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                supervision in Thailand. In particular, it provides a licensing obligation for

                digital asset business platforms that intend to operate in Thailand. Apart from
                the Emergency Decree, the Thai SEC further issued a series of subordinate

                regulations to supplement the Emergency Decree in detail. It should be

                highlighted that these subordinate regulations also included exemptions in the
                                                       (26)
                case of utility token and stablecoins.

                        To conclude, stablecoins including Libra could be considered çdigital

                assetsé and çvirtual currencyé under the Emergency Decree. Accordingly,

                relevant businesses and participants may need to comply with all requirements

                and exemptions as set by the Decree. However, to this extent, the exemptions

                concerning the exempted types of businesses under the Emergency Decree
                may need to be taken into account.


                4.2.2 Regulating Related Businesses or Participants


                        In addition to the issues surrounding the legal status of virtual

                currency, particularly stablecoin and Libra coin under Thai regulatory

                frameworks, it is necessary to identify intermediaries or businesses that might
                be subject to the regulatory regime. This is because the laws involving digital

                assets are normally designed to regulate relevant businesses rather than the

                underlying technology, as there can also be a lack of understanding of

                fast-growing technologies by regulators.









                (26)
                  The exemption is specified in the notification KorTor 10/2561, KorJor 12/2561 and KorTor
                  11/2561 issued by the Securities and Exchange Commission. It became effective on June

                  16, 2018.


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