Crypto ATM / kiosk operator in Cambodia

Prohibition on Issuance, Trading, and Use: In May 2018, the NBC, in collaboration with the Securities and Exchange Regulator of Cambodia (SERC) and the General-Commissariat of National Police, issued a joint public announcement prohibiting financial institutions and the public from buying, selling, or trading cryptocurrencies.

Legal Reference: Joint Public Announcement on the Management of Digital Currency (May 2018) by the National Bank of Cambodia, Securities and Exchange Commission of Cambodia, and the General-Commissariat of National Police. (Direct English URL often difficult to find; commonly cited as "Joint Announcement on Digital Currency, 2018").

Reiteration of the existing ban and public warnings.

Entity Targeted: The general public, unauthorized individuals/entities attempting to circulate, trade, or develop cryptocurrencies. Violation Type: Circulating, trading, mining, or using unauthorized virtual currencies, which are not recognized as legal tender or financial products in Cambodia. Penalty Amount: Not applicable for public warnings. Criminal penalties would apply for engaging in illegal financial activities or fraud.

Date: The original ban was issued in 2018/2019. Warnings have been continuously reiterated, including within the last three years.

Example of recent reinforcement (2022): The NBC Governor reinforced the ban and warned against the risks of digital assets in various forums.

Example of ongoing concern (2023-2024): Cambodian authorities continue to monitor and warn against the use of unauthorized digital assets, often linking it to broader financial stability and anti-money laundering efforts.

Identification and Verification of Customers:

For Individuals: Obtaining and verifying proof of identity (e.g., national ID card, passport, driver's license), date of birth, address, and nationality.

Enhanced Due Diligence (EDD): Required for high-risk customers, business relationships, or transactions (e.g., Politically Exposed Persons - PEPs, customers from high-risk jurisdictions, complex or unusually large transactions, new technologies with inherent anonymity).

Obligation to Report: Any VASP that suspects or has reasonable grounds to suspect that funds or other assets, regardless of the amount, are derived from criminal activity, or are related to terrorist financing, must report promptly.

Recipient: The Cambodia Financial Intelligence Unit (CAFIU).

Timeline: Reports must be made without delay, typically within 24-48 hours of forming the suspicion.

No Tipping-Off: VASPs and their employees are prohibited from disclosing to the customer or to third parties that an STR has been or will be submitted.

Conducting ongoing due diligence on the business relationship and scrutinizing transactions undertaken throughout the course of that relationship to ensure that the transactions are consistent with the VASP's knowledge of the customer, their business, and risk profile, including, where necessary, the source of funds.

Ensuring that documents, data, or information collected under the CDD process are kept up-to-date.

Screening customers against relevant national and international sanctions lists (e.g., UN Security Council sanctions) and PEP lists.

Evidence fact kh.licensing.training-provide-regular-training-to not found (may have been renamed).

UN Sanctions: Cambodia's FIU is responsible for disseminating and ensuring compliance with the UN Consolidated List.

Risk-Based Approach: Assess their money laundering and terrorism financing risks, including sanctions risks.

General Context & AML Focus (2023):