Thailand sends materials on proxy companies to 43 embassies

The Department of Business Development of Thailand has sent information on over 100,000 foreign-related companies to the embassies of 43 countries in Thailand, covering 48 nationalities. This is a notification for the investigation of proxy holdings, not a list of all foreign shareholders of villas to be arrested.

The embassies received company materials for verifying investment funds, shareholding, and land ownership. The commercial department's screening pool includes 125,622 companies. Among them, 36,277 foreign companies hold 305,838 plots of land, totaling 1,064,265.38 rai. Officials clarified that this is a general screening, not a list of those already convicted.

Structurally, about 2,100 companies are indicated as potentially having proxy holdings, with over 10,000 under investigation. The Ministry of Interior has identified about 2,200 land-holding companies with foreign shareholding exceeding that of Thai parties as clearer targets, with the related land valued at approximately 85 billion baht. Additionally, about 1,100 companies have been flagged for changes in shareholders or bank accounts. Prime Minister Anutin Charnvirakul has called for direct action against proxy holdings, illegal operations, and situations where Thailand is treated as a base for criminal activities.

On-the-ground enforcement is less than this list. In May, 243 target companies were searched on Koh Pha Ngan, with 27 suspected of proxy holdings or abnormal land ownership, leading to the arrest of 2 Thais and the seizure of 37 land deeds, over 51 rai, and approximately 150 million baht. In June, 55 arrest warrants were executed in Phuket, Phang Nga, and Krabi, resulting in the arrest of 48 individuals, including 21 foreigners. In August, 13 foreigners were arrested at a villa project in Hua Hin, with property prices ranging from 10 million to 20 million baht. In September, 4 individuals were arrested in Bang Phli, with a tire company valued at over 600 million baht. None of these cases have expanded to include all villa shareholders.

Thai land law prohibits foreign individuals from owning land, and foreign companies are generally not allowed to hold more than 49%. Proxy holdings involve using Thai nationals as nominal shareholders while retaining control with foreign investors. The Department of Business Development has forwarded cases to the tax, land, police, economic crime suppression, and special investigation offices. Once the funding paths are identified, they can enter the anti-money laundering office.

This is an asset disposal driven by enforcement expectations, not open market transactions. The sellers are companies under investigation that are changing shareholders and transferring assets, while the buyers are compliant Thai capital buyers or those under forced sale procedures. Funds flow from land companies actually controlled by foreigners to entities that can pass shareholding reviews. Beneficiaries are legitimate Thai capital buyers and inspection departments; those under pressure are foreign investors nominally holding less than 49% and controlling land, as well as villa projects in Koh Pha Ngan, Phuket, and Hua Hin.

Source: Public information