If we only manage keys and never hold the assets, is it still custody?

It can be. Managing cryptographic keys with full or partial authority to approve transfers, as a regular business for a fee, is enough on its own; holding the assets is not required. The SEC also lists services that are not treated as custodial wallet business.

Are some custody services not treated as custodial wallet business?

Yes. SEC notification Kor Thor. 26/2565 sets out services that are not treated as this business. Whether your service fits depends on its facts.

Does a custody business have AML duties?

A licensed custodial wallet provider does. Licensed digital asset businesses are treated as financial institutions under the Anti-Money Laundering Act B.E. 2542 (Emergency Decree, section 7), which carries customer identification, due diligence and transaction reporting duties.

Digital Asset Custody in Thailand

Find out whether your custody or wallet structure is a licensed business in Thailand, and the options open.

Describe your project Ask a question

For: Wallets, exchanges, platforms and institutions holding customer digital assets or keys
You get: A written custody structure analysis
Fee: The first step is free. The assessment is a fixed fee agreed in writing; later stages are quoted separately. Government and SEC costs are shown apart.

In short

In Thailand, a custodial wallet provider is one of six licensed digital asset business types. The business covers keeping customers' digital assets, or managing cryptographic keys with full or partial authority to approve transfers, as a regular business for a fee; either one is enough. The licence is granted by the Minister of Finance on the SEC's recommendation, and the SEC sets out the services not treated as this business. Corporly, a Thai business legal service led by a Thai-licensed lawyer, analyses who holds your customers' assets and keys, and whether the structure falls within the licensed type.

Licensed type: Custodial wallet provider, added by Ministry of Finance notification (No. 2) B.E. 2565
What triggers it: Keeping customers' digital assets, or managing cryptographic keys with full or partial authority to approve transfers, as a regular business for a fee
Exclusions: Services the SEC sets out as not custodial wallet business (SEC notification Kor Thor. 26/2565)
Who grants the licence: The Minister of Finance, on the SEC's recommendation
Who can apply: A limited company or public limited company established under Thai law
Operators outside Thailand: Also covered when they serve people in Thailand, unless the SEC exempts the service
AML/CTF: Licensed digital asset businesses are treated as financial institutions under the Anti-Money Laundering Act
Fee basis: The first step is free; the assessment is a fixed fee agreed in writing

Last reviewed: 2 November 2026

What’s covered

Who holds customer assets and keys
Whether the structure falls within the licensed type
Third-party custodian and wallet arrangements
Options open, and what each requires

Not included

Licence, exemption or regulator-view promises
Technical security or custody certification

How it works

01
Describe the project
A short questionnaire. Free, no confidential documents.
02
Scope and fee
Questions, exclusions, fee and date in writing.
03
Written route
Your facts against current law, with what remains open.

Have ready: How assets and keys are held · Who can approve a transfer · Any custodian or wallet vendor contracts

A Thai-licensed lawyer with capital-markets and digital-asset compliance practice leads the work and signs off the output.

FAQ

A business that keeps customers' digital assets, or manages cryptographic keys with full or partial authority to approve transfers, as a regular business for a fee. It is one of the six licensed digital asset business types.

The first step is free. The assessment is a fixed fee agreed in writing; later stages are quoted separately. Government and SEC costs are shown apart.

Describe your project

Written and reviewed by Corporly · Last reviewed: 2 November 2026