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From these laws and regulations, it can be surmised that the virtual

currency business is not a kind of financial institution business under the Act,
and therefore has no need to register as a public limited company and to

obtain a specific financial institution license in order to operate their

businesses in Thailand.

To this extent, in the case of Libra and authorized resellers, the latter
may not be considered as a type of commercial banking business under the

Financial Institution Business Act.

4.2.2.4 The Payment System Act B.E. 2560 (2017)

As previously mentioned, the virtual currency business may not fall

within the scope of the designated payment service business under the
(34)
Payment System Act. In particular, Section 16 states that the following

payment services may be prescribed in the notification issued by the Bank of
Thailand as the designated payment service, Section 16 of which

encompasses: ç...(1) provision of credit card, debit card, or ATM card services;

(2) provision of an electronic money service; (3) provision of a service of
receiving electronic payment for and on behalf of sellers, service providers or

creditors; (4) provision of a service of transferring money by an electronic

means; (5) other provisions of the payment services which may affect the

financial system or public interest...é. As a virtual currency business, Libraûs

authorized resellers are not the types of business proscribed in Section 16, and
therefore the businesses are not subject to the payment service business

license requirements.

(34)
The Payment System Act B.E. 2560 (2017), <https://www.bot.or.th/English/AboutBOT/
LawsAndRegulations/SiteAssets/Law_E40_Payment.pdf> accessed 1 December, 2019.

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