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​ 

May 13, 2026
Thailand has prescribed more stringent labeling specifications for traditional and electric vehicles (EVs), requiring manufacturers and importers for sale to display clear, accurate product information on vehicle labels. The requirements, which took effect on March 21, 2026, are set out in a notification issued under Thailand’s consumer protection framework. Background and Scope Under Thailand’s Consumer Protection Act (CPA), products manufactured for sale or imported into Thailand must generally comply with the CPA’s broad labeling requirements, unless the Label Committee prescribes more specific and stringent requirements for certain products. Accordingly, prior to the issuance of this notification, traditional autos and EVs were subject only to the general labeling requirements. Following the issuance of this Label Committee notification, traditional autos and EVs are now for the first time specifically subject to a dedicated regulatory framework for labeling. The requirements apply to private passenger vehicles and private trucks that have not yet been registered, including those powered by an internal combustion engine, electric power, or a combination of both. Label Requirements Labels must be displayed in Thai or with a Thai translation, and must be clearly visible and legible. Text must be proportional to the label area, with a minimum character height of 2 millimeters. All covered vehicles must display the following: Product name, trade name, or trademark Brand and model Manufacturer or importer information Size, weight, and load-bearing capacity Warranty conditions Drive system, usage instructions, and safety precautions Manufacturing date Price Additional Requirements for EVs EVs must also display the following: Type of electric vehicle (e.g., HEV, PHEV, BEV, or FCEV) Maximum electric motor power and rated continuous output power Battery type and capacity Battery warranty conditions or a clear statement that no warranty is provided Estimated driving range per full battery charge Electrical system safety standard Electricity consumption rate These
May 11, 2026
Vietnam’s legal framework governing chemicals has undergone significant reform, with the Law on Chemicals No. 69/2025/QH15 (Law on Chemicals 2025) taking effect on January 1, 2026. Together with a comprehensive set of implementing instruments issued in January 2026, including three decrees (No. 24/2026/ND‑CP, No. 25/2026/ND‑CP, and No. 26/2026/ND‑CP) and two circulars (No. 01/2026/TT‑BCT and No. 02/2026/TT‑BCT), the Law on Chemicals 2025 has significantly reshaped chemical registration and management requirements. Determining What Constitutes a “New Chemical” Among the most notable changes introduced under the Law on Chemicals 2025 are the rules governing the registration and management of new chemicals, which must be registered with the authority before being placed on the Vietnam market. Although the concept of new chemical registration was first introduced under the Law on Chemicals 2007, the corresponding registration mechanism has remained largely dormant in practice. Under the Law on Chemicals 2025, a “new chemical” is defined as a substance that is not yet included in Vietnam’s National Chemical Inventory and the list of foreign chemical inventories recognized by the competent Vietnamese authority (List of Foreign Chemicals). On a literal reading, the definition in the new law may suggest that a substance qualifies as a new chemical only if it is absent from both lists. Accordingly, a chemical present in either list should be treated as an existing chemical without the registration burden. However, a different interpretation emerges from Decree 26, which specifically requires registration of “new chemicals” even where such substances already appear in the List of Foreign Chemicals. This implies that inclusion in a recognized foreign inventory does not automatically exempt a substance from new chemical registration in Vietnam. This inconsistency between the statutory definition in the Law on Chemicals 2025 and the implementing provisions of Decree 26 creates significant interpretative and compliance challenges. At
May 11, 2026
Thailand’s rise as a regional hub for luxury retail has influenced how market entry is structured and assessed across Southeast Asia. As brands consider establishing a presence in the market, regulatory and operational considerations form a key part of the overall entry assessment. Foreign Ownership Restrictions for Retailers Foreign investment in retail activities is subject to a relatively extensive regulatory framework, particularly in relation to foreign ownership and the approvals required under the Foreign Business Act B.E. 2542 (1999) (FBA). Under the FBA, a company is generally regarded as foreign if 50% or more of its shares are held by non-Thai nationals, in which case the business is required to obtain a foreign business license (FBL) issued by the director-general of the Department of Business Development, with the approval of the Foreign Business Committee. The committee will not grant an FBL unless it is convinced the proposed business demonstrates unique characteristics such as a distinctive business model, innovative processes, specialized services or products, or a clear competitive differentiation that will benefit Thailand; constitutes a highly specialized business or requires specialized technology or expertise; and will not compete with Thai business operators who engage in the same business. The committee makes its decisions on a case-by-case basis depending on the circumstances, which can make the licensing process less predictable in practice. However, there are also alternative pathways for consideration, including exemptions in specific circumstances. For example, foreign-owned businesses in Thailand with at least THB 100 million in registered capital are allowed to open five retail stores in the country. Some businesses may also be able to access preferential treatment under international agreements and treaties between Thailand and certain foreign states, subject to eligibility requirements. Structural and Business Model Challenges The determination of what constitutes a “retail store” may itself present
May 8, 2026
The global trade environment for Thai exporters in 2026 has shifted significantly. Recent enforcement developments in both the United States and the European Union show a clear shift in trade policy: regulators are no longer focused solely on tariff levels, but also on whether products genuinely originate where exporters claim they do. Adding to this complexity, the US Supreme Court’s February 2026 decision striking down the use of the International Emergency Economic Powers Act (IEEPA) to impose tariffs has upended the legal basis for a major pillar of US tariff policy, creating significant legal and commercial uncertainty for exporters worldwide, including in Thailand. For Thai companies integrated into regional supply chains, this change carries material implications. Although the IEEPA-based US reciprocal tariffs have been struck down, intensified circumvention enforcement continues under separate legal authorities, and the administration has signaled its intent to reimpose tariffs under alternative statutory frameworks, while EU authorities are using anti-circumvention investigations where trade patterns shift. In both jurisdictions, the decisive issue is whether manufacturing in Thailand constitutes substantial transformation under applicable rules of origin. Such origin determinations increasingly drive duty exposure, audit risk and commercial disputes. In 2026, the ability to defend a product’s Thai origin is not merely a procedural step, it is central to preserving market access in the US and EU. Impact Of US Circumvention Enforcement and an Uncertain Tariff Landscape Following the 2025 Framework for an Agreement on Reciprocal Trade, Thailand saw a shift in its tariff relationship with the US. A substantial range of Thai-origin goods were subject to a 19% reciprocal tariff under the IEEPA. However, the Supreme Court’s ruling invalidating the use of IEEPA for tariffs has removed the legal basis for that rate. The Administration has indicated it intends to pursue replacement tariffs under other statutory authorities,