Cambodia Compliance Report

Generated 2026-09-22

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Key Regulator(s): Bank of Cambodia, Ministry of Economy and Finance, National Coordination Committee for AML, Council of Ministers, General Secretariat of the National Council for AML, Securities and Exchange Commission of Cambodia
Primary Legislation: AML/CFT Law, Prakas on the Implementation of the Law on Anti-Money Laundering and Combating t, While not specific to crypto licensing, this law would form the basis for any fu, Regulations, This law is foundational for financial crime prevention. You would typically fin, Law on Banking and Financial Institutions: Provides the NBC with powers to regul, Cambodia has not enacted a dedicated cryptocurrency or digital asset law as of 2025, Cambodia's Law on Investment, enacted in 2021, offers incentives such as 100 per, Sub-Decree No. 139 ANK.BrK dated 26 June 2023 implements the Law on Investment a, The CDC lists laws including the Law on Commercial Enterprises (2005), the Law o, Cambodia's Law on Investment offers incentives including corporate tax holidays,
Travel Rule: Not adopted
Tax Reporting: The National Bank of Cambodia (NBC), in conjunction with the Securities and Exchange Commission of Cambodia (SECC) and the National Police, has repeatedly issued warnings against the use and trading of cryptocurrencies, stating that they are unauthorized and illegal in Cambodia for payment and investment purposes. These warnings emphasize risks such as fraud, money laundering, and financial instability. This regulatory stance underpins the lack of specific tax recognition.. None currently exists. Cambodia does not have specific laws or regulations defining cryptocurrency as a taxable asset class (e.g., property, currency, security) or outlining specific tax treatments for various crypto-related activities (e.g., mining, staking, trading, airdrops).. Cambodia does not have a standalone "capital gains tax" in the same way many Western countries do for all asset classes.. However, capital gains derived from certain sources are subject to taxation under the "Tax on Income" (often referred to as profit tax for companies, and covers various income for individuals).. Real Estate: Gains from the sale of immovable property are explicitly taxed.

Key Facts

aml Prohibition on Issuance, Trading, and Use: In May 2018, the NBC, in collaboration with the Securities and Exchange Regulator of Cambodia (SERC) and the General-Commissariat of National Police, issued a joint public announcement prohibiting financial institutions and the public from buying, selling, or trading cryptocurrencies. Legal Reference: Joint Public Announcement on the Management of Digital Currency (May 2018) by the National Bank of Cambodia, Securities and Exchange Commission of Cambodia, and the General-Commissariat of National Police. (Direct English URL often difficult to find; commonly cited as "Joint Announcement on Digital Currency, 2018"). A summary is often found on the NBC's press releases or official statements section, for example: National Bank of Cambodia - Press Release on Digital Currency (though this is more a general warning, the joint announcement is the key document). Direct Obligation: Cambodia is a UN member state and is legally bound to implement sanctions imposed by the UN Security Council Resolutions (UNSCRs). This includes resolutions targeting terrorism financing, proliferation financing (e.g., related to WMDs), and specific individuals, entities, and regimes. Compliance for VASPs (Hypothetical): If a VASP were operating in or with Cambodia (even if unofficially or cross-border), it would be expected to screen against the UN Consolidated List. Legal Reference: Law on Anti-Money Laundering and Combating the Financing of Terrorism (2020) (known as the AML/CFT Law). This law serves as the primary domestic legal framework for implementing UN sanctions, especially concerning asset freezing and reporting obligations. A full English version is often difficult to find publicly with a direct URL. It's often referenced as "Law on Anti-Money Laundering and Combating the Financing of Terrorism, Adopted on 26 June 2020 by the National Assembly of Cambodia, Ratified on 15 July 2020 by the Senate, Promulgated by Royal Kram No. NS/RKM/0720/009 dated 15 July 2020." UN Consolidated List: https://www.un.org/securitycouncil/sanctions/un-sc-consolidated-list
custody "The issuance, circulation, and trading of cryptocurrencies and other virtual currencies in Cambodia are illegal activities." It warned the public against engaging in such activities, citing risks of fraud, money laundering, and financial instability. It explicitly stated that "any person or entity that issues, circulates, or trades cryptocurrencies or other virtual currencies without obtaining a license from the National Bank of Cambodia and other relevant authorities, shall be prosecuted in accordance with the applicable laws of the Kingdom of Cambodia." There are no specific custodial licenses for cryptocurrencies/digital assets in Cambodia because the underlying activities (issuance, circulation, trading) are deemed illegal if not authorized by NBC. Since NBC has not authorized private cryptocurrency activities, no licensing mechanism exists for custody. Segregation of Client Assets Rules: Not applicable, as there are no licensed crypto custodians. There is no legal definition of a "qualified custodian" specifically for cryptocurrencies in Cambodia. Joint Press Release on the Illegality of Unauthorized Trading Activities of Cryptocurrencies (National Bank of Cambodia, Securities and Exchange Commission of Cambodia, and General Commissariat of National Police, May 11, 2018):
enforcement Reiteration of the existing ban and public warnings. General law enforcement actions against fraud or illegal activities that might involve cryptocurrencies, rather than specific regulatory actions for crypto-specific violations. Regulator Name: National Bank of Cambodia (NBC), Securities and Exchange Regulator of Cambodia (SERC), General-Commissariat of National Police (jointly issued original ban). Entity Targeted: The general public, unauthorized individuals/entities attempting to circulate, trade, or develop cryptocurrencies. Violation Type: Circulating, trading, mining, or using unauthorized virtual currencies, which are not recognized as legal tender or financial products in Cambodia. Penalty Amount: Not applicable for public warnings. Criminal penalties would apply for engaging in illegal financial activities or fraud. Date: The original ban was issued in 2018/2019. Warnings have been continuously reiterated, including within the last three years. Example of recent reinforcement (2022): The NBC Governor reinforced the ban and warned against the risks of digital assets in various forums. Example of ongoing concern (2023-2024): Cambodian authorities continue to monitor and warn against the use of unauthorized digital assets, often linking it to broader financial stability and anti-money laundering efforts. Outcome: Continued public awareness campaigns and maintenance of the ban, aiming to prevent the adoption and use of cryptocurrencies in the country.
general Would likely be substantial, similar to other financial institutions, to ensure financial stability and solvency. For traditional Payment Service Providers, capital requirements vary based on the scope of services. For example, a basic payment service license might require less than a full-fledged bank. This is the most certain requirement. Cambodia has a comprehensive Law on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT Law). The Cambodian Financial Intelligence Unit (CAFIU) is the key body here. Any future VASP framework would demand strict compliance with FATF recommendations for VASPs, including: Customer due diligence (CDD) procedures. Reporting of suspicious transactions (STRs) to CAFIU. Robust internal AML/CFT policies and procedures. Potentially, adherence to the FATF "Travel Rule" for crypto transfers.
licensing Law on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT Law): Date: Passed in 2020. This law replaced the previous 2007 AML/CFT Law and was enacted to bring Cambodia's framework closer to international standards, particularly the FATF Recommendations. Key Provisions: Defines money laundering and terrorist financing offenses, establishes the legal framework for identifying, verifying, and reporting suspicious activities, and outlines penalties for non-compliance. It also identifies "reporting entities" (or "obliged entities") that must comply. VASPs, by the nature of their services, are generally considered reporting entities under this broad definition, especially concerning the movement of value. Prakas on the Implementation of the Law on Anti-Money Laundering and Combating the Financing of Terrorism (Prakas 285 on AML/CFT) Issuing Body: National Bank of Cambodia (NBC) and the Ministry of Economy and Finance. Date: Issued in 2020. Key Provisions: Provides detailed regulations and guidelines for financial institutions and other reporting entities (which would encompass VASPs) on how to implement the AML/CFT Law, including specific requirements for customer due diligence, suspicious transaction reporting, and record-keeping. For Individuals: Obtaining and verifying proof of identity (e.g., national ID card, passport, driver's license), date of birth, address, and nationality.
securities Cambodia does not have a dedicated cryptocurrency or digital asset securities law; the Securities and Exchange Regulator of Cambodia (SERC) oversees the securities sector under the existing securities legal framework, and digital assets that qualify as securities fall under SERC's jurisdiction. Securities and Exchange Regulator of Cambodia - SERC The primary regulator is the Securities and Exchange Regulator of Cambodia (SERC), operating under the Non-Bank Financial Services Authority (FSA) chaired by the Deputy Prime Minister and Minister of Economy and Finance. Securities and Exchange Regulator of Cambodia - SERC While SERC actively licenses and supervises securities market participants — including securities firms, fund management companies, and introducing agents — no entity has been publicly announced as licensed specifically for cryptocurrency or digital asset securities activities. Securities and Exchange Regulator of Cambodia - SERC The practical reality is that Cambodia's securities regulator has not yet established a crypto-specific licensing regime or published guidance for digital asset securities, leaving businesses in a state of regulatory uncertainty. Securities and Exchange Regulator of Cambodia - SERC The SERC continues to focus on traditional securities market development, including bond listings, equity public offerings, and investor education, with no crypto-specific announcements or approvals visible through 2026. Securities and Exchange Regulator of Cambodia - SERC The Securities and Exchange Regulator of Cambodia (SERC), formerly the Securities and Exchange Commission of Cambodia (SECC), is the government authority responsible for the regulation and supervision of the securities sector in Cambodia. Securities and Exchange Regulator of Cambodia - SERC The SERC operates under the Non-Bank Financial Services Authority (FSA) framework, with the FSA Council chaired by H.E. Dr. Aun Pornmoniroth, Deputy Prime Minister, Minister of Economy and Finance of Cambodia. Securities and Exchange Regulator of Cambodia - SERC The Director General of SERC is H.E. SOU Socheat, Delegate of the Royal Government in Charge, with H.E. SEANG Thirith serving as Deputy Director General. Securities and Exchange Regulator of Cambodia - SERC
status Cambodia has not enacted a dedicated cryptocurrency or digital asset law as of 2025–2026, and no specific legislation governing virtual assets has been enacted. - Cambodia - United States Department of State No licensing authority for crypto businesses has been identified, and no entity has been licensed to operate a cryptocurrency exchange or digital asset service in Cambodia. - Laws and Regulations – The Council for the Development of Cambodia (CDC) Cambodia was removed from the FATF "grey list" in February 2023, indicating progress on AML/CFT standards, but this does not equate to a crypto-specific regulatory framework. - Cambodia - United States Department of State The practical reality is that cryptocurrency activity operates in a legal vacuum without explicit authorization or prohibition under the documents reviewed, creating significant uncertainty for businesses. - Cambodia - United States Department of State The CDC maintains a Laws and Regulations repository organized by categories including Financial Sector, Foreign Exchange, Taxation and Accounting, and Business, but no listed documents address digital assets or cryptocurrency. - Laws and Regulations – The Council for the Development of Cambodia (CDC) Cambodia's Law on Investment, enacted in 2021, offers incentives such as 100 percent foreign ownership, corporate tax holidays, and duty-free import of capital goods, but it does not cover digital assets. - Cambodia - United States Department of State Sub-Decree No. 139 ANK.BrK dated 26 June 2023 implements the Law on Investment and is the most recent regulation listed by CDC, with no mention of virtual assets. - Laws and Regulations – The Council for the Development of Cambodia (CDC) The FATF called on Cambodia to sustain improvements in its AML/CFT system following the delisting. - Cambodia - United States Department of State
tax The National Bank of Cambodia (NBC), in conjunction with the Securities and Exchange Commission of Cambodia (SECC) and the National Police, has repeatedly issued warnings against the use and trading of cryptocurrencies, stating that they are unauthorized and illegal in Cambodia for payment and investment purposes. These warnings emphasize risks such as fraud, money laundering, and financial instability. This regulatory stance underpins the lack of specific tax recognition. None currently exists. Cambodia does not have specific laws or regulations defining cryptocurrency as a taxable asset class (e.g., property, currency, security) or outlining specific tax treatments for various crypto-related activities (e.g., mining, staking, trading, airdrops). Cambodia does not have a standalone "capital gains tax" in the same way many Western countries do for all asset classes. However, capital gains derived from certain sources are subject to taxation under the "Tax on Income" (often referred to as profit tax for companies, and covers various income for individuals). Real Estate: Gains from the sale of immovable property are explicitly taxed. Shares/Securities: Gains from the sale of certain shares or securities can be taxed. For Individuals: If an individual sporadically trades crypto and realizes a gain, it is highly ambiguous whether this would be explicitly taxed as capital gain given the current laws. There's no clear mechanism to tax personal capital gains outside of specific asset classes like real estate. For Businesses: If a business (e.g., a company, sole proprietorship) regularly trades or invests in crypto as part of its operations, any profits (capital gains) from these activities would likely be included in the company's overall taxable income and subjected to the Tax on Profit.
travel rule Not explicitly adopted for VASPs: Cambodia has not yet enacted specific legislation or regulations that define VASPs according to FATF standards, license them, and mandate the Travel Rule requirements directly for them. The existing AML/CFT framework (primarily the Law on Anti-Money Laundering and Combating the Financing of Terrorism) applies generally to financial institutions and designated non-financial businesses and professions (DNFBPs). However, without a clear classification and licensing of VASPs, the Travel Rule cannot be practically enforced against them. The National Bank of Cambodia (NBC) has primarily focused on regulating payment service providers (PSPs) and issuing warnings against unregulated cryptocurrency activities, rather than establishing a comprehensive VASP licensing regime. Since there is no explicit Travel Rule implementation for VASPs, there are no specific Travel Rule threshold amounts adopted in Cambodia (e.g., the FATF recommended USD/EUR 1,000 threshold for originator/beneficiary information sharing). General AML/CFT laws would have thresholds for suspicious transaction reporting (STR) or large cash transactions, but these are distinct from the Travel Rule's specific data-sharing requirements for virtual asset transfers. As there is no specific VASP licensing framework, there are no officially recognized and regulated VASPs explicitly covered by a Travel Rule mandate in Cambodia. Any entities operating with virtual assets in Cambodia generally fall into an unregulated gray area. Some payment service providers (regulated by the NBC under different frameworks) might facilitate fiat-to-crypto on-ramps/off-ramps, but they are regulated as PSPs, not specifically as VASPs under a digital asset-specific regime. Without a specific VASP regulation or Travel Rule mandate, there are no defined technical implementation requirements for VASPs in Cambodia. Globally, technical solutions for the Travel Rule involve secure, auditable, and interoperable data transfer protocols between VASPs (e.g., TRP, OpenVASP, Sygna, Travel Rule Protocol).

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-09. View full profile