The Bank of Thailand wants banks to ask where ฿5m in cash came from, not just where it is going

Since 1 April, a cash withdrawal of ฿5m or more at a Thai bank branch has needed a stated purpose. A draft rule out for consultation until 3 September would extend the same test to cash deposits, banknote exchange and foreign notes from 15 October. What that changes for anyone paying or being paid in cash on a Phuket deal.

Macro detail of a Thai baht banknote

Cash is getting harder to move through a Thai bank in either direction. Since 1 April a customer withdrawing ฿5m or more in a single day has had to tell the bank what the money is for. A draft revision now out for public consultation would apply the same test to money coming in — cash deposits, baht banknote exchange, cash handed over to buy a cheque or draft, and foreign banknotes bought, sold or exchanged. The Bank of Thailand opened comments on 5 August and closes them on 3 September, and intends the revised rules to take effect on 15 October 2026.

For a Phuket transaction that is not an abstraction. ฿5m is the price of a modest one-bedroom condo, and it is well below a villa deposit. The rule does not touch bank transfers.

What is already in force

The Bank of Thailand announced the current rules on 19 March 2026, in news release 10/2569. They come from BOT Announcement 16/2569 on managing the risk of cash-related transactions at financial institutions, and they took effect on 1 April 2026.

The substance is a threshold and a question. Where a customer conducts cash transactions of ฿5m or more in one day, the bank must check the facts about that customer intensively — asking the purpose of the transaction, or asking for documents supporting the use of the money. Where a transaction looks unusual against ordinary practice or against that customer’s own normal behaviour, the bank must report it to the Bank of Thailand.

The scope is narrower than the coverage suggested. The condition applies only to cash withdrawn at a branch and to cash cheques drawn or cashed without being crossed into an account. Bank transfers and crossed cheques paid into an account of ฿5m or more proceed as normal. The Bank of Thailand also told banks not to burden customers unduly with the checks, and to have a fast and fair route for customers caught by them.

The draft, and what it adds

The consultation opened on 5 August 2026 and runs to 3 September, with an intended effective date of 15 October 2026, as reported by InfoQuest and The Standard on 10 August. The draft widens “cash-related transactions” to cover receiving cash deposits, exchanging baht banknotes, receiving cash to issue cheques and drafts, and buying, selling or exchanging foreign banknotes — added to the withdrawals already covered.

Five obligations sit in the draft. Banks must have the customer, or whoever is acting for them, identify or verify themselves before every cash transaction. They must analyse customer behaviour and match their risk approach to it. They must first steer customers towards methods safer than cash — ones whose money trail can be traced. On an unusual transaction, or on any cash transaction of ฿5m or more in a day, they must check the customer’s data and normal transaction behaviour, and judge whether this particular cash transaction is reasonable and necessary; where it is inconsistent, unreasonable or doubtful, they must treat it as high risk and run enhanced customer due diligence, and where that check cannot be completed, they must not carry out the transaction. Finally they must monitor and detect cash behaviour on an ongoing basis and revise the approach regularly.

Cash rules at a Thai bank
In force since 1 Apr 2026Draftfrom 15 Oct 2026
Cash withdrawal at a branchcoveredcovered
Uncrossed cash chequecoveredcovered
Cash depositnot coveredcovered
Baht banknote exchangenot coveredcovered
Foreign banknotes bought, sold or exchangednot coveredcovered
Bank transfer, crossed chequenot coverednot covered
Threshold in one day฿5m฿5m
BOT news release 10/2569 of 19 Mar 2026; draft as reported by InfoQuest and The Standard, 10 Aug 2026houseviser.com

What the withdrawal rule has already done

Speaking on 11 July, Bank of Thailand governor Vithai Ratanakorn said large cash withdrawals fell by around 35% in the first two to three months after the threshold took effect, according to Daily News. He described the test banks apply as asking why the customer needs cash — why a transfer will not do, why a cheque will not do — and said a genuine business need can still be met.

He gave a sharper number for gold. After the central bank required reporting on unusual gold transactions, monthly gold withdrawals fell from an average of about 4,000 kilograms to roughly 700.

Monthly gold withdrawals before and after reporting rules
Before4000kg per month
After700kg per month
BOT governor Vithai Ratanakorn, reported by Daily News, 11 Jul 2026houseviser.com

In the same remarks he named property directly. Daily News reports him citing a case of cash carried to buy a villa worth ฿100m, and saying the central bank is looking for ways to limit grey capital in the property sector — including, possibly, a future measure barring payment in cash. That is a stated intention, not a rule: no such measure has been published, and the villa’s location was not given.

Who is affected

Anyone on either side of a Thai property payment that touches physical cash. Under the rules in force it is the payer who meets the question, at the moment of withdrawal. Under the draft it becomes the recipient too, at the moment of deposit — the seller banking the proceeds, the agent banking a commission, the developer banking a booking fee.

Foreign buyers of condominiums in the foreign quota are largely outside this by construction. That purchase already has to arrive as foreign currency remitted into Thailand, with the receiving bank issuing the FET form the Land Office wants on transfer day. A wire is not a cash transaction and the draft does not make it one.

The exposure sits with cash-settled parts of a deal: a reservation fee handed over in notes, a deposit paid at a developer’s office, a private villa or land sale between residents, a seller who prefers cash. The draft does not reach the handover of cash between buyer and seller — it reaches the bank leg either side of it, the withdrawal that funds the cash and the deposit that banks it.

What it may mean for Phuket property

This is Houseviser analysis, not something either source states about the island. The practical effect of the draft is that the cash leg of a deal acquires a documentation requirement on both ends, at a threshold most Phuket transactions clear. Cash was never the fast option in a property purchase — it was the discreet one — and the draft removes most of the discretion while leaving the speed of a transfer untouched.

The second-order effect is on timing rather than price. A bank that finds a cash transaction inconsistent, unreasonable or doubtful must complete enhanced due diligence before releasing or accepting the cash, and must refuse the transaction if that check cannot be completed — a failure mode a wire does not have. Anyone whose contract sets a payment date and a cash payment method now carries a scheduling risk that did not exist in March. The remedy is the obvious one: agree traceable payment in the contract, which is also what the draft asks banks to push customers towards.

The governor’s remark about a possible ban on cash payment in property is worth filing rather than acting on. It describes a direction of travel, and the direction has been consistent — gold, then withdrawals, then deposits.

What remains unknown

The draft is a draft. Consultation runs to 3 September, and neither the final text nor any changes made in response to comments have been published. The 15 October date is an intention stated at the opening of the consultation.

It is also unclear how banks will treat a legitimate, documented property payment in practice — whether a signed sale-and-purchase agreement satisfies the reasonableness test on its own, or whether the customer will be pushed to a transfer regardless. Nothing in the published material sets out an approved-purpose list. And no measure restricting cash payment for property itself exists; only a statement that one is being considered.

If a payment on your deal is going to move in cash, the guides below cover the alternatives and the paperwork each one needs — escrow, the FET form a foreign condo buyer needs anyway, opening a Thai account, and what actually happens at the Land Office on transfer day. Current asking prices for Phuket are on /prices.

Sources: bot.or.th, infoquest.co.th, thestandard.co, dailynews.co.th

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