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

December 17, 2018

Lex Mundi Anticorruption Compliance Guide—Cambodia Report

Lex Mundi

Partner and director of Tilleke & Gibbins’ Phnom Penh office, Jay Cohen, and advisor, Sophea Sin have contributed their expertise and knowledge to the Cambodia section of the global Anticorruption Compliance Guide  produced by Lex Mundi, the world’s largest network of independent law firms. Their detailed responses give considerable insight into anti-bribery and corruption legislation in Cambodia—all of which was enacted within the last ten years—specifically on laws relating to anti-bribery and corruption, criminal liabilities, and penalties for violations.

This comprehensive and interactive guide provides local insight on anti-bribery and corruption regimes in 78 jurisdictions globally. Reports follow a question and answer format, with responses provided appropriately and thoroughly by a Lex Mundi member firm from each respective jurisdiction. In addition to contributing the Cambodia report for the guide, Tilleke & Gibbins’ legal professionals also supplied the responses for the reports covering Laos, Myanmar, Thailand, and Vietnam.

To view the full Cambodia report, please download the PDF below. For reports from the other 77 jurisdictions, please visit Lex Mundi’s website.

RELATED INSIGHTS​ 

August 13, 2026
Modern agricultural machinery is no longer purely mechanical but instead technology dependent. Modern tractors, harvesters, and other farm equipment increasingly incorporate embedded software, electronic control units, sensors, and digital diagnostic systems. While such technologies enhance efficiency, productivity, and precision farming, they also affect the manner of equipment repair and maintenance. As a result, farmers and independent repair providers may have little practical choice but to rely on authorized dealers, even for routine maintenance and repairs. Section 36 of Thailand’s Patent Act reflects the principle that the authorized sale of a patented invention usually exhausts the exclusive right of the patent owner over the specific product. This means that upon legal sale of the patented product, it can typically be used or resold without further authorization from the patent holder. This principle is relatively straightforward when applied to traditional mechanical equipment. Ownership of a machine ordinarily carries with it the practical ability to diagnose faults, replace worn parts, and restore the equipment to working order. Modern agricultural machinery, however, increasingly depends on embedded software, proprietary diagnostic systems, firmware updates, and other digital resources that may remain under the control of the manufacturer or patent holder. This tension lies within the “right to repair” debate. In the United States, on July 8, 2026, the Federal Trade Commission and five states announced a settlement with Deere & Company resolving allegations that Deere had unlawfully restricted farmers’ and independent repair providers’ ability to repair their equipment. Under the terms of the settlement, for the next ten years, Deere must provide repair resources, including software capabilities, on terms equivalent to those provided to authorized dealers. The Deere settlement highlights that the nature of ownership is changing, but legal concepts have not kept pace. Traditional patent-law concepts, including patent exhaustion, were developed with physical products
August 13, 2026
On August 6, 2026, the National Bank of Cambodia (NBC) issued a notice calling on business owners that issue electronic money, such as e-wallet accounts and stored-value membership cards, to notify the central bank within 90 days. The notice targets businesses that are not licensed banking or financial institutions or payment service providers, but have been issuing e-money to facilitate payments within their own networks. Failure to notify the NBC may result in legal action. Background and Regulatory Basis The NBC has observed that certain businesses, including cafes, restaurants, transportation companies, entertainment centers, and gas stations, have been issuing e-money through e-wallet accounts in mobile apps or membership cards to facilitate customer payments for products or services within their own networks. Customers create e-wallet accounts and load balances to pay for goods or services at the issuing business. The NBC describes this as “single-purpose e-money.” Under the 1999 Law on Banking and Financial Institutions, providing payment facilities to customers forms part of the operations of banking and financial institutions and requires an NBC license. In addition, article 20 of the 2017 Prakas on the Management of Payment Service Institutions further prohibits legal entities other than banking and financial institutions and payment service institutions from issuing e-money. However, article 20 also provides that issuing e-money in certain limited cases does not require a license, but the NBC must be notified in advance in writing. A business may issue single-purpose e-money without a payment service institution license provided it meets all the following conditions and submits written notice to the NBC: The maximum balance per account is KHR 200,000 (approximately USD 50) or equivalent. The total aggregate balance across all accounts does not exceed KHR 800 million (approximately USD 200,000) or equivalent. The e-money is used to pay for products or
August 11, 2026
On July 27, 2026, the State Bank of Vietnam (SBV) released a draft decree proposing amendments to Decree No. 52/2024/ND-CP dated May 15, 2024, on non-cash payments (Decree 52). The draft decree would amend 17 of Decree 52’s 38 articles, with several key changes directly affecting providers of intermediary payment service (IPS). The key proposed changes affecting IPS providers are outlined below. Streamlining IPS Licensing Procedures A central objective of the draft decree is to simplify regulatory procedures for IPS providers. Notably, it would significantly reduce IPS licensing documentation requirements by removing the need to submit enterprise registration certificates, investment registration certificates, and documents evidencing the qualifications of the legal representative and general director. Instead, the SBV would retrieve this information directly from national business registration and other specialized databases, requesting additional documents only where the relevant information cannot be verified electronically or is incomplete. The draft decree also removes the current limit of two rounds for dossier supplementation and shortens processing timelines for several IPS licensing procedures such as issuance, amendment, and reissuance of IPS licenses. The processing time for new IPS license applications would be thereby reduced from 90 to 60 working days. In addition, several continuing IPS business conditions would be removed. For example, IPS providers would no longer be required to maintain certain representations relating to corporate restructuring or the legality of contributed capital. Likewise, the IPS project plan (đề án) would become a one-time application document rather than an ongoing licensing condition. If retained in the final decree, this change could provide IPS providers with significantly greater flexibility to implement post-licensing technology upgrades, system integrations, and corporate restructuring transactions without needing to revisit the originally approved project plan. The draft decree also removes the requirement for the SBV to consult the Ministry of Public
August 11, 2026
Cambodia’s Ministry of Justice has launched a new platform on its official website to publish notices of forced sales issued by each municipal and provincial court of first instance. The platform’s stated purpose is to inform the public and facilitate greater participation in forced-sale auctions conducted in connection with court-ordered enforcement proceedings. How the Platform Works The platform publishes forced-sale notices from courts of first instance across Cambodia’s municipalities and provinces and includes a link where the public can view properties currently subject to forced sale. To participate in a forced-sale auction, individuals can download Khmer-language bidding application forms through links provided on the platform. The form typically requires the applicant’s name, sex, year of birth, identity card number and issue date, and address, together with details identifying the immovable property (including its ownership certificate number), the relevant enforcement case number and date, and the reference to the public auction or tender announcement issued by the court. Completed application forms must be submitted directly to the specific municipal or provincial court that issued the forced sale. For further inquiries about a particular forced sale, interested parties should likewise contact the relevant municipal or provincial court. Forced Sale of Immovable Property in Cambodia The publication of these notices relates to the forced sale procedure for immovable property under Cambodia’s Code of Civil Procedure (CPC). Unlike property seizure by a court, a forced sale is a compulsory execution proceeding—a subsequent enforcement step that arises only after an underlying dispute has been adjudicated and a debtor fails to pay the debt or outstanding amount due under a final and binding judgment or other enforceable title of execution. For the purposes of this procedure, the term “immovable property” under the CPC refers to land, registered buildings, jointly held shares of such property, registered