Cambodia -- Regulatory Status Regulatory Overview

Executive Summary

• 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
• The National Bank of Cambodia (NBC) functions as the central monetary authority, but no NBC-issued cryptocurrency licensing framework or registration regime has been documented. - 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

Regulatory Framework

• The Council for the Development of Cambodia (CDC) is the principal government agency responsible for providing investment incentives and serves as the secretariat to Cambodia's Government-Private Sector Forum (G-PSF), but it does not regulate cryptocurrency. - 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)
• The National Bank of Cambodia (NBC) is cited in the 2025 Investment Climate Statement for its inflation projections, confirming its role as the monetary authority, though no crypto mandate exists. - Cambodia - United States Department of State
• 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 Financial Action Task Force (FATF) removed Cambodia from its "grey list" of jurisdictions subject to increased monitoring in February 2023, after assessing that Cambodia had made progress in improving its AML/CFT regime. - Cambodia - United States Department of State
• The FATF called on Cambodia to sustain improvements in its AML/CFT system following the delisting. - Cambodia - United States Department of State
• The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce issued a conforming rule on February 4, 2026, removing Cambodia from Country Group D:5 (U.S. Arms Embargoed Countries) under the Export Administration Regulations (EAR), effective February 3, 2026, which is unrelated to crypto but reflects Cambodia's international standing. - Federal Register :: Conforming Change to the Export Administration Regulations for Cambodia
• Cambodia remains designated in Country Group D:1 under supplement no. 1 to part 740 of the EAR, with restrictions related to military and military-intelligence end uses remaining in place under sections 744.21 and 744.22. - Federal Register :: Conforming Change to the Export Administration Regulations for Cambodia
• The Federal Register's CFR Indexing Terms for Cambodia lists only two documents since 1994, both from the Office of Foreign Assets Control (OFAC) dated September 11, 2003, concerning civil penalties regulations under the Trading with the Enemy Act — neither relates to cryptocurrency. - Federal Register :: Topics (CFR Indexing Terms) - Cambodia
• Cambodia has four active bilateral and regional free trade agreements as of April 2025: the Cambodia-China Free Trade Agreement (CCFTA), the Cambodia-Korea Free Trade Agreement (CKFTA), the Cambodia-UAE Comprehensive Economic Partnership Agreement (CEPA), and the Regional Comprehensive Economic Partnership (RCEP). - Cambodia - United States Department of State
• The CDC lists laws including the Law on Commercial Enterprises (2005), the Law on Insolvency (2007), and the Law on Secured Transaction (2007), which may tangentially apply to digital asset businesses but do not constitute crypto-specific regulation. - Laws and Regulations – The Council for the Development of Cambodia (CDC)

Licensing Requirements

• No cryptocurrency or digital asset licensing regime has been identified. - Laws and Regulations – The Council for the Development of Cambodia (CDC)
• The National Bank of Cambodia has not been documented as issuing any license for crypto exchanges, wallet providers, or digital asset service providers. - Cambodia - United States Department of State
• The Council for the Development of Cambodia offers Qualified Investment Project (QIP) status to investors based on the amount of capital and location of the investment, with QIPs eligible for specific investment incentives, but this is a general investment mechanism, not a crypto license. - Cambodia - United States Department of State
• All businesses in Cambodia are required to register with the Ministry of Commerce (MOC), the General Department of Taxation (GDT), and the Ministry of Labor and Vocational Training (MOLVT), and the Ministry of Economy and Finance (MEF) launched a Single Portal in 2020 for online registration — this general business registration applies to all sectors but does not address crypto-specific licensing. - Cambodia - United States Department of State
• No capital requirements, application processes, timelines, or structural requirements for crypto licensing have been specified, because no such licensing framework exists. - Laws and Regulations – The Council for the Development of Cambodia (CDC)
• The CDC requires investors to submit an investment proposal to either the CDC or the Provincial-Municipal Investment Sub-committee to obtain QIP status, but this process applies to general investment, not digital asset activities. - Cambodia - United States Department of State
• No entity has been licensed to conduct cryptocurrency exchange, custody, or trading services in Cambodia. Zero entities have been licensed for crypto activities. - Cambodia - United States Department of State
• The CDC's "Checklist" and "Service Fee" documents relate to general investment applications and do not mention digital assets. - Laws and Regulations – The Council for the Development of Cambodia (CDC)
• Foreign investors may own 100 percent of investment projects except in sectors such as cigarette manufacturing, movie production, rice milling, and gemstone mining and processing, which require local equity participation — cryptocurrency is not listed among these restricted sectors. - Cambodia - United States Department of State

AML/KYC Requirements

• The Financial Action Task Force (FATF) removed Cambodia from its "grey list" of jurisdictions subject to increased monitoring in February 2023, after assessing that Cambodia had made progress in improving its AML/CFT regime. - Cambodia - United States Department of State
• FATF called on Cambodia to sustain the improvements in its AML/CFT system following the removal from the grey list. - Cambodia - United States Department of State
• No specific Cambodia AML/KYC requirements such as customer due diligence (CDD), enhanced due diligence (EDD), suspicious transaction reporting (STR), record retention periods, beneficial ownership rules, or PEP screening obligations for crypto businesses have been published. - Cambodia - United States Department of State
• The CDC's Financial Sector category and Foreign Exchange category list general financial regulations, but no documents address AML obligations for virtual asset service providers. - Laws and Regulations – The Council for the Development of Cambodia (CDC)
• The U.S. Department of the Treasury's Office of Foreign Assets Control announced Global Magnitsky sanctions in September 2024 against a Cambodian tycoon and four of his businesses for human rights abuses related to human trafficking and forced labor in online scam centers — this indicates awareness of financial crime risks but does not establish Cambodia-specific crypto AML rules. - Cambodia - United States Department of State
• Cambodia's AML/CFT system improvements were recognized by FATF in February 2023, but the specific content of those improvements has not been detailed. - Cambodia - United States Department of State

Enforcement Actions

• The Federal Register topics page for Cambodia lists two documents from the Office of Foreign Assets Control (OFAC) dated September 11, 2003, concerning civil penalties regulations under the Trading with the Enemy Act — these are general penalty regulations, not specific enforcement actions against crypto entities in Cambodia. - Federal Register :: Topics (CFR Indexing Terms) - Cambodia
• In September 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control announced Global Magnitsky sanctions against a Cambodian tycoon and four of his businesses for serious human rights abuses related to human trafficking and forced labor in online scam centers — this is a U.S. sanctions action, not a Cambodian enforcement action against a crypto business. - Cambodia - United States Department of State
• No records exist of Cambodian authorities imposing penalties, fines, arrests, or other enforcement actions specifically against cryptocurrency exchanges, wallet providers, or digital asset businesses. - Cambodia - United States Department of State
• In November 2021, the U.S. Departments of State, Treasury, and Commerce issued a business advisory to caution U.S. businesses operating in Cambodia to be mindful of interactions with entities involved in corrupt business practices, criminal activities, and human rights abuses — this advisory applies broadly to business conduct, not specifically to crypto enforcement. - Cambodia - United States Department of State
• The BIS final rule effective February 3, 2026, deleting Cambodia's "X" designation from Country Group D:5 addresses export control compliance and does not involve any enforcement action against crypto entities. - Federal Register :: Conforming Change to the Export Administration Regulations for Cambodia

Tax Treatment

• No tax guidance for virtual assets has been issued. - Laws and Regulations – The Council for the Development of Cambodia (CDC)
• The CDC's Taxation and Accounting category lists general taxation regulations, but no documents address the tax treatment of cryptocurrency gains, capital gains on digital assets, or VAT on crypto transactions. - Laws and Regulations – The Council for the Development of Cambodia (CDC)
• Cambodia's Law on Investment offers incentives including corporate tax holidays, reduced corporate tax rates, and duty-free import of capital goods for Qualified Investment Projects, but it is not indicated how these incentives would apply to digital asset businesses. - Cambodia - United States Department of State
• All businesses in Cambodia must register with the General Department of Taxation (GDT), implying that crypto businesses would be subject to general corporate taxation, but no specific guidance on crypto income or gains has been provided. - Cambodia - United States Department of State
• Cambodia offers zero rate VAT and import duty exemptions for raw materials, machinery, and equipment within Special Economic Zones, but it is not specified how VAT applies to digital asset transactions. - Cambodia - United States Department of State
• The CDC lists documents including "PRAKAS on Limited Interest Rates" and various taxation-related regulations, but none address cryptocurrency taxation. - Laws and Regulations – The Council for the Development of Cambodia (CDC)

Key Gaps & Risks

• The most significant gap is the complete absence of a dedicated cryptocurrency or digital asset legal framework — no law, no regulation, no official guidance exists. - Laws and Regulations – The Council for the Development of Cambodia (CDC)
• Businesses operating in the crypto space face legal uncertainty because no Cambodian authority has explicit jurisdiction over digital assets, creating ambiguity about which regulator to approach. - Cambodia - United States Department of State
• Cambodia's regulatory system lacks transparency, as investors report that draft legislation is not consistently subject to stakeholder consultations and that decisions by regulatory agencies can be inconsistent, arbitrary, and influenced by corruption. - Cambodia - United States Department of State
• Cambodian ministries and regulatory agencies are not legally obligated to publish the text of proposed regulations before enactment, and approved laws are often published only in Khmer, limiting accessibility for international crypto investors. - Cambodia - United States Department of State
• The U.S. government issued a business advisory in November 2021 warning U.S. businesses about corruption, criminal activities, and human rights abuses in Cambodia, highlighting the reputational and compliance risks of operating in the jurisdiction. - Cambodia - United States Department of State
• Systemic corruption, limited supply of skilled labor, inadequate infrastructure, and a weak regulatory environment are cited as factors dissuading U.S. investment in Cambodia generally, which would also affect crypto businesses. - Cambodia - United States Department of State
• The weak judicial system and reports of corruption create enforcement risks, as contracts and property rights may not be reliably protected in disputes involving digital assets. - Cambodia - United States Department of State
• The "grey list" removal by FATF in February 2023 shows progress, but the FATF's call to sustain improvements indicates ongoing monitoring and potential risk of re-listing if AML/CFT enforcement falters. - Cambodia - United States Department of State
• The CDC's legal framework disclaimer states that English translations are unofficial and Khmer versions control interpretation, creating practical risks for foreign businesses relying on translated regulations. - Laws and Regulations – The Council for the Development of Cambodia (CDC)
• Cambodia's weak regulatory environment, including preferential treatment for entities that engage in corruption or tax evasion, creates an uneven playing field for compliant crypto businesses. - Cambodia - United States Department of State
• The absence of crypto-specific licensing means a business cannot obtain regulatory approval or clarity, making it impossible to operate with legal certainty in the digital asset space. - Cambodia - United States Department of State
• Cambodia's Special Economic Zones offer incentives but are focused on physical infrastructure and manufacturing, not digital asset services, leaving crypto businesses without a designated regulatory home. - Cambodia - United States Department of State

Sources

• Federal Register :: Conforming Change to the Export Administration Regulations for Cambodia
• Federal Register :: Topics (CFR Indexing Terms) - Cambodia
• Laws and Regulations – The Council for the Development of Cambodia (CDC)
• Cambodia - United States Department of State