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

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

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.