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THAI PROPERTIES

AML & KYC POLICY

Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Last Updated: 31 December 2025

1. Purpose of This Policy

Thai Royal Properties (“the Company”) is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy establishes the principles, procedures, and controls designed to ensure compliance with applicable laws and regulations in Thailand and relevant international standards.

This policy applies to all clients, customers, partners, agents, and employees of the Company.

2. Regulatory Framework

This policy is aligned with, and guided by, the following regulations and standards:

  • Anti-Money Laundering Act B.E. 2542 (1999) of Thailand
  • Regulations issued by the Anti-Money Laundering Office (AMLO), Thailand
  • Financial Action Task Force (FATF) recommendations
  • Applicable international AML and Counter-Terrorist Financing (CTF) standards

Where stricter requirements apply, the Company follows the higher standard.

3. Scope of Application

This policy applies to:

  • Property sales and purchases
  • Rental and lease transactions
  • Investment partnerships and joint ventures
  • Property management services
  • Payments, deposits, and commissions
  • Domestic and international clients, including foreign nationals

4. Know Your Customer (KYC) Procedures

4.1 Customer Identification

The Company verifies the identity of all clients before entering into any business relationship.

For Individual Clients:

  • Full legal name
  • Nationality
  • Date of birth
  • Government-issued photo identification (Passport / National ID)
  • Residential address
  • Contact details

For Corporate Clients:

  • Certificate of incorporation or registration
  • Business address
  • Ownership and control structure
  • Identification of directors and authorized signatories
  • Identification of beneficial owners (holding 25% or more ownership)

4.2 Enhanced Due Diligence (EDD)

Enhanced checks are conducted when dealing with:

  • Politically Exposed Persons (PEPs)
  • High-risk jurisdictions
  • Complex ownership structures
  • High-value or unusual transactions

EDD may include additional documentation, source of funds verification, and senior management approval.

5. Customer Due Diligence (CDD)

Customer Due Diligence is performed:

  • Before establishing a business relationship
  • Before processing large or unusual transactions
  • When there is suspicion of money laundering or fraud
  • When customer information changes

The Company reserves the right to refuse or terminate a relationship if satisfactory verification is not completed.

6. Source of Funds & Source of Wealth

For applicable transactions, particularly property purchases and investments, clients may be required to provide:

  • Bank statements
  • Proof of income or employment
  • Sale agreements or investment records
  • Inheritance or gift documentation

Funds must originate from legitimate and verifiable sources.

7. Transaction Monitoring

The Company monitors transactions to identify:

  • Unusual or inconsistent payment patterns
  • Large cash transactions
  • Rapid resale or transfer of properties
  • Payments from third parties without clear justification

Suspicious activity is reviewed internally and escalated when required.

8. Reporting of Suspicious Transactions

Where a transaction is suspected to involve money laundering or terrorist financing, the Company will:

  • Document the suspicion
  • Report the matter to the Anti-Money Laundering Office (AMLO) as required by law
  • Cooperate fully with competent authorities

Employees are prohibited from disclosing (“tipping off”) any client regarding such reports.

9. Record Keeping

The Company maintains records of:

  • Customer identification documents
  • Transaction records
  • Due diligence and verification materials

Records are retained for at least five (5) years after the end of the business relationship or completion of the transaction, in accordance with legal requirements.

10. Employee Training & Awareness

All relevant employees receive AML & KYC training covering:

  • Identification of suspicious activities
  • Customer verification procedures
  • Legal and regulatory obligations
  • Internal reporting mechanisms

Training is conducted periodically and updated as regulations evolve.

11. Internal Controls & Compliance Oversight

The Company maintains internal controls to ensure compliance, including:

n:

  • Appointment of a Compliance Officer
  • Periodic internal reviews and audits
  • Risk-based assessment of clients and transactions

Non-compliance by employees may result in disciplinary action.

12. Data Protection & Confidentiality

All personal and financial information collected under this policy is:

  • Used solely for compliance and legitimate business purposes
  • Stored securely
  • Protected in accordance with applicable data protection laws

13. Policy Review & Updates

This AML & KYC Policy is reviewed regularly and updated as necessary to reflect:

  • Changes in laws or regulations
  • Emerging risks
  • Business or operational changes

14. Contact Information

For questions related to this policy or compliance matters, please contact:

Compliance Department
Thai Royal Properties
Email: info@thairoyalproperties.com

15. Acceptance

By engaging with Thai Royal Properties, clients acknowledge and agree to comply with this AML & KYC Policy.