What we found
We read 672 short windows of USDT transfers on Ethereum, one in every Bangkok hour of every day from Sunday 4 to Saturday 31 October 2026: 1,249,273 transfers in all. We call a transfer large when it is 909 USDT or more, about THB 30,000 at THB 33 to the dollar. That is the line from which Thailand's Travel Rule asks for the full set of sender and receiver data. 224,304 of the transfers we read were large.
- 3 in 4 large transfers landed outside office hours. 73.2% fell outside Monday to Friday, 9am to 6pm, Bangkok time. Each of the four weeks came in between 72.0% and 74.1%.
- That is mostly the clock, and it still matters. Monday to Friday office hours are 26.8% of the week, and 26.8% of large transfers fell inside them. Large flows run at much the same pace around the clock; they do not bunch into Thai office hours.
- The peak is in the evening. Large transfers per minute were highest at 9pm (111.9) and 8pm (111.8) and lowest at 11am (59.1): nearly twice as many a minute at 8–10pm as at 11am. From about 2pm to 1am the rate stays high.
- Weekends slow down, they don't stop. At weekends large transfers ran about 28% slower per minute than on weekdays.
Our reading: Bangkok's evening is Europe's afternoon and the US morning. These are global flows on a public chain, not transfers made by Thai operators for their customers.
Hour by hour
Transfers per minute in each Bangkok hour, all days of the four weeks together. Each hour is an average over 28 windows.
| Bangkok hour | Large (909 USDT or more) | $1 or more | All transfers |
|---|---|---|---|
| 00:00–01:00 | 93.4 | 368 | 490 |
| 01:00–02:00 | 87.6 | 349 | 493 |
| 02:00–03:00 | 79.5 | 331 | 507 |
| 03:00–04:00 | 84.4 | 305 | 441 |
| 04:00–05:00 | 73.9 | 284 | 467 |
| 05:00–06:00 | 65.2 | 259 | 392 |
| 06:00–07:00 | 60.4 | 243 | 402 |
| 07:00–08:00 | 62.3 | 245 | 398 |
| 08:00–09:00 | 67.1 | 260 | 392 |
| 09:00–10:00 | 67.4 | 266 | 440 |
| 10:00–11:00 | 60.7 | 232 | 395 |
| 11:00–12:00 | 59.1 | 234 | 357 |
| 12:00–13:00 | 68.7 | 279 | 409 |
| 13:00–14:00 | 76.5 | 280 | 416 |
| 14:00–15:00 | 90.0 | 315 | 511 |
| 15:00–16:00 | 88.2 | 328 | 484 |
| 16:00–17:00 | 91.4 | 346 | 514 |
| 17:00–18:00 | 90.5 | 343 | 506 |
| 18:00–19:00 | 96.5 | 366 | 543 |
| 19:00–20:00 | 100.8 | 383 | 518 |
| 20:00–21:00 | 111.8 | 396 | 518 |
| 21:00–22:00 | 111.9 | 398 | 490 |
| 22:00–23:00 | 107.2 | 411 | 507 |
| 23:00–00:00 | 102.4 | 404 | 531 |
Rates are transfers counted in each window divided by the window's length in minutes, averaged over the 28 windows of that hour. "All transfers" includes zero-value and dust transfers.
By part of the day
| Part of the day | Share of the hours | Share of large transfers | Share of transfers of $1 or more |
|---|---|---|---|
| Night, 00:00–06:00 | 25.0% | 24.2% | 24.9% |
| Early morning, 06:00–09:00 | 12.5% | 9.5% | 9.8% |
| Day, 09:00–18:00 | 37.5% | 34.7% | 34.4% |
| Evening, 18:00–24:00 | 25.0% | 31.6% | 30.9% |
This table counts every day of the week. The 73.2% figure above counts Monday to Friday 9am to 6pm as office hours and everything else, including weekends, as outside.
What it means for a Thai digital asset business
- Someone owns the night. Rules, a rota or both, but 6pm to 9am needs an owner, not an inbox that waits for the morning.
- Let rules go first. Screening and holds that run by rule work at 9pm. People then review what was held.
- Test when the volume is there. A monitoring drill at lunchtime tests the quietest hour. Run one at 9pm.
- Inbound checks come before use. Under the SEC's Travel Rule (Notification Sor Thor. 9/2026, in force from 27 February 2027), the receiving operator completes its checks before the customer can use the asset (clause 20). If those checks keep office hours, most large transfers wait for them.
These points are ComplyWise's reading, not SEC guidance. The rule itself is on our Travel Rule page.
Method
- Data. USDT Transfer events on Ethereum, read with eth_getLogs from a commercial node service. Amounts only: no addresses were kept.
- Windows. One window of 20 blocks (about 4 minutes; 241 seconds on average) in each Bangkok hour of each day, 4–31 October 2026: four full weeks, 672 windows. The start minute in each hour was drawn at random with a fixed seed, so transfers batched on the hour are neither over- nor under-sampled.
- Hour check. Each window's first block was found by timestamp and checked against the intended Bangkok hour: none fell in the wrong hour.
- Large. 909 USDT or more, taken as THB 30,000 at THB 33 per US dollar, read as 1 USDT = 1 dollar.
- Rates. Transfers per minute = transfers in the window divided by its length. Shares of the week add up the per-minute rate of every window, so each hour of each day counts once.
Limits
- Global flows, not Thai operators. Exchanges, DeFi contracts and wallet sweeps all appear here. A Thai operator's own customer flows may keep a different clock.
- A sample, not a census. 28 windows per hour of about 4 minutes each. The week-by-week figures (72.0–74.1%) show the main result is stable; single hours are less precise.
- Thai public holidays. 13 and 23 October were public holidays but are counted here as working days. Counting them as days off raises the outside-office share from 73.2% to 75.7%.
- The baht line is our assumption. The Travel Rule does not say which price or exchange rate turns a digital asset amount into baht. We used THB 33 per dollar.
- Value left out. Value by hour is driven by a few very large transfers and swings from window to window, so this page counts transfers, not dollars.
- Ethereum, October only. BSC keeps a different clock (On-chain data No. 6). Tron and other months were not checked.
Frequently asked questions
- What counts as a large transfer here?
- 909 USDT or more, about THB 30,000 at THB 33 per US dollar. From THB 30,000, Thailand's Travel Rule asks for the full set of sender and receiver data.
- Does this show Thai customers trading at night?
- No. These are global flows on Ethereum. They show that large USDT transfers do not follow Thai office hours, not what any Thai operator's customers do.
- Is 3 in 4 just because office hours are a small part of the week?
- Largely, yes. Office hours are about 27% of the week and hold about 27% of large transfers. The point for monitoring is the same: most large transfers arrive when the office is closed.
- When are large transfers busiest?
- Between 8pm and 10pm Bangkok time, with nearly twice as many a minute as at 11am, the quietest hour.
- Is the Travel Rule in force?
- Not yet. SEC Notification Sor Thor. 9/2026 takes effect on 27 February 2027.
Sources
- SEC news No. 179/2026 (2 Sep 2026): SEC issues Travel Rule for Digital Assets (Notification Sor Thor. 9/2026, effective 27 Feb 2027)
- ethereum.org — JSON-RPC API, eth_getLogs (the node call used to read Transfer events)
Accessed and last reviewed . Each figure and table cell is traced to a source above.