You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

September 11, 2020

Cambodia’s New Law on Anti-Money Laundering

Subscribe to Updates

Cambodia’s new Anti-Money Laundering and Combating the Financing of Terrorism Law (the “2020 AML/CFT Law”) came into force in June 2020, abrogating the 2007 law of the same name and the accompanying sub-decree from 2013.

The 2020 AML/CFT Law differs in three major ways from the 2007 law: (1) more specific definitions, (2) a requirement for reporting entities to introduce enhanced due diligence measures, and (3) increased penalties for non-compliance.

Altered Definitions of Legal Terms

The 2020 version of the law has changed several definitions to lend further clarity and increase the scope of the law:

  • “Financing of Terrorism” is expanded by the addition of a list of examples of actions that could qualify as terrorism financing, including traveling or training with the intent to aid terrorists.
  • “Politically Exposed Persons” is broadened to include local officials (in addition to foreign officials) and “international politically exposed persons,” or prominent individuals in an international organization. In practice this means that reporting entities will now be required to monitor these persons’ transactions.
  • “Ultimate Beneficial Owner” is expanded to include any person who exercises ultimate effective control over a legal person through shares or voting rights.

Reporting Entities and Customer Due Diligence

Trustees have been added as a category of reporting entity, in keeping with the Law on Trusts which went into effect in early 2019. Otherwise, the comprehensive list of reporting entities is largely the same as in the 2007 law.

Reporting entities must deploy enhanced customer due diligence (CDD) measures, as more types of transactions and business relationships have been classified as high risk. This also applies retroactively, and must be conducted on existing customers who newly fall into the “high risk” category. Enhanced due diligence measures may include obtaining additional information on:

  • the customers’ identification;
  • the source of funds;
  • the purpose of the transaction; and
  • the intended nature of the business relationship.

Additional ongoing customer monitoring procedures may also be required.

If a reporting entity believes that carrying out these additional CDD measures will result in a particular customer becoming aware of the entity’s suspicions of them, the entity is allowed to cease conducting the measures and must report the customer and the activity that led to the initial suspicions to the Cambodia Financial Intelligence Unit (CAFIU).

The list of activities for which a reporting entity must apply enhanced CDD measures has been expanded to include:

  • business relations and transactions with institutions or persons in jurisdictions that have a high risk of money laundering or financing of terrorism;
  • business relations and transactions with foreign politically exposed persons and their family members and close associates;
  • business relations and transactions with international politically exposed persons, Cambodian politically exposed persons, and their family members and close associates, but only in response to a transaction that is identified as “high risk”; and,
  • all other business relations or transactions that could be identified as having a high risk of being associated with money laundering and/or financing of terrorism.

Penalties

Penalties for legal entities found to be in violation of the 2020 AML/CFT Law include warnings, fines, revocation of business licenses, and the removal of managers or officers from their positions, applied in addition to applicable sanctions under the Criminal Code. In general, the penalties outlined in the new law introduce higher fines and longer prison terms than were previously imposed under the 2007 Law and its subsequent amendments.

Previously, for example, legal entities deemed criminally responsible for money laundering were subject to a maximum fine of KHR 500 million (approx. USD 122,000), in addition to other sanctions under the Criminal Code. The maximum is doubled under the new law, to KHR 1 billion (approx. USD 244,000). Other offenses, such as money laundering by natural persons, various noncompliant activities, breach of confidentiality, and financing of terrorism are similarly expanded.

Related Professionals

Practices

Banking and Finance

Compliance and Investigations

Location

RELATED INSIGHTS​ 

February 4, 2026
On November 18, 2025, Vietnam’s Ministry of Finance released for public consultation a draft decree on administrative sanctions in the field of crypto assets and crypto asset markets (the “Draft Decree”), intended to implement Resolution No. 05/2025/NQ-CP dated September 9, 2025, on the pilot crypto asset market in Vietnam (“Resolution 05”). While Resolution 05 sets out who may participate and under what conditions, the Draft Decree addresses a more practical question for market participants, i.e., what happens if those conditions are not met. In doing so, the Draft Decree offers important insight into how Vietnamese regulators intend to supervise, discipline, and ultimately shape the crypto market during the pilot phase. Regulatory Scope and Overall Sanctions Architecture The Draft Decree applies to both domestic and foreign organizations and individuals engaging in crypto-related activities in Vietnam’s market. Covered entities include: (i) crypto asset issuers; (ii) crypto asset service providers, including trading platforms and market operators; (iii) Vietnamese and foreign investors participating in the pilot market; and (iv) other organizations involved in the offering, issuance, or provision of crypto-related services in Vietnam. The breadth of this scope is deliberate. It appears to reflect a regulatory view that cross-border structures, offshore platforms, and indirect participation may not necessarily insulate market actors from compliance obligations once they operate within the pilot framework. For the crypto industry, this may mark a shift from regulatory ambiguity toward a more explicit articulation of jurisdictional reach. At first glance, the Draft Decree’s monetary penalties appear restrained. The maximum fine per administrative violation is capped at VND 200 million (approx. USD 7,700) for organizations and VND 100 million (approx. USD 3,800) for individuals. However, focusing solely on fine levels risks missing the point. The Draft Decree also places great regulatory weight on supplementary sanctions and corrective measures, including: (i)
Read More
January 23, 2026
On December 31, 2025, the State Bank of Vietnam (SBV) issued Circular No. 72/2025/TT-NHNN (Circular 72), establishing a streamlined foreign exchange framework for Vietnam’s International Financial Center (IFC). Circular 72, which took effect on the same day, implements core provisions of Decree No. 329/2025/ND-CP and marks a fundamental shift from ex ante licensing to ex post supervision for IFC member enterprises and foreign investors. These changes are designed to accelerate capital flows, reduce compliance costs, and position Vietnam as a competitive regional financial hub by granting IFC members substantially greater autonomy in currency transactions, borrowing, lending, and investment activities. Key provisions for IFC members to note are discussed below. Use of Foreign Currency and Payments within the IFC Vietnam generally requires the use of Vietnamese dong for transactions within the country, with limited exceptions. This can be burdensome for foreign investors, who may be unfamiliar with all the foreign exchange rules they must comply with. Under the new regulation, IFC member enterprises and foreign investors gain the ability to transact, list prices, and settle obligations in foreign currency when dealing with other IFC members or offshore counterparties, avoiding currency risk and conversion friction. With respect to individuals and organizations located within Vietnam who are not IFC members, the use of foreign currency must continue to comply with general restrictions on foreign exchange usage within Vietnam. Dual-Track Account System for IFC Members The new regulation introduces a two-tier account structure that differentiates transactions by purpose and counterparty. IFC member enterprises must use a designated foreign currency capital account at an IFC member bank for four specified activities: Borrowing from offshore individuals and organizations Lending to offshore entities and domestic borrowers Outbound investing from the IFC Investing elsewhere in Vietnam from the IFC All other foreign exchange transactions—including operational receipts, vendor
Read More
January 22, 2026
On January 20, 2026, Vietnam’s Ministry of Finance (MOF) issued Decision No. 96/QD-BTC to formally launch pilot administrative procedures for licensing crypto asset trading market services in Vietnam. The decision took immediate effect and implements the government’s pilot crypto asset market program under Resolution No. 05/2025/NQ-CP. Notably, competent authorities have now begun accepting license applications, marking the first time Vietnam has operationalized a licensing pathway for crypto trading market operators. Administrative Procedures and Applications The decision stipulates procedures for (i) granting, (ii) adjusting, and (iii) revoking licenses to provide services for organizing crypto asset trading markets. It provides detailed, step-by-step guidance for each procedure, including dossier composition, internal review stages, coordination mechanisms, and statutory timelines. These procedures apply specifically to entities seeking to organize and operate crypto asset trading markets within Vietnam’s pilot regulatory framework. The MOF is the authority responsible for reviewing and deciding on the above procedures, with the State Securities Commission acting as the receiving, coordinating, and procedural focal point. For licensing applications, the MOF will coordinate with multiple authorities, including the State Bank of Vietnam and the Ministry of Public Security, particularly in relation to anti-money laundering, cybersecurity, system safety, and risk control requirements. Applications may be submitted in person, by post, or electronically via the National Public Service Portal or the administrative procedure information system, in line with applicable regulations. Statutory processing timelines vary depending on the specific procedure and stage involved. For applications to obtain a license to organize a crypto asset trading market, the process is conducted in multiple phases: The MOF will issue an initial written response within 20 working days from receipt of a complete and valid initial dossier, following which, upon submission of the full set of required documents, the MOF will complete substantive review and issue the license
Read More
January 9, 2026
On January 7, 2026, the Central Bank of Myanmar (CBM) announced a further relaxation of foreign exchange regulations through Notification No. 2/2026, with an effective date of January 1, 2026. This notification reduces the mandatory conversion requirement for exporters’ earnings in foreign currency into Myanmar kyat (MMK). Under the new notification, exporters are required to convert only 15 percent of their foreign currency export earnings into MMK at official CBM reference exchange rates, down from the previous required minimum conversion level of 25 percent. The adjustment provides exporters with more flexibility to manage foreign currency, improving liquidity for international transactions and reducing cash flow pressure. However, companies must still comply with the foreign currency conversion procedures and timelines set out in the CBM’s Notification No. 12/2022.
Read More