Real Estate and Grey Money: Sell at Risk of Laundering

This year, as many already know, the economy isn’t doing well.
Especially the real estate market
Which has been affected just as much as other sectors.
And real estate, being a low-liquidity asset,
Has clearly felt the impact.

Many property owners
Who come to talk with me
Whether they are well-off individuals,
Public figures,
Or even from political circles,

I often hear a familiar phrase from owners:
“Please help sell it, Mr. Ex. I don’t care what color the money is.”

It sounds half-joking, half-serious
But many people don’t realize
The consequence of using such an approach
Can have long-term effects.

Because money from a “non-clean” source
Is not only at risk of a money laundering case
But could also cause a house that’s been sold
To become seized as evidence.

The money received… ends up being returned to the state.
And worst of all,
The seller’s name ends up blacklisted by AMLO.

What’s the difference between Grey Money and Black Money?

Grey Money
Comes from semi-legal businesses
Or yet-to-be prosecuted sources, such as:

• Online gambling platforms

• Gaming shops or bars with hidden gambling

• Unregulated crypto financiers

• Cash businesses that evade taxes

Characteristics of grey money:

• It may appear clean on the surface

• Transferred via banks

• But its source violates tax law

Owners of such money try to convert it into assets
So it looks like legitimate income
e.g., buying condos, land, homes, luxury cars, gold, etc.

Black Money
Comes from direct illegal activity such as:

• Drug trafficking

• Human trafficking

• Money laundering operations

• Forgery and fraud

Black money enters the system
Through high-value, easy-to-transfer assets

Real estate is one of the top methods
For laundering money in Thailand.

Legal frameworks related to money laundering:

1. Anti-Money Laundering Act B.E. 2542 (1999)

• AMLO can seize assets

• If they suspect a crime-related origin

• They can trace back up to 10 years

2. Criminal Code Sections 357–361

• Concealing or receiving assets from crimes

• Penalty: up to 10 years imprisonment

3. Financial Transactions Law

• Receiving cash over 2 million THB without source documentation

• Considered a money-laundering risk

What most real estate sellers overlook:

1. Property can be seized even after transfer

• A house or condo purchased with grey/black money

• Even if legally transferred

• Can be seized by AMLO

• The seller won’t get the money back

• Because the money is deemed illegal from the start

2. Sellers may unknowingly face money laundering charges

• When receiving cash or transfers from third-party accounts

• Without verifying the source

• Officers may interpret it as “implicit intent.”

Example case:

• A homeowner receives 20 million baht in cash

• From a buyer without asking about its origin

• Turns out, it was gambling money

• The seller is summoned, and all accounts are frozen

3. Agents are not exempt

• Real estate agents who receive deposits, commissions, or hold money

• Can be liable if funds are linked to laundering

• Even if it’s just temporary

• Because the law defines that
  “Helping conceal money sources is also money laundering.”

4. Banks can halt transactions immediately

• If they detect abnormalities
  e.g., transfers from multiple accounts in a short time
  or foreign transfers without documentation

• Banks have the right to freeze transfers

• And report to AMLO without prior notice

Consequences of a money laundering case:

1. Loss of assets with no refund

• The state can seize related real estate

2. Blacklisted by banks and AMLO

• Can’t open new accounts or get loans

3. Business and personal reputation damage

4. Criminal and tax implications

• Undeclared income is taxed retroactively

• Along with fines and interest

Now that many know the impact,
They often ask:
“How do I know if the money used to buy property is illegal?”

The truth is — you can protect yourself:

1. For property owners:

• Always check buyer’s bank statements

• Avoid accepting cash

• Transfer title only under buyer’s name

• Keep proof of payment and all documents

2. For agents:

• Don’t accept deposits without knowing their source

• Clearly define payment methods in contracts

• If anything seems suspicious (e.g., multiple bank transfers, refusal to provide documents)
  pause the deal and report to AMLO for self-protection

3. For buyers using large cash sums:

• Prepare documents showing source of funds
  (income, loans, inheritance, etc.)

• For foreign funds:
  Must have Foreign Exchange Transaction Form (FET)

Real estate is one of the biggest assets in a person’s life.
Don’t let it become evidence in a money laundering case
Just because of the phrase:
“Any color money will do, just buy it.”

The best money isn’t the biggest amount.
It’s the money you can use safely.

Because the day AMLO knocks on your door…
You’ll realize that “any color money”
Is no longer a small matter.

Join the discussion:
https://www.facebook.com/Ex.MatchingProperty/posts/pfbid0bqcqripPGJn952g8gCgAQZhNJCHRfwfzjNzMqF81x7QoNK297C8THvB98pMRRukZl