Author: Deron Lu
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 Securities and Exchange Commission of Thailand (SEC) announced USDT as a recognized cryptocurrency, and the Deputy Prime Minister of Thailand also announced that Thailand intends to use cryptocurrency and blockchain technology to promote the development of local tourism.
Figure 1 Tether officially announced that gold tokens have officially entered ThailandEarlier, on December 7, 2023, Tether announced that it would cooperate with Bitkub, the largest cryptocurrency exchange in Thailand, to launch an educational project on stablecoins and blockchain knowledge in Thailand. The two parties will enhance Thai users' digital financial awareness by setting up educational courses, general education campaigns, motivational learning programs and question-and-answer programs. It is worth noting that USDT is also the most traded stablecoin by Thai users and Bitkub exchange.
Tether, the issuer of USDT, the world's largest stablecoin, showed in its latest first quarter 2025 financial report that as of March 31, the market value of stablecoins issued by Tether was approximately US$143.7 billion, and the scale of U.S. Treasury bonds held was approximately US$120 billion. In the first quarter, the new supply of USDT was approximately US$7 billion, and 46 million new user wallets were added.
Even though it is the leading stablecoin, Tether has been embracing regulation in recent years in the hope of gaining more regulatory endorsement and market share. On January 13 this year, after obtaining the Digital Asset Service Provider License (DASP) issued by El Salvador, Tether announced that it would move its headquarters and related entities from the British Virgin Islands (BVI) to the Central American island nation of El Salvador. The company's CEO and COO also purchased real estate there and obtained local residency.
Thailand, one of the most active economies in Southeast Asia, is a world-famous tourist destination with an export-oriented economy and frequent cross-border capital and personnel flows. Due to various factors, the Thai government's policy on digital assets is also quite friendly, attracting many industry giants and start-ups to choose to engage in crypto asset business in Thailand. In a global cryptocurrency adoption index country ranking published by Chainalysis in 2024, Thailand ranked 16th on the list.
Figure 2 Chainalysis releases the 2024 cryptocurrency adoption index rankingThis article will take Tether’s strategic layout in Thailand as the starting point to summarize the characteristics of Thailand’s market regulation of digital assets.
Thailand’s regulatory stance on digital assets
Thailand's regulatory attitude towards crypto assets has undergone a transformation from cautious observation to active embrace. This evolution is closely related to the development trend of the global digital economy and Thailand's domestic economic strategy adjustments.
On May 14, 2018, Thailand promulgated the Digital Asset Business Decree, which divides digital assets into two categories: cryptocurrencies and digital tokens. The main difference between the two is that cryptocurrencies are used as a medium of exchange, while digital tokens are used as a representation of rights and interests. At the same time, the decree mainly regulates crypto assets from two dimensions: one is the issuance of digital tokens, and the other is the development of digital asset businesses, including exchanges, market makers, service providers, fund managers, investment advisors, and custodial wallet service providers.
Regulation of token issuance in Thailand
1. Regulated token issuance: investment tokens, utility tokens ready for listing on exchanges, cryptocurrencies.
Based on different sources of income, the Securities and Futures Commission of Thailand classifies digital tokens into real estate digital tokens, infrastructure digital tokens, sustainable development-related digital tokens, debt tokens, etc. In 2022, real estate company SC Asset raised about 300 million baht (about 8 million US dollars) through STO, becoming the first approved case.
If investors want to issue regulated tokens, they need to meet the following conditions:
Obtained permission from the Securities and Futures Commission of Thailand;
Submit a registration application to the Securities and Futures Commission of Thailand for the issuance of digital tokens and submit a prospectus for the issuance of tokens;
Qualifications that meet regulatory requirements.
2. Token issuance exempted from regulation: digital tokens issued by the Bank of Thailand (BOT), consumer utility tokens, and limited offerings that meet specific conditions.
Consumption-oriented utility tokens:
The issuer issues tokens for consumption purposes or as digital certificates;
Utility tokens that are not used for consumption purposes or as digital certificates, but are limited to use in specific distributed accounting systems, such as tokens used within centralized finance CeFi and decentralized finance DeFi, tokens used as discounts or other subsidies in licensed digital exchanges, and tokens representing voting rights.
The issuer is a limited issuer that meets the SEC's requirements for information disclosure to investors and meets one of the following specific conditions:
Issuance to institutional investors or ultra-high net worth clients;
For specific investors with special relationships with the issuer, the issuance period shall not exceed 12 months and the number of specific investors shall not exceed 50;
The issuance period shall not exceed 12 months and the total issuance value shall not exceed 20 million baht.
Thailand’s Regulation of Digital Asset Exchanges
Regulated digital asset exchanges: centers or networks that provide services for buying, selling, and matching digital asset transactions.
Conditions that must be met for digital asset transactions:
1. An entity registered in Thailand and licensed by the Thai Ministry of Finance;
2. Exchanges are not allowed to engage in digital asset trading business;
3. The paid-in registered capital shall not be less than 100 million Thai baht;
4. Maintain the net asset level required by regulation;
5. Comply with regulatory requirements for anti-money laundering and counter-terrorist financing;
6. Fulfill the obligations of KYC, CDD and timely reporting of suspicious transactions.
Attorney Mankiw recommends
1. To conduct token issuance business in Thailand, you must register a corporate entity in Thailand and assess whether you need to obtain a license from the Securities and Futures Commission of Thailand based on the characteristics of the token;
2. The company's management, such as directors, executive directors, and other managers, cannot have a bankruptcy or criminal record;
3. The company should at least have a solid business plan and audited financial statements;
4. The company should pay attention to timely disclosure of the company's operating and financial data in accordance with SEC requirements.
Thailand’s digital asset business is compliant. Please feel free to contact Lawyer Lu for consultation.
