Thailand - Market Insights

From scam to seizure: digital asset fraud and asset tracing in Thailand

Advances in technology and online platforms have facilitated increasingly sophisticated fraud schemes with broader reach. As digital assets have become more widely held, fraud involving such assets has grown correspondingly. In recent years, at least three major fraud cases in Thailand have centered on digital assets. The decentralized nature, volatility, and high mobility of digital assets render the collection of evidence and the tracing of assets significantly more challenging than in conventional fraud cases, underscoring the need for legal frameworks that enable early detection of fraud and effective asset recovery.

This article examines three recent digital asset-related fraud cases in Thailand and offers an analysis of the current legal landscape, together with practical observations for future consideration.

Fraud involving digital assets: recent developments in Thailand

Between late 2021 and early 2022, a cryptocurrency mining company operated an investment scheme promising high returns, exceeding legal limits, from cryptocurrency trading and Bitcoin mining. Payments ceased by mid-2022 and the operator became uncontactable, affecting around 3,000 investors with estimated losses of THB 2.6 billion. Thai authorities launched a multi‑agency investigation, with the Department of Special Investigation (DSI) accepting the case as a special case. Key individuals were charged with public fraud, fraudulent lending, and related offences. Authorities seized significant assets, including cash, cryptoassets, and luxury properties, and transferred them to the Anti‑Money Laundering Office (AMLO) for victim compensation, while criminal proceedings remain ongoing.

In 2022, a licensed digital asset exchange and broker suspended customer withdrawals following exposure to the collapse of overseas crypto lenders, resulting in losses exceeding THB 1.7 billion. Thai customers were consequently unable to access their digital assets, prompting widespread complaints and regulatory scrutiny. Criminal and civil proceedings against the company and its CEO followed, alleging fraud and deception. In 2025, the DSI accepted the case as a special case involving alleged public fraud, with damages exceeding THB 1 billion. Notably, the Criminal Court previously dismissed the criminal case brought by the victims for insufficient evidence, prompting further evidence gathering for appeal and additional legal proceedings.

In 2023, the Thai Securities and Exchange Commission (SEC) filed a complaint against a high-profile cryptocurrency influencer, who operates a digital asset trading platform, alleging unlawful digital asset business operations and misleading investment promotions. The platform allegedly solicited public investments through unlicensed online platforms by promising unusually high returns, often exceeding legal limits. Numerous investors later reported being unable to withdraw funds, with preliminary damages estimated at THB 1.39 billion. In March 2026, police arrested several associates and seized luxury assets as part of a widening investigation involving charges of public fraud, computer crime, and money laundering. Criminal proceedings remain ongoing, alongside active SEC enforcement actions and continued asset tracing efforts. While authorities are examining its digital wallets linked to both domestic and overseas accounts, effective asset freezing will require multi‑agency coordination, and remaining balances are reportedly minimal following transfers made prior to the commencement of the investigation.

Key fraud and asset tracing tools in Thailand – adequate or evolving?

As illustrated by the cases discussed above, Thailand’s current legal framework provides a range of laws and mechanisms relevant to fraud and asset tracing, which can be briefly summarized as follows.

• The principal legislation governing fraud includes the offences of fraud and public fraud under the Criminal Code, the Emergency Decree on Borrowings Which Are Regarded as Public Cheating and Fraud B.E. 2527 (1984) (as amended) and the Anti-Money Laundering Act B.E. 2542 (1999) (as amended). These statutes empower relevant authorities, including the police and the AMLO, to undertake pre-action discovery and implement interim asset preservation measures.
• Digital asset activities in Thailand are regulated under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018) (as amended), enforced by the SEC. The Decree establishes licensing requirements and prohibitions against unfair trading practices and provides criminal and civil sanctions for fraud-related misconduct. Importantly, it empowers the SEC to obtain documents and to seize or freeze assets, supporting early-stage evidence gathering and asset tracing efforts. Notably, evidence obtained through cooperation between foreign authorities and the SEC may be relied upon in Thai legal proceedings.
• The Special Case Investigation Act B.E. 2547 (2004) (as amended) authorizes the DSI to investigate designated special cases, including anti-money-laundering offences, digital asset related offences, and other complex criminal matters that require specialized inquiry, investigation and evidence collection. The Act grants DSI officers broad powers to request information from relevant parties and to seize or freeze assets for investigative and enforcement purposes.

Pre-action discovery and asset preservation measures outside those exercised by public authorities remain limited in Thailand. In civil cases in particular, claimants must generally commence proceedings before seeking court-ordered disclosure or interim relief. This creates a material risk that claims may fail for lack of evidence, or that assets may be dissipated once alleged fraudsters are alerted through service of process, leaving inadequate assets for victim compensation and complicating further asset tracing efforts, particularly where assets have been transferred across borders.

Given the decentralized, volatile, and highly mobile nature of digital assets, Thailand’s legal framework for fraud and asset tracing may require further development to address increasingly sophisticated schemes and to provide more effective remedies for victims.

Practice experience and observations

Until such reforms materialize, practitioners and affected parties will need to rely on the existing legal mechanisms described above. In our experience, the effectiveness of these mechanisms depends significantly on the speed and coordination with which they are deployed. The following observations, drawn from our practice in complex fraud and asset recovery matters, may assist stakeholders in navigating the current landscape.

First, early and proactive engagement with the relevant authorities is critical. Given the speed at which digital assets can be transferred or converted, delays in reporting suspected fraud or in initiating investigations can materially diminish the prospects of meaningful asset recovery. In practice, simultaneous engagement with multiple agencies, such as the DSI, the AMLO, and the SEC can be advantageous, as each possesses distinct investigative powers and asset tracing preservation tools. For instance, while the SEC may exercise its powers to obtain documents and freeze assets at an early stage under the Emergency Decree on Digital Asset Businesses, the AMLO’s powers under the Anti‑Money Laundering Act enable the restraint of assets suspected of being connected to predicate offences. Coordinating these parallel tracks requires careful strategic planning to ensure that actions taken by one agency do not inadvertently compromise the effectiveness of proceedings before another.

Second, cross‑border asset tracing presents particular challenges in digital asset fraud cases. As illustrated by the third case discussed above, where digital wallets showed links to both domestic and overseas accounts, fraudsters frequently exploit the borderless nature of blockchain technology to move assets beyond the reach of domestic authorities. Effective recovery in such cases requires not only familiarity with Thai investigative and enforcement mechanisms, but also the ability to coordinate with foreign counsel and authorities in relevant jurisdictions. The use of blockchain analytics tools has become increasingly important in this regard, enabling the tracing of transactions across multiple wallets and exchanges, and supporting applications for asset freezing orders in the jurisdictions where assets are ultimately held. It should also be kept in mind that certain jurisdictions offer more robust interim relief mechanisms which may complement domestic proceedings and enhance the overall prospects of recovery.

Third, the evidentiary challenges inherent in digital asset fraud cases should not be underestimated. The pseudonymous nature of blockchain transactions, the volatility of digital asset valuations, and the technical complexity of decentralized finance protocols all present obstacles to establishing the requisite elements of fraud and quantifying losses with precision. Engaging forensic and technical experts at an early stage is therefore advisable. Furthermore, as demonstrated in the second case discussed above, where the Criminal Court initially dismissed the case for insufficient evidence, the standard of proof in criminal proceedings demands thorough and well-organized evidence gathering from the outset. Advisors should consider all available avenues, including class actions and civil proceedings, to maximize the likelihood of a favorable outcome for affected investors and other victims.

The observations outlined above reflect both the complexity and the urgency that characterize fraud and asset tracing in the digital asset context. What is clear is that early action, disciplined cross-agency coordination, and forensic rigor in evidence gathering can make the difference between meaningful recovery and the irreversible dissipation of assets. As Thailand’s legal framework continues to develop in this area, stakeholders would be well advised to remain vigilant and to adopt a proactive, multijurisdictional approach to both fraud prevention and asset recovery.