Author: Lawyer Deron Lu Wenlong
On May 13, 2025, Tether, the issuer of the stablecoin USDT, announced that it would launch Tether gold tokens (XAU₮) on the Thai digital asset exchange Maxbit. According to Tether, 1 XAU₮ corresponds to 1 ounce of gold in the real world.
Prior to this, on March 10, 2025, the Thai SEC announced USDT as an accepted cryptocurrency, and the Thai Deputy Prime Minister also announced the intention to use cryptocurrencies and blockchain technology to promote local tourism.
Figure 1 Tether officially announces the launch of gold tokens in Thailand
Earlier, on December 7, 2023, Tether announced a partnership with Bitkub, Thailand's largest cryptocurrency exchange by trading volume, to launch an educational project on stablecoins and blockchain knowledge in Thailand. The two parties will enhance the digital financial awareness of Thai users through the establishment of educational courses, general movement, incentive learning programs, and Q&A shows. Notably, USDT is also the most traded stablecoin among Thai users and on the Bitkub exchange.
Tether, the issuer of the world's largest stablecoin USDT, reported in its latest Q1 2025 financial report that as of March 31, the market value of stablecoins issued by Tether was approximately 143.7 billion USD, with holdings of US Treasury bonds of approximately 120 billion USD, and in Q1, USDT saw a new supply of approximately 7 billion USD, along with the addition of 46 million new user wallets.
Even as the leading stablecoin, Tether has been continuously embracing regulation in recent years, hoping to gain more regulatory endorsements and market share. On January 13 of this year, after obtaining a digital asset service provider license (DASP) issued by El Salvador, Tether announced the relocation of its headquarters and related entities from the British Virgin Islands (BVI) to the Central American island nation of El Salvador, with the company’s CEO and COO also purchasing properties locally and obtaining local residency.
Thailand, one of the most active economies in Southeast Asia, is a world-renowned tourist destination with an export-oriented economy and frequent cross-border flows of capital and people. Under various influences, the Thai government's policies on digital assets are quite friendly, attracting many industry giants and startups to engage in crypto asset businesses in Thailand. In a global cryptocurrency adoption index country ranking released by Chainalysis in 2024, Thailand ranked 16th.
Figure 2 Chainalysis announces the 2024 cryptocurrency adoption index ranking
This article will take Tether's strategic layout in Thailand as a starting point to summarize the characteristics of the Thai market's regulation of digital assets.
Thailand's regulatory attitude towards digital assets
Thailand's regulatory attitude towards crypto assets has evolved from cautious observation to active embrace, closely related to global digital economic development trends and adjustments in Thailand's domestic economic strategy.
On May 14, 2018, Thailand issued the (Digital Asset Business Act), categorizing digital assets into two main classes: cryptocurrencies and digital tokens. The main difference is that cryptocurrencies serve as a medium of exchange, while digital tokens represent rights. The decree primarily regulates crypto assets from two major dimensions: the issuance of digital tokens and the conduct of digital asset business, including exchanges, market makers, service providers, fund managers, investment advisors, and custodial wallet service providers.
Thailand's regulation on token issuance
1. Regulated token issuance: investment tokens, utility tokens preparing for exchange listings, cryptocurrencies.
Depending on the source of income, the Thai SEC classifies digital tokens into categories such as real estate digital tokens, infrastructure digital tokens, sustainable development-related digital tokens, debt tokens, etc. In 2022, SC Asset, a real estate company, raised approximately 300 million Thai Baht (about 8 million USD) through an STO, becoming the first approved case.
Investors wishing to issue regulated tokens must meet the following conditions:
Obtain permission from the Thai SEC;
Submit a registration application for digital token issuance to the Thai SEC and submit a prospectus for token issuance;
Meet the qualification conditions required by regulations.
2. Exempted token issuance: Digital tokens issued by the Bank of Thailand (BOT), utility tokens for consumption, limited offerings meeting specific conditions.
Utility tokens for consumption:
Token issuance by the issuer for consumption purposes or as a digital certificate;
Non-consumption-based or not as a digital certificate, but limited to practical tokens used in specific distributed ledger systems, such as tokens used within centralized finance (CeFi) and decentralized finance (DeFi), or tokens used as discounts or other subsidies in licensed digital exchanges, or tokens representing voting rights.
The issuer meets SEC requirements for investor information disclosure and satisfies one of the following specific conditions for limited issuance:
Issuance to institutional investors or ultra-high-net-worth clients;
Issuance to specific investors who have a special relationship with the issuer, with an issuance period not exceeding 12 months, and no more than 50 specific investors;
Issuance period not exceeding 12 months, and the total issuance value not exceeding 20 million Thai Baht.
Thailand's regulation of digital asset exchanges
The scope of regulated digital asset exchanges: centers or networks providing services for buying, selling, and matching trades of digital assets.
Conditions that digital asset exchanges must meet:
1. An entity registered in Thailand, with a license issued by the Ministry of Finance of Thailand;
2. Exchanges must not engage in digital asset trading;
3. The registered capital paid in must not be less than 100 million Thai Baht;
4. Maintain the required net asset level according to regulations;
5. Compliance with anti-money laundering and anti-terrorism financing regulations;
6. Fulfillment of KYC, CDD, and timely reporting of suspicious transactions.
Lawyer Mankun's suggestions
1. To conduct token issuance business in Thailand, one must register a company entity in Thailand and assess whether a license from the Thai SEC is required based on the characteristics of the tokens;
2. Company management, such as directors, executive directors, and other management personnel must not have bankruptcy or criminal case records;
3. The company must have a reliable business plan and audited financial statements;
4. The company should pay attention to timely disclosure of its operational and financial data in accordance with SEC requirements.
Compliance with Thai digital asset business regulations; please contact and consult Lawyer Lu.
