Centralized exchange in Cambodia
Order-book exchange that takes custody of user assets and matches trades between users.
CEX is not permitted in Cambodia.
Verdict Details
- Permitted
- no
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- Entities engaging in unauthorized virtual asset activities face prosecution under the Law on Anti-Money Laundering and Combating the Financing of Terrorism (2020) if activities facilitate ML/TF.
- General AML/CFT Law obligations apply to reporting entities, but VASPs are not recognized as licensed reporting entities under the current framework.
- Suspicious Transaction Reports (STRs) must be filed with the Cambodia Financial Intelligence Unit (CAFIU) without delay (typically within 24-48 hours) if suspicious activity is detected.
- UN sanctions screening against the UN Consolidated List is legally binding for any entity operating in Cambodia.
- Customer due diligence / KYC requirements (identification, verification, beneficial ownership, ongoing monitoring) exist under Prakas 285 but are not specifically operationalized for crypto activities.
- No specific Travel Rule obligations adopted for VASPs; no threshold amounts or technical implementation requirements exist.
Key Restrictions
- The issuance, circulation, and trading of cryptocurrencies and other virtual currencies without a license from the National Bank of Cambodia is illegal.
- The NBC, SERC, and General-Commissariat of National Police jointly declared (2018, reiterated 2022-2023) that unauthorized crypto activities are prohibited.
- No specific VASP licensing regime exists; the 2018 ban on unauthorized activities effectively blocks centralized exchange operations.
- No segregation-of-client-assets rules, custodial license frameworks, or cold-storage mandates exist — because the activities they would govern are not legally permitted.
Key Risks
- Direct legal exposure: operating a centralized exchange without NBC authorization can lead to prosecution under applicable laws, fines, and imprisonment.
- FATF grey-list scrutiny: Cambodia's AML/CFT framework deficiencies (including lack of VASP regulation) create ongoing international pressure and enforcement attention.
- No regulatory pathway: there is no exchange/VASP license to apply for, creating indefinite legal uncertainty.
- Correspondent banking risk: any fiat on/off-ramp relationships may be terminated if international partners detect crypto-related activity linked to Cambodia.
- Repeated public warnings by NBC (2022) and ongoing monitoring (2023-2024) indicate continued enforcement risk.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
"The issuance, circulation, and trading of cryptocurrencies and other virtual currencies in Cambodia are illegal activities."
It explicitly stated that "any person or entity that issues, circulates, or trades cryptocurrencies or other virtual currencies without obtaining a license from the National Bank of Cambodia and other relevant authorities, shall be prosecuted in accordance with the applicable laws of the Kingdom of Cambodia."
Custodial License Requirements:
Segregation of Client Assets Rules:
Cold Storage Mandates:
Qualified Custodian Definitions:
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").
Not explicitly adopted for VASPs: Cambodia has not yet enacted specific legislation or regulations that define VASPs according to FATF standards, license them, and mandate the Travel Rule requirements directly for them.
Since there is no explicit Travel Rule implementation for VASPs, there are no specific Travel Rule threshold amounts adopted in Cambodia (e.g., the FATF recommended USD/EUR 1,000 threshold for originator/beneficiary information sharing).
Which VASPs are Covered:
Law on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT Law):
Prakas on the Implementation of the Law on Anti-Money Laundering and Combating the Financing of Terrorism (Prakas 285 on AML/CFT)
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.
Reiteration of the existing ban and public warnings.
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.
Original 2018/2019 Ban (Context):
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
No — a centralized exchange cannot legally operate in Cambodia because the issuance, circulation, and trading of cryptocurrencies without NBC authorization is prohibited by the joint 2018 ban (repeatedly reaffirmed), and no VASP licensing or custodial framework exists to authorize such activity.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?