Self-custodial wallet / non-custodial software in Cambodia
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is not permitted in Cambodia.
Verdict Details
- Permitted
- no
- Local entity required
- No
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- No AML obligations apply because the underlying activity (issuance, circulation, trading of cryptocurrencies) is illegal under the 2018 Joint Public Announcement.
- If operating despite the ban, CAM-SRT reporting to CAFIU within 24-48 hours would theoretically apply under the 2020 AML/CFT Law.
Key Restrictions
- The issuance, circulation, and trading of cryptocurrencies and other virtual currencies in Cambodia are illegal activities per the May 2018 Joint Public Announcement by NBC, SERC, and the General-Commissariat of National Police.
- Any person or entity that issues, circulates, or trades cryptocurrencies without a license from NBC shall be prosecuted under applicable Cambodian laws.
- No licensing mechanism exists for any crypto-related activities because NBC has not authorized private cryptocurrency activities.
- Even non-custodial software that enables Cambodian residents to self-custody and transact in cryptocurrencies would likely be deemed as facilitating 'circulation' or 'trading' of cryptocurrencies, bringing it within the scope of the ban.
Key Risks
- Criminal prosecution risk — the 2018 announcement explicitly states violators 'shall be prosecuted in accordance with the applicable laws'.
- Repeated public warnings by NBC (as recently as 2022-2024) indicate continued enforcement vigilance.
- FATF grey-list scrutiny means Cambodia is under pressure to demonstrate enforcement against illicit virtual asset activity.
- Reputational risk from operating in a jurisdiction that has publicly declared all crypto activities illegal and unauthorized.
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."
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.
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.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Not permitted — Cambodia's 2018 Joint Public Announcement declares the issuance, circulation, and trading of cryptocurrencies illegal, and even a non-custodial wallet publisher facilitating Cambodian residents' use of crypto would likely be captured as enabling 'circulation' of virtual currencies, with no licensing pathway available.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?