Thailand's Land Department has intensified enforcement against foreign property ownership violations, deploying enforcement teams across three southern provinces in coordinated operations targeting nominee structures designed to circumvent strict land ownership laws. Operations conducted in early 2025 swept through Phuket, Phang Nga, and Krabi, with authorities seizing 172 land parcels spanning more than 130 rai—valued at approximately 1.67 billion baht—and arresting individuals in what officials describe as a decisive escalation in enforcement.
Why This Matters
• Property at risk: Foreign nationals using Thai proxies to hold land face criminal charges, fines up to 20,000 baht, and potential asset forfeiture.
• Enforcement shift: The government has integrated AI screening and inter-agency data sharing to flag suspicious corporate structures, making evasion significantly harder.
• Legal exposure: Both Thai nominees and foreign beneficiaries can be prosecuted under anti-dummy laws, with companies facing fines up to 50,000 baht and dissolution.
The Scale of the Crackdown
The Royal Thai Police, working in coordination with the Land Department, the Department of Special Investigation (DSI), and immigration authorities, executed enforcement operations in early 2025. Multiple arrest warrants were issued, with authorities apprehending Thai nationals and foreigners allegedly involved in nominee arrangements—corporate shells where Thai citizens hold shares on paper but foreign investors retain actual control and capital.
The operations resulted in the seizure of 172 land plots, totaling over 130 rai with an estimated value exceeding 1.67 billion baht. In parallel enforcement actions targeting illegal forex trading operations, the DSI froze bank accounts and confiscated assets including cash, vehicles, gold bars, luxury items, firearms, and cryptocurrency hardware wallets.
Since the current government took office, cumulative asset seizures from criminal networks and legal violations have surpassed 40 billion baht, according to statements from the Prime Minister's office. The Anti-Money Laundering Office (AMLO) has returned significant amounts to victims in major cases.
How the Nominee System Works—and Why It's Illegal
Thailand's Land Code prohibits foreign nationals from owning land outright, a restriction designed to preserve domestic control over real estate. To work around this, many foreign buyers set up limited companies in which Thai nationals hold at least 51% of shares, technically satisfying the majority-ownership requirement. In practice, however, the foreign investor provides all capital, retains decision-making power, and treats the Thai shareholders as passive proxies—hence the term "nominee."
Under Thai law, this arrangement constitutes fraud. If authorities determine that a Thai shareholder lacks genuine financial contribution or independent interest in the property, the entire transaction can be voided. The property may be confiscated, and both the foreign buyer and Thai nominees face criminal liability.
What Changed in 2023—and Why Enforcement Intensified
While nominee structures have always been illegal, enforcement was historically sporadic. That changed in March 2023 when the Land Department issued Circular Letter W 6346, consolidating enforcement guidelines dating back to 2011 and directing provincial offices to apply them systematically.
Key measures introduced include:
• Transaction thresholds: Purchases by Thai nationals married to foreigners exceeding 5 million baht, or cash payments above 2 million baht, now trigger mandatory income and asset verification. Buyers must certify that funds used are "personal assets," not provided by foreign spouses.
• Corporate scrutiny: Companies with foreign directors or shareholders face deep audits of capital sources, share structure, and business rationale. Authorities cross-reference data with the Department of Business Development, AMLO, and the Bank of Thailand to detect shell companies.
• AI-powered screening: The government deployed the Intelligent Business Analytic System (IBAS), an artificial intelligence platform that analyzes corporate behavior patterns to flag high-risk entities in six sectors: tourism, real estate, land trading, hospitality, retail, and import-export.
• Inter-agency coordination: Real-time data sharing between the Land Department, DSI, Immigration Bureau, and AMLO has closed gaps that previously allowed nominee arrangements to slip through.
Enhanced enforcement protocols have been implemented to conduct forensic examination of corporate ownership, shareholder financial backgrounds, and capital origins for all land transactions involving foreign-linked entities.
Impact on Residents and Expats
For foreign nationals living in Thailand who hold property through corporate structures, this crackdown introduces significant legal and financial risk. Even arrangements established years ago under less stringent oversight are now vulnerable to investigation.
Penalties under current law include:
• Criminal charges: Up to 2 years imprisonment or fines up to 20,000 baht for individuals; companies face fines up to 50,000 baht.
• Forced disposal: Authorities can order the sale of illegally held land within a specified period. Failure to comply may result in forced auction.
• Asset forfeiture: Properties determined to be held via nominee arrangements can be seized outright.
Legal experts advise foreign property owners to conduct compliance audits immediately. Those holding land through companies should verify that Thai shareholders have genuine financial stakes, documented income streams, and independent roles in corporate governance. Structures that exist solely to satisfy the 51% rule without substantive Thai ownership are at high risk.
Regional Context: How Neighbors Handle Foreign Ownership
Philippines: Foreign nationals cannot own land, but can hold up to 40% equity in a Philippine corporation that owns land. Lease agreements can extend up to 99 years. The Anti-Dummy Law (Commonwealth Act No. 108) criminalizes the use of Filipino nominees, with penalties including imprisonment, fines, and asset confiscation.
Vietnam: All land is state-owned; foreigners acquire Land Use Rights (LURs) for up to 50 years, renewable once. Foreign ownership of condominiums is capped at 30% per building. Nominee arrangements operate in a legal gray zone, and Vietnamese courts typically recognize registered holders—not foreign financiers—as lawful owners, leaving foreign investors with limited recourse in disputes.
Both countries face similar enforcement challenges, but Thailand's integration of AI screening and inter-agency data sharing represents a more aggressive technological approach.
What Expats Should Do Now
Review corporate structures immediately. If you hold property through a Thai company, ensure that:
• Thai shareholders contributed capital proportionate to their ownership stake.
• Shareholders have documented income sources and are not financially dependent on you.
• Corporate governance reflects genuine Thai participation in decision-making.
Avoid cash transactions. Large cash payments trigger automatic scrutiny. Use traceable bank transfers and retain documentation showing the origin of funds.
Consult legal counsel. If your arrangement resembles a nominee structure, seek advice on restructuring options. In some cases, converting to a long-term lease (up to 30 years, renewable) may be safer than maintaining a questionable corporate shell.
Understand that ignorance is not a defense. Authorities presume knowledge of the law. Claims that a lawyer or agent assured you the structure was legal will not shield you from prosecution.
Enforcement Continues to Expand
Ongoing enforcement operations have targeted foreign-linked companies and construction sites, resulting in multiple arrests. Authorities have examined labor practices and corporate ownership structures, particularly involving capital flows and workers operating without proper permits.
Deputy officials have stated that enforcement teams are investigating not only nominee structures but also the source of construction labor and capital flows, indicating a comprehensive approach to corporate ownership verification.
Authorities have made clear that this represents sustained, technology-enabled monitoring. Companies that restructure nominee arrangements may still face audits if historical transactions raise red flags in the IBAS system.
The Bottom Line
For foreign nationals invested in Thailand's property market, the era of lax enforcement is over. The government has committed substantial resources—human, technological, and legal—to dismantling nominee structures and reclaiming assets held in violation of the Land Code. The financial stakes are immense, with billions of baht in seized assets already processed and thousands of properties under investigation.
The message from Thai authorities is unambiguous: comply with the law or lose your investment. Those who assumed that widespread use of nominee structures implied tacit acceptance should reassess that calculus immediately. In this enforcement environment, the risk of asset forfeiture, criminal prosecution, and deportation has never been higher.
