Tilleke & Gibbins has contributed an updated Cambodia chapter to Foreign Investment Review 2026, a global guide to the legal and regulatory environment for foreign investment in 25 jurisdictions around the world. Published and distributed by Lexology Panoramic, the guide is focused on law and policy regarding foreign investment oversight, regulatory frameworks, procedural requirements, and other notable concerns for foreign investors. The updated Cambodia chapter was prepared by Jay Cohen, partner and director of Tilleke & Gibbins’ Phnom Penh office, and Nitikar Nith, associate. The chapter focuses most closely on the law and policy section, which explains the government’s policies and practices regarding foreign direct investment, the main investment laws and their scope, and the relevant authorities responsible for regulating mergers, acquisitions, and other business transactions. The chapter also brings up key recent developments, such as the prospect of Cambodia establishing a competition regulator. A PDF of the Cambodia chapter can be downloaded through the button below. Tilleke & Gibbins also provided the Laos, Myanmar, and Vietnam chapters to Foreign Investment Review 2026. Readers can also gain 30 days of complementary access to the full Foreign Investment Review 2026 guide and the rest of Lexology Panoramic’s varied offerings through this link.

Myanmar’s Private Security Services Law, enacted on February 18, 2025, together with its implementing Directive on Applications for a Private Security Services License or Permit issued on June 18, 2025, establishes the country’s first comprehensive regulatory framework for both commercial private security service providers and companies that employ in-house security personnel. The framework applies to both Myanmar and foreign entities. For foreign investors and multinational operators, the new regime introduces strict licensing requirements, local content rules, and various approvals that must be carefully considered as part of business planning and compliance processes. Regulatory Authority and Structure The governing authority under the Private Security Services Law is the Private Security Services Central Supervisory Committee, formed with the minister of the Ministry of Home Affairs (MOHA) as chairperson, the chief of the Myanmar Police Force as vice-chairperson, and members from other high-ranking officials from relevant ministries, such as Transport and Communications, Defense, Planning and Finance, Investment and Foreign Economic Relations, Legal Affairs, Immigration and Population, Labor, and Commerce. This Central Committee is the highest regulatory authority and has the power to adopt policies, approve or reject applications for licenses and permits, and decide appeals against administrative actions taken by Supervisory Committees, which operate under the Central Committee at the state and regional level. They are responsible for processing applications, verifying compliance with statutory requirements, submitting applications to the Central Committee with remarks, and issuing licenses and permits once approved. Supervisory Committees also monitor compliance by license or permit holders and impose administrative penalties for noncompliance, while the Central Committee exercises final decision-making authority. License Requirements for Security Service Providers To apply for a private security services license, companies must be registered under the Myanmar Companies Law. Foreign companies may also operate a private security services business in Myanmar, subject to compliance

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

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