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 8, 2026
Thailand has liberalized its wine import regime, allowing, for the first time, multiple importers to bring in and distribute the same wine brands. On March 27, 2026, the Ministry of Finance issued the Ministerial Regulation on the Importation of Alcoholic Beverages (No. 3) 2026, which waives the requirement to appoint a sole authorized agent for alcoholic beverages to be specified in notifications from the Excise Department. The Excise Department has already issued its first such notification, expressly exempting wine and sparkling wine made from grapes from the sole agent requirement. For all other types of alcoholic beverages (e.g., beer, tequila, spirits) the sole agent requirement remains in force, and applicants for importer licenses must provide evidence of exclusive distributorship issued by the manufacturer or brand owner. The exemption may be extended to other alcoholic beverage categories through future Excise Department notifications. Implications for Competition and Tourism The reform allows multiple importers to bring in and distribute the same wine brand without routing through the brand owner’s designated exclusive importer, reducing monopolization and boosting competition. Excise Department Director-General Pornchai Thirawet noted that wine was chosen as the starting point because implementation is straightforward in this case and because domestic wine prices remain high—with increased competition expected to exert downward pressure on prices. More broadly, the reform is intended to lower market entry barriers, expand supply, and make wine more accessible to Thai consumers, while supporting Thailand’s position as a regional tourism hub. Product Quality Control and Loss of Sole Agent Accountability Under the previous framework, the designated importer bore full responsibility for the proper storage, handling, and distribution of wine and sparkling wine from importation to final sale. This arrangement helped ensure that products were maintained under appropriate conditions, including temperature control, light exposure, and humidity management, to preserve quality
May 6, 2026
Thailand has introduced new requirements for online social media platforms to verify the identity of paying advertisers before publishing their advertisements. On May 5, 2026, the Electronic Transactions Commission published the Notification on Measures for Prevention of Technology Crime for Online Social Media (No. 2) in the Government Gazette. The notification, which aims to prevent technology crimes such as fraud and scams, takes effect 180 days after publication (i.e., on November 1, 2026). Mandatory Advertiser Identity Verification Online social media service providers must verify the identity of every advertiser before publishing an advertisement. Verification remains valid for up to one year from the most recent verification date. The notification requires social media providers to use either of the following methods when verifying advertisers: Document-based verification: Examine government-issued identity documents (e.g., national ID, passport, or juristic person registration certificate), cross-check the connection between the advertiser and the identity documents (e.g., facial comparison with photo ID), and ensure that the identity documents are verifiable against reliable sources. Digital identity verification: Use an identity verification system with a level of assurance no lower than that prescribed by the Electronic Transactions Commission. Advertiser Data Collection and Retention Service providers must collect and retain certain data—including name, identification number, and contact details—from the start of the advertising service and for a minimum of 90 days after the end of the advertising service relationship. The same requirements apply where there is a third-party payer, such as an ad agency. Implications for Affected Businesses The notification raises two key areas of concern for affected businesses: Social media platforms must implement know-your-advertiser (KYA) onboarding as described above, including document upload and identity matching processes. The 180-day implementation window requires immediate technical and operational planning. The collection and retention of national ID cards, passport copies, and other personal
April 30, 2026
Thailand’s Long-Term Resident (LTR) Visa regime offers an attractive immigration pathway for qualifying foreign nationals, providing a 10-year renewable permission to stay in Thailand. Following amendments under Board of Investment (BOI) Announcement No. Por. 3/2568 dated February 4, 2025, the regime now more explicitly accommodates property investment as a qualifying vehicle—a development of particular relevance to foreign nationals already considering real estate acquisitions in Thailand. The LTR Visa is available to several categories of applicants, including wealthy global citizens with global assets of at least USD 1 million, and wealthy pensioners aged 50 or older with an annual pension or fixed income of at least USD 40,000. Property as a Qualifying Investment For both categories, property investment is recognized as one of three eligible investment types alongside Thai government bonds (with at least five years remaining to maturity) and direct investments in Thai companies or approved venture capital or private equity vehicles. The minimum qualifying property investment is USD 500,000 for wealthy global citizens and USD 250,000 for wealthy pensioners. Eligible property types include freehold condominiums, buildings, or villas, as well as leasehold properties with a remaining lease term of at least 10 years. Health Coverage Requirement Beyond the investment threshold, applicants must demonstrate adequate health coverage. This requirement can be satisfied through a health insurance policy covering at least USD 50,000 in Thai medical expenses with at least 10 months of remaining coverage, evidence of social security benefits covering Thai medical costs, or a bank deposit of at least USD 100,000 retained for 12 months. Practical Considerations For foreign nationals already considering property acquisitions in prime residential markets—where investment values commonly meet or exceed the USD 500,000 threshold—the visa pathway effectively transforms a real estate purchase into a dual-purpose investment, combining asset ownership with long-term residence rights that
April 30, 2026
Vietnam’s Decree No. 134/2026/ND‑CP, which took effect on 9 April 2026, plays an important role in detailing and implementing Vietnam’s Intellectual Property (IP) Law in the context of rapid digital transformation and the growing application of artificial intelligence (AI). The new decree provides comprehensive guidance on the application of copyright and related‑rights regulations, addressing key issues such as authorship, ownership, statutory exceptions and limitations, registration procedures, and enforcement mechanisms. Through these measures, Decree 134 seeks to achieve an appropriate balance between safeguarding the legitimate interests of rightsholders and fostering innovation, research, and technological advancement, thereby strengthening the state’s framework for the effective management, protection, and exploitation of intellectual property in the digital and AI‑driven environment. Some notable aspects of Decree 134 are discussed below. Copyright for AI-Created Works Decree 134 provides important guidance on the determination of copyright and related rights in works created with the assistance of AI. Article 5a reaffirms the principle that human creativity remains central to copyright protection, clarifying that copyright or related rights arise only where a human makes a substantial and decisive intellectual contribution, exercises effective control over the creative outcome, and assumes responsibility for the content and its legality. At the same time, the provision confirms that AI is regarded solely as a technological tool rather than a rights‑holding subject, thus ensuring consistency with the fundamental concepts of authorship and ownership under the IP Law. By introducing requirements on transparency, proof of human contribution, and compliance with AI‑specific labelling and technical marking obligations, Decree 134 establishes a clear and enforceable legal framework for the responsible use of AI in creative activities. Lawful Use of Copyrighted Texts and Data Article 37a of Decree 134 sets out the specific conditions under which copyrighted texts and data may be lawfully used for scientific research, experimentation,