Remote VASP serving residents in Cambodia

"The issuance, circulation, and trading of cryptocurrencies and other virtual currencies in Cambodia are illegal activities."

It warned the public against engaging in such activities, citing risks of fraud, money laundering, and financial instability.

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."

Reiteration of the existing ban and public warnings.

Regulator Name: National Bank of Cambodia (NBC), Securities and Exchange Regulator of Cambodia (SERC), General-Commissariat of National Police (jointly issued original ban).

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

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.

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.

The government has historically issued warnings against unregulated cryptocurrency activities, which suggests that unauthorized operations could lead to legal action, fines, or imprisonment under existing laws governing financial crimes or unauthorized financial services.

Key Provisions: Defines money laundering and terrorist financing offenses, establishes the legal framework for identifying, verifying, and reporting suspicious activities, and outlines penalties for non-compliance. It also identifies "reporting entities" (or "obliged entities") that must comply. VASPs, by the nature of their services, are generally considered reporting entities under this broad definition, especially concerning the movement of value.

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.

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.

Identification and Verification of Customers:

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).

There are no specific custodial licenses for cryptocurrencies/digital assets in Cambodia because the underlying activities (issuance, circulation, trading) are deemed illegal if not authorized by NBC. Since NBC has not authorized private cryptocurrency activities, no licensing mechanism exists for custody.

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