As Thailand continues to strengthen its position as a regional investment and wealth management hub, Family Offices are becoming increasingly important for international investors and high-net-worth families seeking to preserve, manage, and transfer wealth across generations in a structured manner. A Family Office can serve as a central platform for coordinating investments, legal and tax planning, asset structuring, succession planning, and services provided by various professional advisers. However, establishing a Family Office in Thailand requires careful consideration of its operating model, scope of services, and applicable regulatory requirements. Due our work for wealthy families and high net worth individuals from Dubai, South America, Switzerland, Singapore and Luxembourg, our law firm in Thailand, Herrera and Partners (H&P) have prepared a summary of the regulations related to family offices under Thai Law.
Recognizing the potential of Family Offices to support Thailand’s investment ecosystem, the Securities and Exchange Commission (the “SEC”) issued Circular Letter No. SEC. Nor. Chor. (W) 47/2569 on the Promotion and Regulation of Family Office Businesses in Thailand, dated 9 September 2026 (the “Family Office Circular Letter”), to clarify its regulatory approach and provide practical guidance for families and business operators considering the establishment of such structures.
Understanding Family Office Structures
Family Offices generally operate under two main models:
Single-Family Office (SFO)
An SFO is an organization that manages the wealth and affairs of a single family or a related business group. Its functions may include investment coordination, oversight of family assets, succession planning support, and liaison with external professional advisers. Its activities generally focus on serving the family’s own interests rather than providing services to unrelated external clients.
Multi-Family Office (MFO)
An MFO provides services to multiple families and typically operates on a commercial basis. Its scope of services may include administrative support, investment advice, portfolio management, and coordination with licensed financial institutions, depending on its business model.
The appropriate structure depends on the family’s objectives, the number of families served, the nature of the required services, and the level of investment decision-making authority delegated to the Family Office. A well-designed structure can centralize governance and improve coordination while allowing suitably qualified external professionals to perform specialized functions.
Thailand’s Regulatory Approach: Substance Over Labels
A key consideration for investors is that Thailand does not prescribe a specific license solely for operating a business under the name “Family Office”. Instead, the regulatory assessment focuses primarily on the actual activities conducted and whether those activities constitute regulated businesses under Thai law.
Services such as general administration, legal coordination, accounting, and tax planning generally do not fall within the SEC’s securities business licensing requirements, provided that they do not involve activities requiring separate authorization under applicable laws. Nevertheless, other professional or business-specific regulatory requirements may still apply.
An SFO that serves only its own family, does not ordinarily operate on a commercial basis, does not provide services to external clients, and does not solicit members of the public to use its services would generally not be regarded as operating a securities business under the approach set out in the Family Office Circular Letter.
By contrast, an MFO operating on a commercial basis should carefully assess whether its services involve regulated investment activities, particularly investment advisory services and discretionary portfolio management, which may require different types of licenses.
Investment advisory services may arise when a service provider analyses or makes recommendations concerning securities, investment products, or asset allocation without making investment decisions on behalf of clients. The Circular Letter identifies certain circumstances in which exemptions may be available, including providing advice to no more than 15 clients within any 12-month period, subject to conditions. These may include the requirement that the service provider must not hold itself out as operating an investment advisory business and must not conduct such activities as an ordinary business. Providing advice exclusively to institutional investors may also qualify for an exemption.
The availability of an exemption depends on the applicable conditions and the overall circumstances of the case. The number of clients alone may not be decisive. Other relevant factors include the service provider’s intentions, marketing activities, target clientele, and actual operating model.
Private fund management may arise when a service provider manages clients’ assets and exercises discretion over investment decisions, such as selecting investments or adjusting portfolios under delegated authority. Such activities may require a private fund management business license unless an exemption prescribed by law applies.
Accordingly, investors should clearly define the Family Office’s scope of responsibilities from the outset, particularly where the proposed activities involve investment advice, handling trading orders, or exercising discretion over asset management.
Working with Licensed Financial Institutions
A Family Office does not necessarily need to perform every function in-house. It may coordinate with banks, securities companies, investment advisers, fund managers, and other licensed professional service providers, depending on the intended arrangement.
An unlicensed Family Office may perform permissible administrative functions, such as arranging appointments, collecting documents that do not constitute trading orders, and monitoring transaction progress. However, it must not engage in activities that require a license, including receiving, confirming, amending, or forwarding trading orders on behalf of clients where the applicable regulations do not permit such activities, or exercising investment discretion without the necessary legal authority.
Licensed financial institutions may delegate certain functions to a Family Office where the relevant regulatory requirements are satisfied. Such arrangements should clearly define each party’s duties and responsibilities, confidentiality obligations, data protection measures, and audit or monitoring rights. Outsourcing does not relieve a financial institution of its legal responsibilities.
In addition, commercial arrangements involving client referral fees, revenue sharing, or other forms of remuneration should be carefully reviewed. Appropriate measures should be implemented to manage conflicts of interest, and relevant information should be disclosed to clients in accordance with applicable requirements.
How Herrera & Partners Can Assist
Herrera and Partners recognize that establishing a Family Office involves more than simply selecting an organizational structure. Investors and families must also consider the associated legal, corporate, regulatory, tax, and succession planning implications.
Our private client’s team with our tax team in Thailand at H&P, can assist clients in evaluating their proposed Family Office model, reviewing the intended scope of services, identifying potentially applicable licensing requirements, and developing an appropriate legal and corporate structure under Thai law.
We can also advise on agreements with external professionals and licensed financial institutions, corporate governance, asset-holding structures, and coordination with relevant advisers on succession planning and wealth preservation. Where regulated investment services are contemplated, we can help identify the relevant regulatory considerations and support clients in evaluating an appropriate and legally compliant operating model.
Our approach takes into account each client’s objectives, family circumstances, investment activities, and long-term plans. Addressing legal and regulatory considerations at an early stage enables families to make better-informed decisions and helps reduce the risk of costly restructuring or regulatory issues arising at a later stage.
If you require a legal consultation regarding family offices in Thailand and the regulatory framework to build up the wealth in Thailand as your new tax residency, please contact our private clients team at our law firm in Bangkok via email at info@herrera-partners.com
