being a majority of board directors. Any media outlets that registered were therefore forced to use complicated, expensive, and risky legal routes to register under the ownership of a figurehead Thai citizen. Thailand’s regulatory framework also required media outlets to acquire a special media license under one or more laws, including the Broadcasting and Television Business Act (2008), Publishing Act (2007), and Film and Video Act (2008). As a result, many media outlets operated clandestinely and faced significant legal risks as a result of operating unofficially. Individual journalists faced personal risks particularly from immigration laws.92 Thailand, for example, had not ratified the Convention Relating to the Status of Refugees (1951) and therefore did not fully recognize or protect the legal rights of Myanmar refugees who risked refoulement back to Myanmar or the constant need to bribe local officials. Several journalists were threatened with refoulement during the period under review, and some may have been refouled.93 At the same time, the Thai government has reportedly not allowed many journalists to leave Thailand for safe third countries, perhaps fearing that more refugees would come if they saw an “easy” escape route. 92 VOA (2022), “Future Remains Cloudy for Exiled Myanmar Journalists in Thailand”. 93 Reuters (2021), “Myanmar reporters, activists arrested in Thailand”. Assessing Detentions of Journalists in Myanmar, Feb. 2021 to Feb. 2025 32