements for the relevant type of business.
Chapter 14 Acceptable payment methods
This chapter ranks payment methods by the strength of their audit trail. First is a wire transfer from abroad directly into the seller's account, with bank evidence. Second is a domestic transfer, which suits Thai buyers: state the unit reference, use a separate project account, reconcile every day and issue receipts promptly.
Cashier's cheques are often used on transfer day. They should name a specific payee and be crossed, with the amount and cheque number verified with the bank and a copy kept. Common problems are misspelt names or cheques not issued before the end of the business day.
Cash ranks last because the source of funds is hard to prove, control costs are high and there are security risks. The handbook recommends setting a cash acceptance ceiling in the internal policy below the reporting threshold, for example limiting cash to small booking deposits, with executive approval for any exceptions.
For freehold purchases by foreign nationals, evidence that foreign currency was brought into Thailand must be reviewed. Baht already held in Thailand without linking evidence, or domestic loans, may not qualify. If funds are first transferred to the buyer's own account in Thailand, the full origin evidence must be kept. A cleaner approach is to transfer directly from abroad into the project account.
Chapter 15 Foreign customers paying in Thai baht cash
This chapter analyses the most sensitive case. A freehold purchase without evidence of funds remitted from abroad should not proceed. For leasehold, although the same requirement does not apply, that does not make it safe, because the source of funds must still be proven and the bank, land office, Revenue Department or AMLO may raise questions.
The handbook divides the risk into four layers: money laundering scrutiny, bank rejection, disruption at the land office and a tax audit. The impact may exceed the profit on a single unit, so a decision matrix is used that treats cash as rejected by default. Exceptions must go through compliance, legal counsel and the chief executive.
- Verifiable sources of funds: taxed income, salary, documented property sales, and inheritance or gifts with supporting evidence.
- Sources of funds not to be accepted: unexplained funds from third parties, informal currency exchange, loans without a contract, or cash without evidence.
- Options that can be offered: remit the money out and bring it back properly through the banking system, or use verifiable evidence of the original inward remittance.
Switching to a leasehold sale may resolve the currency restriction but does not solve the source of funds problem. If a transaction is rejected, record the reasons, return the money through an appropriate channel and take care when informing the customer about reporting.
Chapter 16 AML compliance for developers
The final chapter of this part builds an AML framework. Start by checking which laws and announcements make the business a reporting entity, then appoint a responsible person, prepare a policy, train the sales and transfer teams, set a customer risk rating and keep documents systematically.
Customer due diligence covers identity, address, source of funds, purpose and beneficial owner. Enhanced due diligence applies to PEPs, high-risk countries, large cash amounts, complex company structures or high-value transactions. The latest FATF lists and sanctions lists should be checked.
The handbook uses the THB 2 million cash reporting threshold as a control point, while some public legal sources also mention a threshold for real estate transactions. Developers should confirm the threshold, report forms and deadlines from the AMLO announcements that apply to their type of business before writing the SOP. Reporting of suspicious transactions does not depend on the amount.
Red flags the team must remember include: large cash amounts with no explanation of the source, splitting transactions to stay below the threshold, third-party funds, unusually fast resale, financial standing inconsistent with the transaction, requests for refunds in cash, high-risk countries, refusal of KYC, complex structures and inconsistent accounts of events. When one is found, it must be recorded and escalated to compliance immediately, and the report must not be disclosed to the customer.
Penalties may extend to directors or executives. The penalty rates and sections should be checked against the current law with legal counsel.