The long-standing use of nominee arrangements to circumvent Thailand’s foreign business and land ownership laws is now facing a decisive and tangible response from authorities. Recent actions and statements from the Department of Business Development (DBD) signal a significant escalation in both enforcement actions and investigative methodology.
Scope of the Crackdown
The scale of the nominee issue was made clear as DBD Director-General Poonpong Naiyanapakorn revealed that over 7,000 businesses on Koh Samui and Koh Phangan are under scrutiny as suspected nominee companies.
These are not small operators — many are core parts of the local economy, concentrated in real estate, tourism, and hospitality. This announcement underscores the pervasive nature of the problem and highlights the government’s heightened focus on compliance.
A Data-Driven Enforcement Model
The campaign has evolved from sporadic investigations to a systematic, data-driven program using advanced computer databases and search algorithms.
The DBD has fundamentally revised its inspection framework, moving beyond a simplistic review of shareholding percentages. The new model targets entities where foreigners hold any stake between 1% and 49.99% across six high-risk sectors, applying forensic criteria to uncover genuine beneficiaries and financial flows.
This approach enables prioritization of high-risk cases, ensuring that enforcement resources are deployed efficiently and with maximum impact.
Institutional Strengthening and Inter-Agency Coordination
Institutional capacity is being expanded to ensure this is not a temporary initiative. A new special committee has been established to prevent and suppress illegal businesses — a critical structural development.
Notably, this body includes the Department of Special Investigation (DSI) and the Anti-Money Laundering Office (AMLO), representing a fusion of commercial regulation, criminal investigation, and financial tracking. This multi-agency cooperation acts as a force multiplier, dramatically increasing risks for those operating illegal nominee networks.
Political Oversight and Commitment
The Commerce Ministry is seeking the establishment of a new committee chaired by a Deputy Prime Minister, ensuring high-level political oversight and policy continuity.
This sustained engagement at the Cabinet level reinforces that nominee enforcement is now a strategic national priority.
Targeting the Core Issues
This concerted action directly addresses two of the most sensitive areas under the Foreign Business Act:
- Land ownership through real estate ventures
- Restricted occupations in key service sectors
The message is clear:
The era of nominal Thai shareholders masking ultimate foreign control is ending.
Government commitment to enforcement is evidenced by a data-driven strategy, enhanced legal tools, and a rare, government-wide commitment to sustained enforcement.