800K two months before and 3 months after = 5 months. The point of it is to (maybe) identify those who pay agents for the loan and at a cost. I understand that borrrowing money is not a crime, but the interest cost of holding it a further 3 months (=c.10k extra at c.5%) will adversely affect some who do not have the necessary funds.
But that does seem unfair and heavy-handed. From the article, you could still use the combination method, if that's a better option and probably that flexibility will become the most favoured.
For example, 400k stuck in a Thai bank account for one year, earning interest of 8k, plus income of 33k per month sent to a Thai bank account.