Two problems remain after the licences are in hand and the laboratory report is clean. The money has to reach Thailand through a banking system that does not want to touch this sector, and the goods have to reach the buyer without passing through a jurisdiction that would treat them as contraband. Both can be solved. Both are usually solved in the wrong order: after the contract is signed, rather than before the currency and the Incoterm are chosen.
The Thai legal basis comes first. Cannabis flower is a controlled herb under the Notification of the Ministry of Public Health Re: Controlled Herbs (Cannabis) B.E. 2568, issued 26 June 2025. Exporting it requires a permit, and exported flower must come from a GACP-certified cultivation site. The Cannabis Control Act is still a draft: Cabinet approved it on 22 September 2026 and sent it to the House. Everything below assumes that licence chain is already in place.
1. The banking position in Thailand, stated as it is
This research found no Bank of Thailand or AMLO circular on cannabis-sector banking. There is no Thai equivalent of the US FinCEN marijuana guidance. What exists is each bank’s own risk policy, and those policies are consistent. A 2025 analysis by ILAWASIA on Legal 500, “In-depth analysis of the risk of doing cannabis business in Thailand and strategies for mitigation” (In depth Analysis of the Risk of Doing Cannabis Business in Thailand and Strategies for Mitigation – Legal Developments), calls cannabis a “no-bank” sector. It says commercial banks typically refuse financing, credit facilities or lending to cannabis operators on compliance and reputational grounds.
A published rule can be complied with. An unpublished risk appetite can only be navigated, and it can change without notice.
2. The currency decision, which is the highest-leverage choice available
US federal status as of October 2026 (check current status before relying on this): The December 2025 executive order directed rescheduling. After it, the DEA moved two categories to Schedule III: marijuana in FDA-approved products and state-licensed medical marijuana. That final order was published in the Federal Register on 28 April 2026. All other marijuana remains in Schedule I, and broader rescheduling is still pending after a DEA administrative hearing. The banking argument holds under either schedule. Making, importing or distributing cannabis without DEA registration is still a federal crime, so a US bank may treat the proceeds as potentially unlawful for money-laundering purposes.
This matters because most USD wires clear through US correspondent banks. A payment from a German importer to a Thai exporter, with no US party involved, can still pass through a US institution. Some USD clearing happens offshore (Hong Kong’s USD CHATS is one example), but offshore clearing banks run their own sanctions and AML screening. Plan for three things:
- funds frozen or returned in flight
- a suspicious activity report
- your own bank’s compliance team discovering your sector at a moment it chooses, not you
To be precise about the evidence: the mechanism is standard correspondent-banking law, but no published US enforcement action against a correspondent bank for a foreign-to-foreign legal-cannabis payment was found. It is a well-founded structural risk, not a documented precedent.
The mitigation is to settle in EUR, AUD, CHF or THB rather than USD. This reduces the risk but does not eliminate it. European and Australian banks run their own AML checks, and the receiving Thai bank still reviews the transaction. It is not free either: a non-USD invoice brings FX conversion costs and possibly hedging. Decide the currency before the price is quoted.
No bank or payment provider is named here as accepting cannabis-related payments. No credible source found says any does, and a name circulated informally is a liability rather than an asset.
3. Thailand’s foreign exchange rules: the threshold moved tenfold in January 2026
The repatriation exemption threshold rose from “less than USD 1 million” to “less than USD 10 million”:
- Export proceeds: Notification of the Ministry of Finance on Exchange Control (No. 11), in force 20 January 2026.
- Other foreign-sourced funds: Notice of the Competent Officer re: Rules and Practices regarding Currency Exchange (No. 35), in force 27 January 2026.
Source: Baker McKenzie, “Thailand: Repatriation Exemption for Foreign-Sourced Funds”, 18 February 2026 (Thailand: Repatriation Exemption for Foreign-Sourced Funds | Insight | Baker McKenzie). The Royal Gazette volume and publication date could not be independently confirmed for this article, so ask your authorised bank for the gazetted text. Below the threshold, Thai residents may keep and use funds offshore without approval.
Where the requirement applies, proceeds must be repatriated within 360 days of the export date. They must then be sold to an authorised bank or deposited in a foreign currency deposit (FCD) account with one.
The rule that actually bites is a different one. Transactions of USD 200,000 or more require supporting documents to be submitted to the authorised bank, unless the bank has completed know-your-business procedures (Bank of Thailand, “Exchange Control Regulation”, Exchange Control Regulation). That is the moment a compliance officer reads the product description. Have that conversation early and deliberately, with documents ready, rather than letting a wire trigger it.
One accuracy flag: that same Bank of Thailand page still showed the superseded USD 1 million figure when fetched in September and October 2026. Cite the notifications above and confirm with your bank rather than relying on the web page.
4. Payment instruments, and why a letter of credit is not the answer people expect
| Instrument | Exporter’s position | Realistic availability |
|---|---|---|
| Advance payment | Strongest for the exporter | The de facto norm in this sector |
| Letter of credit (UCP 600) | Bank-backed, but banks examine legality as well as documents | Frequently refused; assume unavailable unless confirmed in writing |
| Documentary collection D/P | No payment guarantee; goods can sit unclaimed | Cheap, but see below |
| D/A | Credit extended on acceptance | Avoid |
| Open account | Full credit risk | Established buyers only |
| Escrow | Neutral holder of funds | The agent has the same sector-risk problem as a bank |
A documentary credit is meant to be independent of the underlying contract (the autonomy principle), but that independence is not absolute in practice. A bank’s sanctions and AML obligations sit outside it, and an issuing or confirming bank can decline on compliance grounds even when the documents conform.
Documentary collection needs a specific warning. If the buyer walks away, ordinary cargo can be resold locally. A licence-gated controlled consignment cannot. No local buyer may lawfully take it, and it sits in bond, building up costs.
For a first shipment, a split advance tends to work best:
- a deposit on signature
- the balance against scanned shipping documents and the endorsed export authorisation
- payment in a non-USD currency
- the buyer clearly established as importer of record
5. Transit: the risk that has nothing to do with your buyer
Scope: this section covers only licensed commercial consignments moving under export and import authorisations. It is not guidance for personal, passenger or courier carriage, which is what the seizure figures in this article describe.
Goods that never enter a country’s commerce are still subject to its controlled-goods rules. Singapore Customs says the transhipment agent must get a Customs transhipment permit before arranging transhipment. It lists transhipping without a permit as an offence under regulation 3(1) of the Regulation of Imports and Exports Regulations. On first conviction, the penalty is a fine of up to S$100,000 or three times the value of the goods, whichever is greater, up to two years’ imprisonment, or both (“Transhipment Procedures Overview”, https://www.customs.gov.sg/doing-business/transhipment-operations/transhipment-procedures/transhipment-procedures-overview/). Singapore’s Misuse of Drugs Act also covers import and export, and trafficking more than 500 g of cannabis may attract the death penalty. This research could not confirm whether free-trade-zone transhipment counts as “import”, which is exactly why it should not be tested.
Hubs to route around, based on legal status and enforcement: Singapore, Dubai and Abu Dhabi, Doha, Hong Kong, Kuala Lumpur, Jakarta, the Saudi hubs and mainland Chinese hubs. Hong Kong Customs regularly publishes passenger seizures. On 20 April 2026, for example, it seized about 10 kg of suspected cannabis buds, worth about HK$2 million, from a passenger arriving from Bangkok via Hanoi (Hong Kong Customs seizes suspected cannabis buds worth about $2 million at airport (with photos)).
The useful question is not air versus sea. It is: how many sovereign jurisdictions does this consignment touch, and does each of them see a copy of the export authorisation? The 1961 Single Convention sets the transit rules in Article 31:
- Article 31(11): a Party shall not permit drugs consigned to another country to pass through its territory unless a copy of the export authorisation is produced to its authorities.
- Article 31(12): transit authorities must take all due measures to prevent diversion.
- Article 31(14): these transit rules do not apply when the consignment is carried by an aircraft that does not land in the transit country.
For controlled goods, one direct routing beats a cheaper two-stop routing.
6. Incoterms: why DDP is the wrong answer here
Under DDP the seller bears all costs and risks to the destination, including import clearance, duties and taxes. Under DAP the buyer clears import (ICC, Incoterms® 2020).
The import certificate for a narcotics-scheduled consignment is issued to the importer, in the importer’s name, by the importer’s national authority. A Thai exporter cannot be importer of record for a controlled substance in the EU or Australia. DDP would bind the seller to something the destination’s law forbids.
Appropriate terms:
- CIP or CPT for multimodal movements. Risk passes at handover to the first carrier, and the buyer clears import. CIP under Incoterms 2020 requires Institute Cargo Clauses (A) cover.
- DAP if the buyer wants delivered pricing but keeps import clearance.
Inappropriate terms:
- DDP, for the reason above.
- EXW, which leaves export formalities to the buyer, when only the Thai licence-holder may perform them.
- FOB, CFR or CIF for containerised or air cargo. This is a general Incoterms misuse, not one specific to cannabis.
7. The payment and transit failures that cause detention
- No copy of the export authorisation with the goods. Article 31(6) requires a copy to accompany each consignment. Article 31(10) provides that consignments entering or leaving a Party’s territory without an export authorisation “shall be detained by the competent authorities.”
- A transit state not shown a copy (Article 31(11)).
- Product description inconsistent across the invoice, packing list, air waybill and authorisation. Customs checks against the authorisation, and banks check the same documents before releasing payment.
- Quantity above the import certificate, or shipment outside the validity window of either certificate. The Convention does not itself say an excess voids the whole consignment, but importing authorities commonly refuse or hold such shipments. Check the destination country’s own rule.
Batch-number matching against the certificate of analysis, HS codes, phytosanitary scope and the licence chain are covered in the licence-chain and testing articles. Storage, drying and curing are covered in the forum’s separate guides.
For calibration: the Thai Customs Department reported 3,309 cannabis cases and more than 37,210 kg seized between 1 October 2025 and 30 June 2026, almost all of them attempted exports (Vietnam News Agency/VietnamPlus, 16 July 2026, Thailand, UK step up cooperation to combat illegal cannabis smuggling). These were passenger and courier cases. This research found no documented seizure of a properly Article 31-documented shipment in transit. Their relevance to a legitimate exporter is that Thai-origin consignments will be examined more closely than the same goods from Canada.
What has actually gone wrong on a shipment for people here: the money side or the movement side? The failure modes above are built from the rules, not from case files. One real account of a held consignment, a refused wire or a closed account would be worth more than the whole list.
Related reading: the licence-chain article on the Article 31 certificate pair, the certificate-of-analysis testing article, and the five-market comparison.
This article is reference information for readers operating legally in their own jurisdictions. It is not legal, banking, tax, customs or financial advice, and nothing here is a recommendation about any bank, payment method or route. Exchange-control thresholds, US scheduling, sanctions positions and narcotics law change frequently, and at least one official source consulted was out of date when this was written. Verify every figure with your authorised bank, your freight forwarder and qualified counsel before shipping or invoicing.