Thai SEC Proposes Stablecoin Transfer Limits, Wallet Restrictions

Thailand’s SEC Proposes Strict Stablecoin Regulations, Capping Daily Transactions at 5 Million Baht Per Customer

Bangkok, Thailand – The Thai Securities and Exchange Commission (SEC) has unveiled a draft regulation aimed at tightening oversight of stablecoin transactions, initiating a public consultation period that closes on November 26. The proposed rules, detailed in Announcement No. 253/2026 issued on November 12, focus on establishing clear boundaries for individual customer activity, transaction limits, and the traceability of funds.

Daily Transaction Caps and Wallet Restrictions

Under the proposed framework, individual customers will be subject to a daily limit of 5 million Thai baht (approximately $148,000 USD) for both depositing and withdrawing stablecoins with each SEC-regulated digital asset provider. These limits will be calculated separately for incoming and outgoing transactions, meaning a customer could theoretically deposit up to 5 million baht and withdraw another 5 million baht on the same day without these amounts offsetting each other.

A critical component of the draft is the “same person” principle. Stablecoin transfers into a customer’s account must originate from a wallet verified to belong to that same customer. Similarly, withdrawals from a customer’s account must be directed to a wallet also verified as belonging to the same individual. Transfers to or from third-party wallets will be strictly prohibited.

The SEC emphasized that these transfers must adhere to the Travel Rule and related requirements. This includes customer due diligence, screening to ensure accounts are not used as proxies or linked to high-risk individuals or wallets involved in illicit activities, and the use of blockchain analysis tools to track fund flows and identify connections to high-risk or blacklisted wallets.

Income Matching Principle Introduced

The draft also incorporates an “income matching principle,” stipulating that the value of stablecoins flowing into and out of a customer’s account must be commensurate with their declared income and financial standing. This means that retail investors with monthly incomes in the tens of thousands of baht experiencing significant stablecoin inflows or outflows in a short period would be flagged as suspicious activity requiring intervention by the service provider.

Exemptions to Transaction Limits

The proposed regulations are not absolute, with four categories of transactions exempt from the 5 million baht daily limit:

• Transactions related to market-making activities.
• Stablecoin operations by businesses approved by the Bank of Thailand (BOT) under specific frameworks.
• Subscriptions and refunds for Initial Coin Offerings (ICOs).
• Transactions involving stablecoins used as payment for goods and services, provided they are conducted through approved channels.

Enhanced Transparency for Wholesale Markets

The second layer of the draft aims to increase transparency in the wholesale stablecoin market. Digital asset exchanges will be required to publicly disclose their list of market makers and the stablecoins they provide liquidity for. These market makers will also be subject to screening, monitoring, and review processes to verify the source of their assets and their trading intentions.

Brokers will be prohibited from using liquidity providers (LPs) for stablecoin-to-Thai baht trading pairs. LPs themselves must be based in jurisdictions that comply with Financial Action Task Force (FATF) recommendations on anti-money laundering (AML) and counter-terrorist financing (CTF), possess robust AML/CTF measures, be regulated by a competent authority, and demonstrate secure asset custody practices.

Brokers will also be obligated to disclose their LP lists and any potential conflicts of interest to their clients. For over-the-counter (OTC) transactions, the draft sets a minimum threshold of 3 million Thai baht (approximately $89,000 USD). Service providers must publicly disclose the transaction prices on their websites or platforms, and brokers will be barred from facilitating OTC trades between clients.

Background and Objectives

This latest draft follows a public hearing held by the Thai SEC in September concerning regulatory principles for stablecoin trading through licensed entities. That consultation focused on five key areas: market makers, liquidity providers, source exchanges, OTC trading, and data disclosure.

Prior to this, in July, the Bank of Thailand and the SEC collaborated to scan for unusually large USDT transactions using data analysis tools, referring suspicious cases to the SEC for further investigation. The preamble to the draft regulation explicitly states its objective: to prevent digital assets from being used for money laundering, cybercrime, or as channels to circumvent international remittance regulations.

Impact on Retail and Wholesale Users

For ordinary retail investors, the most immediate impact of the new rules will be the restriction of fund flows to within their own accounts. The ability to transfer USDT to friends or family, or to use third-party payment agents, will be eliminated on regulated platforms.

While the 5 million baht daily limit may not significantly affect most retail users, it is expected to have a structural impact on OTC merchants, cross-border payment providers, and underground remittance services that rely heavily on Thai baht inflows and outflows. These business models often depend on direct wallet-to-wallet transfers, a practice explicitly prohibited by the draft.

Conversely, the exemption list effectively designates legitimate wholesale flows as “whitelisted.” Market makers, BOT-approved corporate use cases, and ICO subscriptions and refunds will operate outside the 5 million baht cap, indicating that Thai regulators are primarily targeting retail-level fund flows rather than institutional liquidity.

Comparison with Taiwan’s Regulations

In comparison, Taiwan’s Financial Supervisory Commission (FSC) implemented the first phase of its Travel Rule in October, requiring domestic exchanges to transmit sender and receiver data for all transactions, regardless of amount. Transactions exceeding NT$30,000 (approximately $980 USD) also require the addition of the sender’s date of birth and address. Both jurisdictions emphasize same-name wallet verification and data transmission as core principles, with Thailand directly incorporating monetary caps into its regulations, while Taiwan relies on layered reporting fields.