Bank of Thailand extends enhanced checks to branch cash deposits of THB 5 million or more from 1 November

Implications for lenders

Lenders that take loan repayments, down payments or early payoffs in cash at bank branches may find borrowers asked about the source of funds once a day's cash reaches THB 5 million, which can delay large settlements. Non-bank lenders that collect in cash and bank the takings in bulk may need records of where the cash came from ready for their banks. Shifting collections to electronic channels, which the rule excludes, can reduce that friction.

Implications

Facts

The rule: the Bank of Thailand (BOT) announced on 26 October 2026 (News No. 40/2569) that Notification No. 57/2569 on risk management for cash-related transactions at financial institutions takes effect on 1 November 2026. When a customer's cash transactions at a branch reach THB 5 million ¹ or more in a single day, the institution must apply enhanced customer due diligence scaled to the customer's risk. This may include asking about the source of funds and the purpose of the transaction and requesting supporting documents.

Coverage: the release lists six types ² of branch transaction: cash deposits; deposits of cheques or drafts whose source is not clearly known; exchange of baht banknotes; receipt of cash to issue cheques or drafts; buying, selling or exchanging foreign currency; and receipt of cash for insurance premiums, investment products or derivatives. Transactions through electronic channels are not affected.

Reporting and customer treatment: institutions must report to the BOT transactions that are unusual or inconsistent with a customer's normal behaviour. They must also keep service convenient and have fast, fair procedures for customers affected by the checks. The BOT links the rule to the Bangkok Blueprint for Fraud-Resilient Financial Services, launched with the IMF and the World Bank Group.

The earlier step: Notification No. 16/2569, in force since 1 April 2026, applied the same approach to cash withdrawals of THB 5 million ³ or more in a day, with identity checks on every withdrawal and a duty to state the purpose and provide documents (ThaiPublica). At the Bangkok Blueprint launch on 14 October, the BOT Governor said cash withdrawals above THB 5 million ⁴ had fallen by about 50% ⁵ over roughly the past year.

Analysis

Time-series comparison: the BOT has moved in two steps within seven months. From 1 April 2026 the checks applied to cash leaving the banking system through large withdrawals; from 1 November they also apply to large cash coming in at branches, through deposits, banknote exchange, foreign-currency trades and cash payments for financial products. When it issued the withdrawal rule in March, the BOT had already encouraged banks to apply the same practices to cash deposits and banknote exchange, so the November notification turns that encouragement into a requirement.

What the earlier step suggests: the Governor's figure of a fall of about 50% in large withdrawals is consistent with customer behaviour responding to the first rule. The same measure does not show how much of that cash moved to electronic channels, which the November rule excludes and where the April rule already requires strong identity checks, or was split into smaller amounts below THB 5 million. The reporting duty on transactions inconsistent with a customer's normal behaviour is the part of the rule aimed at such splitting.

Counterpoints and uncertainties

The release refers to financial institutions without listing which types are covered, and gives no figures on how many transactions or customers are affected. The fall in large withdrawals is a statement by the Governor rather than a published data series, and it covers a period that began before the April rule took effect, so it does not isolate the rule's effect. Splitting cash across days or branches, or moving it outside the banking system, could limit what the rule achieves; how the BOT applies the unusual-transaction reporting duty will determine that.