AML checks your Phangan agent or lawyer must run: AMLO's customer due diligence rules explained

Why is your agent suddenly asking for a passport copy, a source-of-funds explanation and details of who really controls your buying company — before you've even made an offer? Because since being designated "reporting entities" under the Anti-Money Laundering Act B.E. 2542 (1999) (AMLA), real estate brokers, agents and developers carry their own legal duty to check who they're dealing with and to report certain transactions to Thailand's Anti-Money Laundering Office (AMLO) — separate from, and in addition to, the checks a Land Office runs when a deal is registered.

What your agent is now required to do

• Customer due diligence (CDD) — verify your identity from your passport, under the Ministerial Regulation on Customer Due Diligence B.E. 2563 (2020), before acting for you on a sale, purchase, lease or transfer of real property.
• Beneficial-owner (UBO) identification — if you're buying through a company (Thai or foreign), your agent or the closing lawyer must identify and verify the natural person who ultimately owns or controls it, generally anyone holding 25% or more of the shares or voting rights, directly or indirectly.
• Enhanced due diligence — for higher-risk profiles: politically exposed persons, complex or opaque ownership structures, and buyers from jurisdictions AMLO treats as higher-risk.
• Transaction reporting to AMLO — cash payments of roughly ฿2 million or more, and real-estate transactions valued at roughly ฿5 million or more, are reportable regardless of whether anything about the deal looks suspicious. A separate duty applies to genuinely suspicious transactions at any value.

Who exactly is covered

Real estate brokers, agents and developers were brought within AMLA's reporting-entity net under the ministerial regulation designating additional non-financial businesses and professions (a category regulators call DNFBPs — designated non-financial businesses and professions), alongside lawyers, accountants and dealers in high-value goods when those professionals handle a real estate transaction, company formation or client funds on your behalf. AMLO's own guidelines on customer due diligence, which its inspectors use as an audit manual, spell out the specific expectations for each business type, including real estate.

How this differs from the Land Office's checks

This is a distinct compliance layer from the source-of-funds questioning a Provincial Land Office now runs at registration under its 2026 "Most Urgent" circulars — see The Land Office's May 2026 source-of-funds checks. The Land Office checks are a government registration control, applied by land officials at the point of transfer; AMLO's CDD and reporting duties sit with the private-sector intermediaries — your broker, agent or lawyer — and apply from the moment they start acting for you, well before any registration appointment.

What this means for you as a buyer

• Expect it, and don't treat it as a red flag on its own. A legitimate agency asking for your passport, the source of your funds and, if you're buying through a company, the identity of its ultimate owners is doing what the law requires — not being unusually cautious.
• Have your paperwork ready early. Passport, proof of the funds' origin, and company documents showing beneficial ownership (if applicable) will be asked for before a listing agreement or offer proceeds, not just at the Land Office.
• Be wary of an agent who skips this entirely. A broker who never asks any of these questions is either unaware of a legal duty that applies to them or ignoring it — neither is reassuring about the rest of how they'll handle your transaction.
• This is separate from moving the money itself — how you actually transfer funds into Thailand and keep the paper trail is its own step; see Bringing money into Thailand: the FET form.

The takeaway: the paperwork your Phangan agent asks for before you've signed anything isn't just prudent business practice — much of it is a specific legal obligation under Thailand's anti-money-laundering law. Treat a thorough intake process as a sign you're dealing with a compliant intermediary, not an obstacle to get around.