D1 Sanctions
Sanctions is not yet covered for this jurisdiction in this report.
Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.
Financial Integrity Monitor
Cambodia KH
Domains (D1–D6)
2
Sources
11
Role actions
8
Jurisdiction profile
Largely CompliantTier BRisk: IncreasingPermissive
Cambodia operates under the 2020 AML/CFT Law and 2021 CDD Directive, supervised by CAFIU (FIU), the National Bank of Cambodia, and the Ministry of Economy and Finance.
Key deficiencies
- Limited regulation and oversight of casino, real estate and financial sectors exploited for laundering scam proceeds
- No comprehensive public beneficial ownership registry; shell-company layering (100+ entities in the Prince Group case) obscures true ownership
- Weak fit-and-proper and risk-based supervision of DNFBPs per successive APG follow-up reports
- Elite/political protection of scam-compound operators (senators, oknha, family ties to senior officials) undermining domestic prosecution
- No dedicated virtual asset service provider (VASP) licensing/supervision regime commensurate with the scale of crypto-enabled fraud
Recent developments (18m)
- October 14, 2025: coordinated OFAC/OFSI/DOJ/FinCEN action - Prince Group TCO designation (146 targets), Chen Zhi indictment, $15bn bitcoin forfeiture, Huione Group Section 311 final rule
- January 2026: Chen Zhi arrested in Cambodia and extradited to China rather than the United States
- April 23, 2026: OFAC designation of Cambodian Senator Kok An and 28 individuals/entities including Heng Feng Cambodia Bank
- June 2026: UK widened sanctions on additional Prince Group-linked individuals and London properties; OFAC added further Prince Group TCO designations and issued an OFAC-OFSI comparative guidance overview
Brief
Lead signal
Lead Signal
Domain intelligence (D1–D6)
D2 Beneficial Ownership
Beneficial Ownership is not yet covered for this jurisdiction in this report.
D3 Enabler Jurisdictions and Professional Facilitators
Enabler Jurisdictions and Professional Facilitators
Continue reading
Cambodia's casino sector has functioned as a node in the broader regional scam-compound financial infrastructure, and this cycle's enforcement activity is the clearest sign yet of state capacity being brought to bear on that enabler function. Under Royal Government Order No. 01 BB (14 July 2025), the CCOS Secretariat revoked 18 casino licences and suspended 9 further licences pending investigation for links to online scam activity. This is not an isolated case-by-case action: it is a batch revocation targeting a named cohort of facilitators, which is the structural signature of an enabler-jurisdiction correction rather than routine licensing housekeeping.
The second enforcement thread reinforces this reading. The CCTC Secretariat, working with the CGMC, confirmed that 24 casinos across Preah Sihanouk (12), Banteay Meanchey (7) and Svay Rieng (5) had ceased online and live-streamed casino betting, football betting, digital lotteries and virtual-cockfighting products by a 30 September 2026 deadline. The specific products targeted — online and proxy-streamed betting channels rather than land-based gambling for foreign patrons — are precisely the product forms most associated with cross-border money flows of unclear origin, the kind of flow that an enabler jurisdiction's casino sector is positioned to launder or obscure. Officials' framing of the driver as difficulty monitoring money of unclear origin is itself a structural admission: the online/proxy channel had outpaced the state's monitoring capacity, and the response has been prohibition rather than enhanced monitoring.
A third, adjacent signal strengthens the enabler-correction reading further. The National Bank of Cambodia revoked the payment-institution licence of Tian Xu International Technology Plc (CoolCash Cambodia), the sixth such revocation in nine months. Payment institutions are a frequent secondary facilitator layer in enabler-jurisdiction architectures, moving funds between casino, gambling-adjacent, and scam-compound actors. A sustained pattern of six revocations in nine months — rather than a single action — indicates this is a supervisory policy shift, not an isolated enforcement event.
The enablement-as-signal principle cuts in Cambodia's favour here: the absence of continued permissiveness is itself the finding. Where enforcement does not occur, that absence is analytically significant; here, enforcement has occurred at scale, across three provinces, against 24 venues and 27 licences (18 revoked, 9 suspended), which is itself the signal that the enabler-correction thesis should be taken seriously rather than dismissed as performative. That said, the underlying scam-compound financial infrastructure that the casino sector has served is unlikely to be fully dismantled by casino-side licence action and an online-betting prohibition alone; displacement to unlicensed or cross-border channels remains a live possibility that this cycle's evidence cannot rule out.
Outlook
The binding constraint going forward is less likely to be policy will and more likely to be enforcement capacity and displacement risk. Watch for whether a primary CCOS, CCTC or CGMC gazette notice is published to corroborate the press-reported enforcement narrative with an actual instrument text, and whether the 18 revoked and 9 suspended licences are followed by further revocations as investigations conclude. Also watch whether the sixth payment-institution licence revocation in nine months is followed by a seventh, which would confirm a sustained supervisory policy rather than a cluster of unrelated actions.
D4 Conflict Finance
Conflict Finance is not yet covered for this jurisdiction in this report.
D5 Crypto, Digital Assets, and Financial Innovation
Crypto, Digital Assets, and Financial Innovation
Continue reading
Cambodia's virtual-asset supervisory architecture is undergoing its most material shift since the 2024 interim Prakas. The National Bank of Cambodia and the Securities and Exchange Regulator of Cambodia issued a joint statement, dated 23 September 2026, establishing a dual-gateway supervisory intent: NBC-licensed banks require NBC prior approval for crypto-asset activity, while non-bank entities offering virtual-asset services will require a separate SERC licence. This is a structural finding, not an incident — it signals an institutional re-allocation of supervisory authority between the banking regulator and the securities regulator, ahead of a comprehensive Law on the Management of Virtual Assets and Digital Assets targeted for completion by end-2026.
The joint statement explicitly cites money-laundering risk as a driver for the forthcoming framework, which is a notable instance of CTF/CPF-adjacent reasoning being foregrounded in a licensing-architecture announcement rather than appearing only after an enforcement incident. This correction for the usual AML-volume bias is worth naming explicitly: regulators frequently cite money-laundering risk reactively, after a scandal; here it is being cited proactively, as a design principle for a dual-licensing gateway that does not yet exist in binding form.
The practical effect, until the comprehensive law is enacted, is an extension of the existing interim regime under Prakas B7-024-735 rather than its replacement. That Prakas already requires non-bank entities providing crypto-asset services to hold an NBC licence; the 23 September joint statement signals that this licensing function may migrate toward SERC for non-bank entities specifically, while banks remain under NBC's direct approval process. This bifurcation — bank-channel crypto exposure supervised by the banking regulator, non-bank CASP activity supervised by the securities regulator — is architecturally significant for compliance teams mapping counterparty risk: a Cambodia-facing crypto counterparty's regulatory status now depends on which regulator will ultimately hold its licence, a question the joint statement raises but does not yet resolve.
This development also sits adjacent to the casino-sector enforcement activity described elsewhere this cycle. Online gambling products and virtual-asset activity can share overlapping payment and settlement rails, and a tightening of the virtual-asset licensing perimeter at the same time as a crackdown on online casino betting products is consistent with a broader supervisory push against unmonitored money flows generally, rather than two unrelated policy tracks.
Outlook
The comprehensive Law on the Management of Virtual Assets and Digital Assets, targeted for completion by end-2026, is the development to watch. Its content will determine whether the dual-gateway supervisory intent in the 23 September joint statement becomes binding statute, whether existing Prakas B7-024-735 licensees are grandfathered or required to re-apply under the new framework, and whether the money-laundering-risk rationale cited in the joint statement translates into specific CASP due-diligence or reporting obligations. Compliance functions with Cambodia-facing virtual-asset exposure should treat the current period as transitional and avoid assuming the existing NBC-only licensing gateway will persist unchanged.
D6 Compliance Technology & Active Defence
Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.
D7 AML/CTF Regime
AML/CTF Regime is not yet covered for this jurisdiction in this report.
D8 Commercial Activity
Commercial Activity is not yet covered for this jurisdiction in this report.
Regulatory horizon
No dated horizon items this cycle. 3 items tracked without a confirmed date.
3 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLRO
Cambodia casino-sector licence revocations and online-betting cessation confirm an active enforcement channel relevant to STR filing triggers for casino-linked counterparties.
The revocation of 18 casino licences and suspension of 9 more for links to online scam activity, alongside confirmed cessation of online/proxy betting at 24 venues, raises the materiality of any existing exposure to Cambodian casino counterparties and should inform ongoing monitoring of related customer relationships.
2 evidence refs
Compliance
NBC-SERC joint statement signals an imminent dual-gateway licensing re-draw for virtual-asset activity in Cambodia.
Compliance functions with Cambodia-facing crypto-asset or payment-institution relationships should note the 23 September 2026 joint statement and the sixth payment-institution licence revocation in nine months as indicators of a tightening supervisory environment that may require updated counterparty due diligence.
2 evidence refs
Legal
No material change this cycle.
No material change for this persona this cycle
Board
Cambodia's casino and payments sectors are under sustained, escalating enforcement pressure relevant to any regional exposure.
The combination of 18 casino licence revocations, a confirmed sector-wide online-betting cessation, and a sixth payment-institution licence revocation in nine months indicates a structural tightening of Cambodia's financial-crime enforcement posture, material to any institution with regional exposure to Cambodian casino or payment counterparties.
3 evidence refs
CTO
NBC-SERC joint statement signals a prospective dual-gateway crypto-licensing architecture with unresolved institutional allocation.
Technical teams supporting Cambodia-facing crypto infrastructure should anticipate a possible re-allocation of licensing authority between NBC (banks) and SERC (non-bank entities) under a comprehensive digital-asset law targeted for end-2026, which may require architecture changes to counterparty onboarding and licence-status verification.
1 evidence refs
Risk
Cambodia's casino-enabler risk architecture and virtual-asset supervisory perimeter are both tightening simultaneously this cycle.
The convergence of casino licence revocations, a sector-wide online-betting cessation, a sixth payment-institution licence revocation, and a prospective dual-gateway crypto licensing regime together indicate an escalating, structural risk-exposure profile for any counterparty network touching Cambodian casino, payment, or virtual-asset channels.
4 evidence refs
Operations
No material change this cycle.
No material change for this persona this cycle
Audit
Enforcement findings this cycle rest on press reporting of official statements rather than a published primary gazette instrument.
Audit teams should note that the casino licence-revocation and online-betting cessation findings, while government-attributed, have not been independently corroborated against a published CCOS, CCTC or CGMC gazette notice this cycle, which affects the strength of documentary evidence available for control-testing purposes.
2 evidence refs
Decision lens
MLRO
Cambodia casino-sector licence revocations and online-betting cessation confirm an active enforcement channel relevant to STR filing triggers for casino-linked counterparties.
Compliance
NBC-SERC joint statement signals an imminent dual-gateway licensing re-draw for virtual-asset activity in Cambodia.
Legal
No material change this cycle.
Board
Cambodia's casino and payments sectors are under sustained, escalating enforcement pressure relevant to any regional exposure.
CTO
NBC-SERC joint statement signals a prospective dual-gateway crypto-licensing architecture with unresolved institutional allocation.
Risk
Cambodia's casino-enabler risk architecture and virtual-asset supervisory perimeter are both tightening simultaneously this cycle.
Operations
No material change this cycle.
Audit
Enforcement findings this cycle rest on press reporting of official statements rather than a published primary gazette instrument.
Shared evidence: 4 refs
Scenario sketches
AMLA direct-supervision transition and cross-border obliged-entity evasion
Illustrative orientation only: as the Anti-Money Laundering Authority (AMLA, under Reg (EU) 2024/1620) moves toward direct supervision of a defined set of high-risk cross-border obliged entities, alongside the directly-applicable AML Regulation (Reg (EU) 2024/1624) and per-Member-State transposition of the sixth AML Directive, the supervisory perimeter for large cross-border groups could shift from a purely national to a hybrid EU-level model. One illustrative possibility is that entities currently structured to exploit divergent national supervisory intensity across Member States could face a narrower arbitrage window as AMLA's direct-supervision list is finalised, potentially prompting a reactive restructuring of group compliance functions toward jurisdictions expected to remain under indirect (national) supervision for longer. This is a structural illustration of the architecture's possible effects, not an observed development or a prediction of which entities or states will be affected.
Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.
Standing trackers (T1–T6)
| Tracker | Status | Note |
|---|---|---|
| T1 · Russian Sanctions-Evasion Architecture | stable | No material KH-linked development this cycle. |
| T2 · EU AML Package / AMLA | no_change | Not applicable to KH (non-EEA). |
| T3 · FATF Grey List | stable | Cambodia removed from FATF grey list Feb 2023; no new plenary action affecting KH located this cycle. |
| T4 · Beneficial-Ownership Register Status | stable | No KH-specific BO-registry development located this cycle. |
| T5 · Crypto & Digital-Asset Integrity | material_change | NBC-SERC 23 Sep 2026 joint statement signals an imminent dual-licensing gateway for virtual-asset activity and a comprehensive digital-asset law targeted for end-2026, explicitly citing money-laundering risk. |
| T6 · Sanctions Regime Divergence | stable | US/UK/EU sanctions actions against Cambodia-linked scam networks remain broadly convergent rather than divergent this cycle; no new KH-specific designation located. |
Registers
Enforcement actions
- Coordinated designation of the Prince Group TCO and Chen Zhi under Global Magnitsky/TCO authority, alongside a DOJ wire-fraud/money-laundering indictment of Chen Zhi and the largest-ever US civil forfeiture (127,271 BTC, ~$15bn), plus a FinCEN Section 311 final rule against Huione Group. 14 Oct 2025
- UK coordinated sanctions under the Global Human Rights Sanctions Regulations 2020 against the Prince Group network operating Cambodia-based scam centres, freezing a £12m North London mansion and other UK assets. 14 Oct 2025
- Final rule under Section 311 of the USA PATRIOT Act imposing a special measure severing Cambodia-based Huione Group's access to the US financial system, following a May 2025 NPRM finding it a primary money-laundering concern. 14 Oct 2025
- OFAC designated Cambodian senator Kok An's business empire and network under E.O. 13694/14390 for operating scam compounds tied to at least $73 million laundered from US victims, including direct control of a Cambodian bank. 23 Apr 2026
- Cambodia's interior ministry arrested Chen Zhi in early January 2026 following his sanctioning and US indictment, and extradited him to China rather than to the United States, which held the outstanding criminal indictment. 8 Jan 2026
- UK widened its Prince Group sanctions package, adding further individuals identified operating under multiple aliases and freezing additional London properties including a £9m penthouse, building on the October 2025 designations. 1 Jun 2026
Sanctions changes
- OFAC designated the Prince Group Transnational Criminal Organization and 146 associated Cambodia-linked targets under Global Magnitsky/TCO sanctions authority, later expanded with 25 additional bitcoin addresses. 14 Oct 2025
- UK Global Human Rights sanctions regime listed Prince Group, Jin Bei Group, Golden Fortune Resorts, Byex Exchange and named individuals (Chen Zhi et al.), coordinated with the US action of the same date. 14 Oct 2025
- OFAC designated Cambodian senator Kok An and 28 individuals/entities including Heng Feng Cambodia Bank for operating scam-compound and money-laundering infrastructure. 23 Apr 2026
- UK widened its Prince Group-related sanctions list to add Hu Xiaowei and other alias-holding individuals, plus associated UK companies and properties. 1 Jun 2026
- As of the December 2025 EU high-risk third country delegated regulation update (EU 2026/46, EU 2026/83), Cambodia remains absent from the EU AML high-risk list, and no EU autonomous sanctions regime designation of Cambodia-linked scam-network entities has been identified, in contrast to the coordinated US/UK action. 4 Dec 2025
Regulatory horizon (register)
- FinCEN final rule on H-Pay Service PLC / Huione successor entities
- Next FATF Plenary review point for Cambodia AML/CFT standing
- Next periodic EU high-risk third country list update
Active schemes
- [CRITICAL] Cambodia scam-compound pig-butchering crypto fraud complex
- [CRITICAL] Huione Group crypto-fiat guarantee-marketplace laundering hub
- [HIGH] DPRK cyber-heist to crypto laundering corridor via Cambodia
- [HIGH] Elite patronage network monetising extractive-industry corruption
- [HIGH] Citizenship-for-sale and shell-layering BO opacity exploitation
Sources
Coverage gaps
Evidence
Confidence-tiered claims
18 casino licences revoked and 9 further licences suspended pending investigation for links to online scam activity, under Royal Government Order No. 01 BB (14 July 2025). SRC-fim-KH-001
Probable · 1 source24 casinos across Preah Sihanouk (12), Banteay Meanchey (7) and Svay Rieng (5) confirmed to have ceased online/live-streamed casino betting, football betting, digital lotteries and virtual-cockfighting products after a 30 September 2026 deadline. SRC-fim-KH-003
Probable · 1 sourceNBC and SERC issued a joint statement (23 September 2026) establishing a dual-gateway supervisory intent for virtual-asset activity - NBC-licensed banks need NBC prior approval, non-bank entities need an SERC licence - explicitly citing money-laundering risk, ahead of a comprehensive Law on the Management of Virtual Assets and Digital Assets targeted for completion by end-2026. SRC-fim-KH-002
Probable · 1 sourceNBC revoked the payment-institution licence of Tian Xu International Technology Plc (CoolCash Cambodia), the sixth such payment-institution licence revocation in nine months. SRC-fim-KH-004
Uncertain · 1 sourceCambodia remains off the FATF grey list (removed February 2023); no new plenary action affecting Cambodia located within this cycle's window. SRC-fim-GLOBAL-001
Probable · 1 source