Mankun Lawyer | The issuer of USDT, Tether, issues gold tokens, interpretation of Thailand's digital asset regulatory policies.

On May 13, 2025, Tether, the issuer of the stablecoin USDT, announced that it would be launching the Tether Gold Token (XAU₮) on the Maxbit digital asset exchange in Thailand. According to Tether, 1 XAU₮ corresponds to 1 ounce of gold in the real world. Prior to this, on March 10, 2025, the Thai SEC announced that USDT is an accepted cryptocurrency, and the Thai Deputy Prime Minister also announced that Thailand intends to utilize cryptocurrency and blockchain technology to promote the development of the local tourism industry.

Figure 1 Tether officially announces that the gold Token has officially entered Thailand. Earlier, on December 7, 2023, Tether announced a partnership with Bitkub, the largest cryptocurrency exchange by trading volume in Thailand, to launch an educational project on stablecoins and blockchain knowledge in Thailand. Both parties will enhance the digital financial awareness of Thai users through the establishment of educational courses, general campaigns, incentive learning programs, and Q&A sessions. It is worth noting that USDT is also the largest stablecoin by trading volume among Thai users and on the Bitkub exchange. Tether, the issuer of the world's largest stablecoin USDT by market size, reported in its latest Q1 2025 financial report that as of March 31, the market capitalization of stablecoins issued by Tether is approximately $143.7 billion, with holdings of U.S. Treasury bonds amounting to about $120 billion, and a new supply of USDT in Q1 of approximately $7 billion, along with 46 million new user wallets. Even as the top stablecoin, Tether has been continuously embracing regulation in recent years, hoping to gain more regulatory endorsement and market share. On January 13 of this year, after obtaining a Digital Asset Service Provider license (DASP) issued by El Salvador, Tether announced the relocation of 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 property locally and obtained local residency. Thailand, one of the most active economies in Southeast Asia, is a world-renowned tourist destination with an export-oriented economy and frequent cross-border flow of funds and personnel. Under the influence of various factors, the Thai government has a relatively friendly policy towards digital assets, attracting many industry giants and startups to engage in cryptocurrency business in Thailand. In a global cryptocurrency adoption index country ranking published by Chainalysis in 2024, Thailand ranked 16th.

Figure 2 Chainalysis releases the 2024 Cryptocurrency Adoption Index rankings. This article will take Tether's strategic layout in Thailand as a starting point to summarize the characteristics of digital asset regulation in the Thai market. Thailand's regulatory attitude towards digital assets Thailand's regulatory attitude towards digital assets has undergone a transformation from cautious observation to active embrace, closely related to the global trend of digital economic development and adjustments in Thailand's domestic economic strategy. On May 14, 2018, Thailand issued the "Digital Asset Business Act" which classifies digital assets into two main categories: cryptocurrencies and digital tokens. The main difference between the two is that cryptocurrencies serve as a medium of exchange, while digital tokens represent rights. At the same time, the act primarily regulates crypto assets from two dimensions: first, the issuance of digital tokens, and second, the conduct of digital asset businesses, including exchanges, market makers, service providers, fund managers, investment advisors, and custodial wallet service providers. Thailand's regulation on Token issuance

1. Regulated Token Issuance: Investment Tokens, Utility Tokens ready to be listed on the exchange, Cryptocurrencies. Depending on the source of income, the Thai Securities and Exchange Commission categorizes digital tokens into real estate digital tokens, infrastructure digital tokens, sustainable development-related digital tokens, debt tokens, etc. In 2022, the real estate company SC Asset raised approximately 300 million Thai Baht (about 8 million USD) through an STO, becoming the first approved case. If investors want to issue regulated tokens, they must meet the following conditions: Obtain permission from the Thai Securities and Exchange Commission; submit a registration application to the Thai Securities and Exchange Commission for the issuance of digital tokens and submit the prospectus for the token issuance; meet the qualification requirements of regulatory compliance.
2. Exempted regulatory token issuance: Digital tokens issued by the Bank of Thailand (BOT), consumption-type utility tokens, and limited offerings that meet specific conditions. Utility tokens for consumption: The issuer issues tokens based on consumption purposes or as digital certificates; utility tokens that are not based on consumption purposes or as digital certificates, but are limited to use within specific distributed ledger systems, such as tokens used within centralized finance (CeFi) and decentralized finance (DeFi), tokens used as discounts or other subsidies on licensed digital exchanges, and tokens representing voting rights. The issuer shall conduct a limited issuance upon meeting the SEC's requirements for investor information disclosure and one of the following specific conditions: Issuance directed at institutional investors or ultra-high-net-worth clients; targeted at specific investors who have a special relationship with the issuer, the issuance period must not exceed 12 months, and the number of targeted specific investors must not exceed 50; the issuance period does not exceed 12 months, and the total value of the issuance must not exceed 20 million Thai Baht. Thailand's regulation of digital asset exchanges Regulated digital asset exchange category: a center or network providing services for the purchase, sale, and matching of digital asset transactions. Conditions that a digital asset exchange must meet:
3. An entity registered in Thailand and licensed by the Ministry of Finance of Thailand;
4. The exchange shall not engage in digital asset trading activities;
5. The paid-in registered capital shall not be less than 100 million Thai Baht;
6. Maintain the net asset level required by regulations.
7. Comply with regulatory requirements for anti-money laundering and anti-terrorism financing regulations;
8. Fulfill the obligation of KYC, CDD, and timely reporting of suspicious transactions. Lawyer Mankun suggests
9. To conduct token issuance business in Thailand, it is necessary to register a company entity in Thailand and assess whether it is required to obtain a license from the Thai Securities and Exchange Commission based on the characteristics of the token.
10. The company's management, such as directors, executive directors, and other management personnel, must not have a history of bankruptcy or criminal cases.
11. The company should have at least a reliable business plan and audited financial statements;
12. The company should pay attention to timely disclose its operational and financial data in accordance with SEC requirements. Thailand's digital asset business compliance, feel free to contact and consult Lawyer Lu.

/ END. Author of this article: Lawyer Deron Lu Wenlong