What is acting in concert?

Separate persons who act together to hold or control shares, so that their holdings are counted as one. The SEC assesses it under Capital Market Supervisory Board Notification TorChor. 7/2552; in this case it points to shared funding sources and linked beneficial owners.

Under section 247 of the Securities and Exchange Act, a person or group whose holding passes the 25% trigger must make a tender offer for the company's shares. Holdings also have to be reported as they cross each 5% step under section 246.

Has anyone been convicted?

No. These are allegations made by police and the SEC at a briefing on 27 October 2026. The case goes through the police investigation, the public prosecutor and the courts, and the people named are presumed innocent.

AMLO says it will publish a notice in the Royal Gazette so that people who lost money can file claims for the seized assets; the Civil Court decides.

Are the listed companies accused?

No. The SEC has said the listed companies are not involved. The allegations concern the investors behind the shares.

Foreign Funds as a Front: Thai SEC, Police and AMLO Case

1

What happened

On 27 October 2026 the Economic Crime Suppression Division and the SEC announced a joint case against a network that, they allege, hid who really owned a block of shares in a Thai listed company. Arrest warrants were issued, four sites were searched, and AMLO has frozen assets of more than THB 26 billion, including listed shares, bank accounts and property.

Everything below is what the agencies allege. No court has ruled, and the people named are presumed innocent. The SEC has said the listed companies themselves are not involved. This update names no persons and no companies; it follows the money path, the process and the law.

2

The money path, as alleged

Illicit proceeds. Money the agencies link to fraud passed through personal and company accounts in Thailand used as pass-throughs.
Offshore. A bank in Cambodia transferred tens of billions of baht to a fund in Singapore, in what looked like ordinary bank-to-fund business.
Re-entry. The money came back as foreign investment: three groups of foreign funds took newly issued shares in a listed company in a private placement.
One owner behind three funds. The SEC says the three groups shared funding sources and had linked beneficial owners. Together they held more than 25% of the voting rights, without reporting the holding as one group and without making a tender offer.

3

How the case was built

Asking abroad. The SEC obtained fund data from foreign regulators through the IOSCO Enhanced Multilateral Memorandum of Understanding.
Looking through. Shared funding, links between the investors and the same beneficial owners add up, under Capital Market Supervisory Board Notification TorChor. 7/2552, to acting in concert: separate holders counted as one.
Warrants and searches. Police obtained arrest warrants and searched four sites, seizing documents, mobile phones, computers and crypto hardware wallets.
Freezing the assets. AMLO's seizure orders cover more than THB 26 billion. AMLO says it will publish a notice in the Royal Gazette so that victims can file claims, and the Civil Court decides.

4

The laws cited

Securities and Exchange Act B.E. 2535. Section 246 (reporting a holding as it crosses each 5% step), section 247 (a tender offer once a group passes the 25% trigger), section 298 (the penalty), and section 281/10.
Criminal Code. Criminal association, section 209.
Anti-Money Laundering Act B.E. 2542. Conspiracy to launder money, section 9; temporary seizure of assets, section 48.

The briefing named the offences; the section numbers for the Criminal Code and the Anti-Money Laundering Act are taken from the Acts themselves.

5

Where it sits on the map

Disclosure of holdings and tender offers are the SEC's rules for the capital market; laundering, the seizure of assets and the duties of reporting entities sit with AMLO. The police lead the criminal case, with the SEC supplying the securities evidence. The figure highlights the AMLO band and the SEC.

6

What it means for KYC

A fund is a customer too. A fund's name explains nothing about whose money it holds. When a fund subscribes for a large stake, the question is the same as for any customer: who ultimately owns and controls the money.
Look across, not only down. Several investors that look unrelated can share one owner. Check shared funding sources, shared directors and the same ultimate owner across investors, not only within each one.
Foreign money is not explained by being foreign. Funds that arrive from abroad still need a source. Regulators now exchange fund data across borders; the file you keep is the file they will compare.
Digital assets are in the search warrant. Crypto hardware wallets were among the items seized. Custody and transfer records for digital assets are part of the evidence trail, like bank records.

These points are ComplyWise's reading of the case for compliance teams, not findings of the agencies or a court. The full map is on the landscape page.

7

Frequently asked questions

What is acting in concert?: Separate persons who act together to hold or control shares, so that their holdings are counted as one. The SEC assesses it under Capital Market Supervisory Board Notification TorChor. 7/2552; in this case it points to shared funding sources and linked beneficial owners.
Why does 25% matter?: Under section 247 of the Securities and Exchange Act, a person or group whose holding passes the 25% trigger must make a tender offer for the company's shares. Holdings also have to be reported as they cross each 5% step under section 246.
Has anyone been convicted?: No. These are allegations made by police and the SEC at a briefing on 27 October 2026. The case goes through the police investigation, the public prosecutor and the courts, and the people named are presumed innocent.
What can victims do?: AMLO says it will publish a notice in the Royal Gazette so that people who lost money can file claims for the seized assets; the Civil Court decides.
Are the listed companies accused?: No. The SEC has said the listed companies are not involved. The allegations concern the investors behind the shares.

8

Sources

Accessed and last reviewed 28 October 2026. Each figure and table cell is traced to a source above.

When the "foreign fund" is a front: the case Thai police, the SEC and AMLO set out