Vietnam’s Ministry of Public Security (MPS) recently published on its website a dossier of the Draft Law on Data (the “Draft Law”) for public feedback, initiating a consultation period from February 26 to March 26, 2024. The dossier comprises a Policy Impact Assessment Report and a Summary Report on the implementation of existing legal documents governing data. An outline of the Draft Law was later circulated to relevant organizations for their input and commentary. The MPS drafted this legislation with several objectives, including bolstering national data infrastructure, advancing digital government while streamlining administrative procedures, fostering growth in the digital economy and building a digital society, and establishing a National Data Center. Comprising 65 articles across 6 chapters, the Draft Law is slated for implementation on January 1, 2026. The Draft Law currently is very preliminary, resembling a framework document. It features numerous provisions akin to policy mandates, yet only presents introductory concepts without further elaboration. Scope of Application The Draft Law applies to agencies, organizations, and individuals involved in data activities in Vietnam. This scope of application appears excessively broad and ambiguous, without a clear definition of “data activities”, leaving uncertainty regarding the breadth of this term’s coverage. Key Policy Groups The Draft Law focuses on four key policy groups: 1. Regulations on development, processing, and management of data This policy group focuses on matters relating to the collection, digitalization, and creation of data; assurance of data quality; data classification; data storage; data combination, adjustment, and updating; data strategy; data management; data sharing; provision of data to state agencies; data analysis and synthesis; data verification and authentication; data disclosure; access and retrieval of data; data encryption and decryption; data copying, transmission, and transfer; data revocation, deletion, and destruction; application of science and technology in data processing; identification and management

On March 25, 2024, Thailand’s Securities and Exchange Commission (SEC) published an amendment to its Notification re: Public Digital Token Offering to strengthen governance for initial coin offerings (ICOs). The amendments took effect on April 16, 2024, and reflect the SEC’s commitment to creating a safer and more transparent ICO environment, enhancing investor protection, and building confidence in ICOs as a fundraising tool. The key changes are outlined below: New Checks and Balances Requirements The new regulations require digital token issuers to implement checks and balances to protect investor rights—including an annual audit requirement and measures to prevent and manage conflicts of interest. These measures must be clearly disclosed in the ICO filing documents. In addition, certain project-related decisions must be approved by the issuer’s board of directors, which is also responsible for the accountability of such decisions. Improved Rules Concerning Voting Rights The SEC has introduced rules concerning voting rights and procedures for digital token holders, particularly for token types that previously lacked regulatory clarity. These rules specify the procedures for soliciting votes, the rationale behind vote requests, and the criteria for determining voting outcomes. The new rules, however, do not apply to real estate-backed tokens or infrastructure-backed tokens. Enhanced Advertising Regulations The SEC has revised advertising guidelines to ensure that investors receive essential information. The updated rules now require all ICO advertising to be fair and informative and to avoid misleading content. Advertisements must include appropriate risk warnings and a credible source for any claims made. The notification also stresses that it is the responsibility of digital token issuers to strictly supervise and ensure that those who create advertisements with or for an issuer comply with all relevant advertising regulations, including the following: Warning of investment risk: Advertisements must include warnings about investment risks and contact information

On November 4, 2021, Cambodia’s Ministry of Mines and Energy (MME) issued a Prakas No. 0305 on Management of the Steam Energy Subsector within the Energy Sector. The prakas aims to regulate steam energy operations, and requires companies wishing to develop, build, install, or operate steam energy to apply for a steam energy license. As this is the first prakas regulating steam energy operations in Cambodia, all relevant companies operating in steam energy must apply for a steam energy license with the MME. Prakas 0305 discusses permits for three types of activities: Development, Construction, Installation, and Operation of Steam Energy. Companies wishing to develop, build, install, and operate steam energy production facilities must first apply for a permit from the MME. Steam Energy Service Provision. Companies wishing to develop, build, install, and operate steam energy for the purpose of supplying steam energy to consumers must apply for a permit for steam energy service provider in addition to a permit for development, construction, installation, and operation of steam energy. Two-in-One Steam Energy and Electricity Production. Companies wishing to develop and operate both steam energy and electricity production activities must also apply for a permit for two-in-one steam energy and electricity production. Companies operating without the necessary permits are subject to a daily fine of KHR 400,000–4,000,000 (approx. USD 100–1,000). In addition, they may face other penalties, including: An order to halt business activities; Permit suspension; Permit revocation; Judicial action; and Other legal measures as the MME deems fit. For more information on regulations and requirements for steam energy licenses in Cambodia, please contact Tilleke & Gibbins at [email protected].

On March 15, 2024, Thailand’s Board of Investment (BOI) updated its investment incentives for software development and data centers by issuing a regulation replacing the previous categories of software or platforms for digital services or content (category 8.1) and data centers (category 8.2.1). The new and updated categories are detailed below. Software and Platform Development Under the new promotion policy, the BOI has made separate subcategories for “development” and “improvement” of software or platforms, each with its own set of incentives. The BOI is expected to clarify the characteristics of these two activities in a forthcoming announcement. Qualifying development activities are eligible for a corporate income tax (CIT) exemption for eight years (capped), while improvement activities are not eligible for any CIT exemption. A number of adjustments have been made to the eligibility criteria for development of software and platforms for digital services or content. These include the following: Salary expenditures for Thai information technology (IT) personnel hired temporarily after applying for investment promotion can now be included in the calculation of total salary expenditures for Thai IT personnel hired subsequent to applying for investment promotion. Previously, only salary expenditures for permanently employed personnel could be included in this figure. The minimum salary expenditures for each project remain unchanged at THB 1.5 million per year. Similarly, salary expenditures for temporary hiring of Thai IT personnel can be included in calculating the actual expenditures in the year that the project would like to benefit from the CIT exemption. Projects must commence operations within 12 months of the promotion certificate being issued. No extensions are allowed. Projects are no longer allowed to extend the machinery importation period. The other eligibility criteria for development of software and platforms for digital services or content remain unchanged. Projects in the new BOI subcategory for