Nominees, Bank Accounts, and Border Checks: Why Thailand’s enforcement is suddenly feeling very real

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Phuket has become a visible reminder that Thai authorities are moving from written regulations to active enforcement, signaling to foreign business owners that compliance is now being closely monitored across multiple agencies.

PATTAYA, Thailand – For years, there has been a quiet understanding among many foreign business owners in Thailand, as long as nothing goes wrong, nobody looks too closely. That assumption is starting to crack. Over the past few days, Phuket has become a very public reminder that Thailand’s authorities are no longer content with rules existing on paper. They are enforcing them on the ground, across agencies, and with consequences that are no longer theoretical.



Phuket: Where the spotlight is turned on
In late January and early February, officials from the Department of Business Development (DBD), working alongside the DSI, Immigration Police, Tourism Police, and provincial authorities, conducted intensive inspections across Phuket. The target was not subtle, companies suspected of using nominee shareholders Thai individuals fronting businesses that are effectively controlled by foreigners. These were not desk audits. Officials showed up in person. What they reportedly found will sound familiar to anyone who has spent time around Phuket’s business ecosystem:

  • Multiple companies registered at the same accounting or legal office
  • Thai shareholders unable to explain their role or decision-making authority
  • Accountants stepping in as “directors” when real directors were unavailable

Several businesses were ordered to submit further documentation. Some cases were flagged for legal action. This wasn’t random. Phuket, with its heavy foreign investment in tourism, property, and services, is an obvious place to start. And it almost certainly won’t be the last.


Nominee structures: No longer a grey zone
Nominee arrangements have existed for decades. Everyone knows someone who knows someone. But enforcement has changed the equation. Authorities are no longer just checking whether documents look correct they are asking whether the control, funding, and decision-making are real. If a Thai shareholder owns 51% on paper but can’t explain, where the investment money came from, how business decisions are made, why profits flow the way they do, that structure is suddenly fragile. What used to be “common practice” is now a liability.


Bank accounts compliance gets personal
At the same time, banks are tightening the screws. Foreign account holders are increasingly being asked to explain, the source of funds, the purpose of transactions, whether their visa status matches their financial activity, In some cases, accounts have been frozen or closed outright when answers or documents couldn’t be produced quickly enough. This isn’t banks being difficult. It’s banks protecting themselves. Under stricter AML and KYC obligations, Thai banks are under pressure to show they are not facilitating undocumented income, nominee flows, or informal business arrangements. For expats used to “set and forget” banking, this has come as a shock.


Immigration proof of funds is back in the picture
Then there’s immigration. More travelers report being asked for proof of funds at airports, especially those entering on long-stay or non-tourist visas. The law hasn’t changed but enforcement has. What makes people uneasy is not the requirement itself, but the inconsistency, Different officers, different expectations, Unclear standards on what counts as acceptable proof, Little warning before questions are asked. For long-term residents, this adds another layer of uncertainty to what used to be a routine process.



The bigger picture: This is about substance, not paper
Put all of this together, and a pattern emerges. Thailand is moving away from informal tolerance and toward substantive compliance, Who really controls the company? Where does the money really come from? Does your visa actually support what you’re doing? If the answers exist only in theory, that may no longer be enough. This isn’t about chasing every foreigner out of Thailand. It’s about drawing firmer lines and enforcing laws that have been on the books for years but unevenly applied.


What Expats should take from this
No panic is required. But complacency is risky. If you run a business using nominee shareholders, rely on loosely documented income, assume your bank account or visa is “safe because it always has been” – it may be time for a serious review.

Thailand hasn’t changed the rules. It has changed how seriously it enforces them and Phuket may just be the opening chapter.