--- title: "Cambodia Crypto Regulation Monitor | cryptoassets.gi" canonical: https://cryptoassets.gi/jurisdictions/cambodia/ source_html: /jurisdictions/cambodia/index.html description: "Cambodia crypto asset regulation: 9 categories, 43 sourced findings, updated 2026-10-25. Licensing, token classification, stablecoins, tax treatment." generated_at: 2026-11-07T14:19:44Z content_sha256: 04eff00a49d6754a2e7532e88feef0ae3ba681931f3bac69f04539e841ebd5ba generator: "fe-fleet/md-twin@1.0" --- # Cambodia Crypto & Digital Asset Regulation schema crypto-v2.0.0 trajectory: not yet assessed in transition overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/cambodia/), [World Payments](https://payments.gi/jurisdictions/cambodia/) Last updated 2026-10-25 · 9 categories · 43 sourced findings · 30 sources in the cumulative register Download report (PDF) Expand all Evidence re-verified: 2026-10-25 · Position last changed: 2026-10-25 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently. Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26 [Open in Co-Pilot ↗](/reports/?type=copilot&j=CAMBODIA)[Build Report](/reports/?j=CAMBODIA)[Compare](/compare/?j=CAMBODIA) Framework posture In transition 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified Lead supervisory authority National Bank of Cambodia Primary statutory & supervisory perimeter Next milestone (> 2026-10-26) 2026-11 Draft comprehensive virtual-asset law final draft and legislative approval Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed 9 Categories 0 Moved this cycle 0 Key judgments 3 Open gaps 43 Findings 6 Tier-1 sources Confidence mix 9 unpopulated (sums to 9 rendered categories; click to filter) No categories moved this cycle. ## Jurisdiction lead brief ###### Latest update · 25 October 2026 #### Lead Signal Cambodia's virtual-asset regime is in active transition. A joint oversight arrangement between the National Bank of Cambodia (NBC) and the Securities and Exchange Regulator of Cambodia (SERC), reported as launched in late September 2026, sets out a licensing and reporting perimeter under which NBC-supervised banks require central-bank approval to provide virtual-asset services, other entities require a SERC licence, and authorised firms become reporting entities to CAFIU. This framework has not been independently verified as a published, numbered Prakas or Circular; the finding rests on a single secondary source, and the underlying instrument's exact legal form remains unconfirmed. Alongside this, a draft comprehensive Law on the Management of Virtual Assets and Digital Assets is reported to be targeted for a final draft in the fourth quarter of 2026, which would replace or supplement the current Prakas-based crypto perimeter with a dedicated statute. #### Other Developments Licence revocation reaffirms the restrictive baseline. The National Bank of Cambodia revoked the payment-service licence of Huione Pay Plc and issued a public warning that non-compliant cryptocurrency transactions pose risks to the banking system. As of this action, no bank or financial institution is currently authorised to offer crypto-asset services in Cambodia, underscoring that the existing Group 1/Group 2 classification framework, under which only tokenised instruments and backed stablecoins may be handled by NBC-supervised banks and payment service providers with NBC approval, remains the operative baseline even as the newer joint framework is layered on top of it. A conference partnership signals institutional engagement, not a capital transaction. The National Bank of Cambodia and the Global Fintech Technology Network (GFTN) announced a partnership tied to the Black Swan Summit Cambodia, scheduled for 15-16 November 2026, intended to showcase the Bakong payment system and discuss regulatory frameworks for digital-asset innovation. No capital amount was disclosed, and the arrangement is better characterised as a convening and dialogue mechanism than as a commercial deal with financial terms. #### Cross-Monitor Connections The licensing and enforcement signals here connect to concurrent payments-sector and financial-integrity developments in Cambodia this period, where the central bank has separately moved to tighten oversight of non-bank payment issuers and to pursue large-scale asset-freeze action against scam-linked networks. The virtual-asset licensing perimeter under development sits adjacent to these broader supervisory tightening efforts, suggesting a single regulatory posture extending across payments, crypto, and financial-crime enforcement rather than isolated, unrelated initiatives. #### Outlook The draft Law on the Management of Virtual Assets and Digital Assets, targeted for a final draft in the fourth quarter of 2026 ahead of the Black Swan Summit, is the single development most likely to reshape this picture. Its eventual text would determine whether the current ad hoc, Prakas-based approach is replaced by a statutory licensing regime. Until that draft law is finalised and the underlying instrument behind the NBC-SERC joint framework is independently confirmed, the regulatory perimeter for virtual-asset activity in Cambodia should be read as provisional rather than settled. 2 earlier updates not shown here. ###### Standing brief · as of 25 August 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal Cambodia's cryptoasset regulatory posture shifted materially this cycle with confirmation that the National Bank of Cambodia's Prakas B7-024-735 now permits commercial banks and payment settlement institutions to provide cryptoasset services, subject to prior NBC approval, at high confidence. This moves Cambodia from what had been a blanket 2018 prohibition on domestic crypto trading toward a permission-based regime for regulated financial institutions, marking the most significant structural change to the jurisdiction's crypto-licensing framework identified this cycle. This is assessed as a liberalising shift: rather than the categorical prohibition that characterised Cambodia's approach in 2018, the Prakas establishes a permission-based structure in which banks and PSPs may now engage in cryptoasset services with prior regulatory approval, a materially different starting posture for any institution assessing Cambodia as a market for regulated crypto activity. #### Other Developments A separate Crypto Asset Service Provider licence category exists but remains structurally incomplete. Legal entities other than banks and payment institutions must obtain an NBC licence to operate as a CASP; however, the detailed approval procedures under Clause 20 of the Prakas are to be set out in a separate regulation that had not been published as of this cycle, at high confidence. This gap caps the practical availability of the CASP pathway even though the Prakas establishing the requirement is itself in force. The interpreter data flags this Clause 20 gap as enacted-not-yet-effective, a status distinct from the Prakas's own in-force status for the bank/PSP permission itself, a distinction worth preserving precisely, since conflating the two would overstate how far Cambodia's CASP licensing track has actually progressed. Market access in practice remains narrow. Only two platforms, Royal Group Exchange and Cambodian Network Exchange, currently operate as authorised crypto platforms, and both do so under the NBC's FinTech Regulatory Sandbox rather than under the full licensing regime the Prakas contemplates, at high confidence. #### Cross-Monitor Connections This cycle's crypto-licensing developments in Cambodia sit adjacent to the World Payments Monitor's coverage of a newly established notification requirement for non-bank e-wallet issuers and an Inter-Ministerial Working Group tasked with drafting a comprehensive Law on the Management of Virtual Assets/Digital Assets, both of which address the same underlying policy transition from a payments-market-access perspective rather than the digital-asset-licensing perspective addressed here. Separately, the Financial Integrity monitor's coverage of NBC's crypto containment strategy, including the Telecommunication Regulator of Cambodia's blocking of major offshore exchanges, should be read alongside this cycle's licensing findings as two facets of the same regulatory environment: one liberalising and one restrictive, operating simultaneously. Institutions assessing Cambodia-linked crypto exposure should treat the licensing, payments, and containment strands as complementary views of a single, still-forming regulatory architecture rather than as independent or contradictory signals. #### Outlook The single most consequential open item is whether and when the Clause 20 CASP licensing-procedure regulation is published; until it is, the CASP pathway remains theoretical rather than operative for any entity other than banks and payment institutions. Separately, watch for whether the forthcoming comprehensive Law on the Management of Virtual/Digital Assets, whose drafting was initiated in August 2026 under an Inter-Ministerial Working Group, absorbs or supersedes the current Prakas-based framework; no timeline has been confirmed, and the interpreter data assesses it at a multi-year uncertainty band. The sandbox-based market access currently enjoyed by Royal Group Exchange and Cambodian Network Exchange should also be watched for whether it is formalised into a permanent licensing category once Clause 20 procedures are published, or whether the sandbox model itself persists as the durable long-term access route. Read full brief · 1101 words Key regulatory facts for Cambodia Regulatory Dimension Cambodia Standing Position Jurisdiction Cambodia (KH) Regulatory Scope Crypto & Digital Asset Regulation (9 modules, 43 sourced findings) Crypto Licensing Cambodia has no single comprehensive crypto-asset licensing statute. Token Classification Cambodia has no statutory token taxonomy distinguishing security tokens, e-money tokens, asset-referenced tokens, utility tokens, stablecoins or NFTs. On-Chain Activity Regime No dedicated Cambodian legal or regulatory treatment of staking, DeFi lending, DEX operation, mining, node operation, validator activity, or asset tokenization was identified in this research pass. Stablecoin Regime Cambodia has no statute governing private stablecoin issuance, reserve requirements, redemption rights, disclosure, or systemic designation. Primary Instruments Cited National Bank of Cambodia, National Bank of Cambodia, Asia/Pacific Group on Money Laundering (APG) / FATF, Securities and Exchange Regulator of Cambodia, National Bank of Cambodia (NBC) Last Confirmed / Updated 2026-10-25 (30 sources in cumulative register) 9 of 9 categories Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### Cambodia: C1 Crypto LicensingAmberEnacted in forceModule confidence: Probable▾ Cambodia has no single comprehensive crypto-asset licensing statute. The operative regime is built from (a) a May 2021 tripartite Joint Statement (NBC, then-Securities and Exchange Commission of Cambodia, and the General-Commissariat of National Police) declaring unlicensed crypto trading/settlement penalisable, and (b) an NBC Prakas of 26 December 2024 restricting banks and payment service providers from facilitating unlicensed cryptoasset transactions. SERC's separate rules are understood to target security-token offerings narrowly and were not independently verified in full text during this pass. There is no operative general VASP registration/licensing registry. Open gap — crypto-int-1 Has the NBC-SERC joint virtual-asset framework been published as a formal Prakas/Circular, and under what instrument number? Not located this cycle. no under-indexing note recorded Horizon · 2027-Q1 (± a year) CASP licensing procedures under Clause 20 not yet published Adopted · Tier 2 source Horizon · 2027 (± more than a year) Law on the Management of Virtual/Digital Assets drafting initiated Proposed · Tier 3 source Horizon · 2027-Q1 (± a year) CASP licensing procedures under Clause 20 not yet published Adopted · Tier 2 source Horizon · 2026-Q4 (± a quarter) Law on the Management of Virtual Assets and Digital Assets targeted for completion Consultation · Tier 1 source Horizon · 2026-Q4 (± a quarter) NBC/SERC scope-defining virtual-asset regulation expected Proposed · Tier 2 source Horizon · 2026-11 (± a quarter) Draft comprehensive virtual-asset law final draft and legislative approval Consultation · Tier 3 source Horizon · 2026-Q4 (± a quarter) Draft Law on the Management of Virtual Assets and Digital Assets final draft Consultation · Tier 3 source #### Crypto Licensing Cambodia's crypto-licensing framework underwent its most significant documented change to date with confirmation that the National Bank of Cambodia's Prakas B7-024-735 Prokor on the Management of Cryptoasset-Related Businesses and Activities permits commercial banks and payment settlement institutions to provide cryptoasset services, subject to prior NBC approval, at high confidence sourced to a detailed legal-update publication. This represents a structural liberalisation relative to Cambodia's prior blanket prohibition on crypto trading, replacing categorical prohibition with a permission-based supervisory model for regulated financial institutions. The framework, however, remains incomplete for entities outside the bank and payment-institution channel. Legal entities other than banks and payment institutions that wish to act as a Crypto Asset Service Provider must obtain a separate NBC licence, but the detailed approval procedures for that licence, specified under Clause 20 of the Prakas, are to be set out in a further regulation that had not been published as of this cycle. This is a materially important distinction: the Prakas itself is in force, and the bank/PSP permission it grants is operative now, but the CASP licensing pathway for non-bank, non-PSP entities is enacted in principle but not yet effective in practice, pending the implementing procedures. Any assessment of Cambodia as a market for a standalone crypto exchange, custodian, or other CASP-type business should treat this pathway as currently theoretical rather than operative. Consistent with this incomplete build-out, market access in practice remains narrow and sandbox-confined. Only two platforms, Royal Group Exchange and Cambodian Network Exchange, currently operate as authorised crypto platforms, and both do so under the NBC's FinTech Regulatory Sandbox rather than under a general licensing regime. This sandbox-scoped market structure indicates Cambodia's crypto-licensing regime today functions more as a controlled pilot than as an open licensing market, notwithstanding the Prakas's broader in-force permission structure for banks and PSPs. The regulatory direction is assessed as liberalising overall: Cambodia has moved from prohibition to permission for the bank/PSP channel, has established, if not yet operationalised, a CASP licence category for other entities, and has signalled further legislative ambition through the August 2026 Inter-Ministerial Working Group mandate to draft a comprehensive Law on the Management of Virtual Assets/Digital Assets. But the licensing framework's current state is best characterised as transitional and structurally incomplete: a functioning permission channel for banks and PSPs, a named-but-not-yet-operative licence category for other CASPs, and a sandbox-scoped market of exactly two authorised trading platforms. Institutions or entities evaluating Cambodia for crypto-business market entry should size their assessment to which of these three tracks is actually relevant to their intended business model, since the maturity, evidentiary basis, and regulatory certainty differ materially across the three. From a token-classification-adjacent perspective, though full classification detail sits outside this module's authorised scope this cycle, it is worth noting the licensing framework interacts directly with the Prakas's broader asset taxonomy: bank and PSP permission to provide cryptoasset services is calibrated to which category of asset the service touches, meaning the licensing question and the token-classification question are not fully separable in practice even though they are tracked as distinct modules in this monitor's spine. #### Outlook The single clearest signal that would move Cambodia's crypto-licensing regime from transitional to operative for non-bank entities is publication of the Clause 20 CASP licensing-procedure regulation; until that occurs, the CASP pathway should be treated as enacted but not yet effective rather than as a genuinely available market-entry route. The forthcoming comprehensive Law on the Management of Virtual Assets/Digital Assets, whose drafting process was initiated in August 2026, is the second major item to watch, given the possibility that it supersedes or restructures the current Prakas-based framework entirely; no draft text or implementation timeline has been confirmed, and this is assessed at a multi-year uncertainty band. Whether the current two-platform sandbox model is retained, expanded, or folded into a general licensing regime once Clause 20 procedures are published is a further open question with direct market-structure implications for prospective entrants. Read full sub-brief · 655 words Periodic update · new data 2026-10-25 #### Crypto Licensing Cambodia's crypto-licensing perimeter is presently defined by a combination of a two-tier classification instrument and a newer joint oversight arrangement, neither of which amounts to a comprehensive statute. Under the classification framework associated with NBC Notification/Prakas B7-024-735, Group 1 crypto-assets, meaning tokenised instruments and backed stablecoins, may be dealt in by NBC-supervised banks and payment service providers with central-bank approval, while Group 2 unbacked crypto-assets are excluded from bank balance sheets entirely. Layered on top of this, a joint oversight framework between the National Bank of Cambodia and the Securities and Exchange Regulator of Cambodia, reported as launched in late September 2026, establishes that NBC-supervised banks need central-bank approval for virtual-asset services, other entities need a SERC licence, and authorised firms become reporting entities to CAFIU. This joint framework has not been independently verified as a formally published Prakas or Circular, and its precise legal instrument number remains unconfirmed; the finding rests on a single secondary source. The practical restrictiveness of this perimeter is illustrated by enforcement: the National Bank of Cambodia revoked the payment-service licence of Huione Pay Plc and issued a public warning that non-compliant cryptocurrency transactions pose risks to the banking system. As of that action, no bank or financial institution is currently authorised to offer crypto-asset services in Cambodia, meaning the Group 1 pathway exists on paper but has not translated into an active population of authorised crypto-dealing banks. Separately, access to crypto-fiat conversion for Cambodian customers is reported to be restricted to NBC/SERC-approved local platforms, with major offshore exchanges blocked, though this restriction rests on a lower-tier secondary source and has not been independently corroborated. #### Outlook A draft comprehensive Law on the Management of Virtual Assets and Digital Assets is targeted for a final draft in the fourth quarter of 2026, timed ahead of the Black Swan Summit Cambodia in mid-November. This statute, if finalised, would replace or supplement the current Prakas-based perimeter with a dedicated legal framework, resolving much of the present uncertainty about whether virtual-asset licensing rests on administrative notice or statutory footing. Until that draft is finalised, the licensing perimeter should be treated as transitional: Group 1 dealing permissions exist in principle, but no authorised crypto-dealing bank or financial institution currently operates under them, and the underlying instrument behind the newer joint NBC-SERC framework remains unconfirmed. 3 earlier distinct update(s) Periodic update · new data 2026-10-19 #### Crypto Licensing Cambodia's crypto-licensing perimeter is built on two layers that are only partially joined up as at October 2026. The first, and only fully in-force, layer is NBC Prakas No. B7-024-735 Prokor, in effect from its signing on 26 December 2024. Under Article 26 of that Prakas, banks and payment service institutions require prior NBC approval before dealing in Group 1 cryptoassets, and other crypto-asset service providers require an NBC licence to operate at all. This remains the operative statutory floor for the sector. The second layer, announced jointly by the National Bank of Cambodia and the Securities and Exchange Regulator of Cambodia around 23-25 September 2026, splits licensing responsibility going forward: banks must obtain NBC approval to offer virtual-asset services, while other entities, including non-bank crypto-asset service providers, must secure a licence from SERC instead. This is a structural widening of the regulatory perimeter beyond banks and payment institutions to capture a broader set of market participants, but the scope-defining release that will specify precisely which activities and entity types fall under each track has not yet been published, so the practical reach of the SERC track cannot yet be assessed with precision. Entities that do become licensed or authorised under either track acquire AML/CFT reporting-entity status with obligations running to the Cambodia Financial Intelligence Unit. This is a meaningful compliance consequence of licensure, though the specific penalties applicable to unlicensed provision of virtual-asset services have not been located in primary sources reviewed this cycle, leaving a gap in the enforcement picture for non-compliant operators. Layered on top of both existing instruments is a forward-looking legislative project: an inter-ministerial working group is drafting a comprehensive Law on the Management of Virtual Assets and Digital Assets, targeting a final draft in November 2026 and legislative approval by end-2026. Its stated design, covering competent authorities, AML/CFT provisions and enforcement mechanisms, is intended to align with FATF's VASP expectations, suggesting the government's end objective is a single, comprehensive statute rather than the current patchwork of a 2024 Prakas plus a 2026 joint regulatory announcement. Notably, despite this expanding architecture, the National Bank of Cambodia's own December 2025 statement accompanying the Huione Pay licence revocation confirmed that no bank or financial institution in Cambodia was at that time authorised to offer cryptocurrency-asset services, a negative finding that underscores how much of the current framework remains aspirational rather than operational. #### Outlook The scope-defining regulatory release promised under the September 2026 NBC/SERC joint framework is the immediate item to watch; without it, the practical boundary of the SERC licensing track cannot be assessed. The targeted November 2026 final draft of the comprehensive virtual-asset law, with legislative approval anticipated by end-2026, represents the more structurally significant development: if enacted as drafted, it would replace the current fragmented permission-based perimeter with Cambodia's first comprehensive statutory licensing and AML/CFT regime for virtual-asset service providers. Periodic update · new data 2026-10-11 #### Crypto Licensing Cambodia's crypto-licensing perimeter rests on Prakas No. B7-024-735 Prokor, issued by the National Bank of Cambodia. Under this instrument, a bank or payment service institution must obtain prior NBC approval before holding own-account cryptoasset exposure, while a cryptoasset service provider is described as requiring NBC authorisation under a separately-stipulated Prakas. This two-track structure, one covering regulated financial institutions taking proprietary exposure and one covering dedicated CASPs, has been in force since 26 December 2024, but the implementing procedure for the CASP track specifically has not been confirmed as published this cycle; commentary from 2024 and 2025 continues to refer to it as forthcoming. Only two domestic platforms are reported operating under an NBC or Securities and Exchange Regulator of Cambodia sandbox authorisation as of 2026, identified in secondary commentary as Royal Group Exchange and Cambodian Network Exchange. Whether both operate under the same sandbox route or under distinct approval pathways was not resolved this cycle, and no NBC publication confirming issuance of the long-referenced CASP-procedure Prakas was located. The most recent concrete enforcement data point in this module is the NBC's confirmed revocation of Huione Pay Plc's licence, formalised by Letter No. 14,024,026 Ch.T dated 25 September 2024 and reported as taking effect by December 2025, issued alongside an NBC warning on cryptocurrency activities generally. This is the clearest evidenced instance of the NBC exercising licensing-enforcement power in the crypto-adjacent payments space, though whether any further CASP-specific enforcement action has occurred since that revocation was not confirmed this cycle. Taken together, the module presents an approval perimeter that is real and has been exercised at least once through revocation, but whose customer-facing CASP-authorisation procedure remains structurally unconfirmed as issued. This leaves the two sandboxed exchanges operating under an authorisation basis that is less than fully resolved against the eventual CASP regime the Prakas contemplates. #### Outlook The central unresolved question is whether the National Bank of Cambodia publishes the CASP customer-facing licensing procedure referenced in 2024-2025-era commentary on Prakas B7-024-735. Until that procedure is confirmed as issued, the authorisation basis for non-bank, customer-facing cryptoasset service providers in Cambodia remains structurally uncertain, notwithstanding the existence of a licensing perimeter for banks and payment institutions taking proprietary cryptoasset exposure. Periodic update · new data 2026-10-05 #### Crypto Licensing Cambodia's crypto-licensing architecture is in active transition. Under the existing Prakas No. B7-024-735 Prokor, commercial banks may provide crypto-asset services or transactions for their own account only within Group 1, or for customers subject to prior NBC approval; non-bank entities offering such services require an NBC CASP licence. This framework has been in force since the Prakas took effect in late December 2024 and remains the operative legal basis for crypto-asset activity in Cambodia today. The material development this cycle is the SERC-NBC joint statement of 23 September 2026, which announces an intent that non-bank legal entities offering virtual-asset services will require an SERC licence rather than, or possibly in addition to, the existing NBC CASP licence. The statement is framed as pending a subsequent regulatory release that will define the scope of permitted activities under the new SERC gateway — meaning the practical licensing requirement for non-bank CASPs cannot yet be fully specified. Whether existing NBC CASP licensees under Prakas B7-024-735 will be covered by, or superseded by, the forthcoming comprehensive digital-asset law also remains unresolved as of this statement. This joint statement sits ahead of a comprehensive Law on the Management of Virtual Assets and Digital Assets, targeted for completion in Q4 2026, which would convert the current dual-regulator interim-licensing posture into a single comprehensive statutory regime. Until that law is enacted, the practical licensing position for a non-bank entity seeking to operate in Cambodia is that an NBC CASP licence is the confirmed binding requirement today, with an SERC licensing track signalled as forthcoming but not yet operative. #### Outlook The principal item to watch is the subsequent regulatory release referenced in the 23 September joint statement, which should define the scope of activities requiring an SERC licence. The enactment timeline and final content of the comprehensive Law on the Management of Virtual Assets and Digital Assets, targeted for Q4 2026, will determine whether the current NBC CASP licensing track is retained, superseded, or run in parallel with a new SERC gateway for non-bank entities. 1 further periodic run re-emitted the standing brief unchanged and is not shown. Sources and findings (13) - T1[National Bank of Cambodia](https://www.nbc.gov.kh/english/news_and_events/news_info.php?id=380) — Authorities in Cambodia have announced that domestic investors are now required to obtain a license in order to purchase, sell or trade cryptocurrencies – activities that would be otherwise regarded as illegal. - T1[National Bank of Cambodia](https://www.nbc.gov.kh/english/news_and_events/news_info.php?id=380) — Any person or legal entity that propagates to mobilize funds, buys, sells, trades or settles Crypto Currencies without obtaining license from competent authorities shall be penalized in accordance with applicable laws. - T1[National Bank of Cambodia](https://www.nbc.gov.kh/english/legislation/prakas_new.php) — The NBC issued a Prakas on Transaction Related to Cryptoassets dated 26 December 2024, confirmed as a listed instrument on the NBC's official Prakas & Circulars index; per the injected seed disambiguation this instrument is a payments-perimeter restriction on banks/PSPs facilitating unlicensed cryptoasset transactions rather than a general prohibition on personal crypto holding. - T2[Asia/Pacific Group on Money Laundering (APG) / FATF](https://www.fatf-gafi.org/content/dam/fatf/documents/reports/fur/APG-Follow-Up-Report-Cambodia-2021.pdf) — The FATF/APG follow-up review found that Cambodia's 2018 inter-ministerial statement and NBC's 2014 press release cautioning against unlicensed crypto activity do not constitute an enforceable prohibition meeting FATF Footnote 44 criteria, and that it remains unclear whether Cambodian authorities have a legal basis to enforce a prohibition against VA/VASPs. - T1[National Bank of Cambodia (NBC)](https://www.disruptionbanking.com/2026/10/16/cambodia-crypto-regulation-enters-a-decisive-quarter-ahead-of-black-swan-summit-cambodia/) — Prakas B7-024-735 Clause 20: conditions and procedures for prior NBC approval and for licensing legal entities to act as CASPs are to be set out in a separate regulation, not yet confirmed issued. - T3[National Bank of Cambodia / Securities and Exchange Regulator of Cambodia](https://www.khmertimeskh.com/501800630/nbc-revokes-huione-pay-plcs-license-issues-warning-on-cryptocurrency-activities/) — A comprehensive KH Digital Asset Law is reported targeted for a final draft in November 2026, with legislative approval expected by end of 2026, splitting licensing between NBC (bank channel) and SERC (non-bank channel). - T2[National Bank of Cambodia (NBC)](https://www.dfdl.com/insights/legal-and-tax-updates/cryptoassets-regulation-introduced-by-the-national-bank-of-cambodia-nbc/) — Commercial banks and payment settlement institutions may provide cryptoasset services subject to prior NBC approval under Prakas B7-024-735. - T2[Crypto Asset Service Provider (CASP) licence](https://www.dfdl.com/insights/legal-and-tax-updates/cryptoassets-regulation-introduced-by-the-national-bank-of-cambodia-nbc/) — Legal entities other than banks/payment institutions must obtain an NBC licence to act as a CASP; detailed approval procedures under Clause 20 are to be set out in a separate, not-yet-published regulation. - T4 · Monaquatorium[Royal Group Exchange (RGX) / Cambodian Network Exchange (CNX)](https://monaquatorium.org/national-bank-of-cambodia-crypto-ban-the-truth-behind-the-restrictions) — Only RGX and CNX currently operate as authorised crypto platforms, under the NBC's FinTech Regulatory Sandbox. - T3[National Bank of Cambodia / SERC](https://www.disruptionbanking.com/2026/10/16/cambodia-crypto-regulation-enters-a-decisive-quarter-ahead-of-black-swan-summit-cambodia/) — NBC-supervised banks need central-bank approval for virtual-asset services; other entities need SERC licence; authorised firms become CAFIU reporting entities - T3[National Bank of Cambodia](https://www.khmertimeskh.com/501800630/nbc-revokes-huione-pay-plcs-license-issues-warning-on-cryptocurrency-activities/) — NBC revoked Huione Pay Plc's licence and warned that non-compliant cryptocurrency transactions pose risks to the banking system; no bank/FI currently authorised to offer crypto-asset services - T2[Virtual-asset licensees (NBC/SERC framework)](https://www.khmertimeskh.com/502030034/nbc-serc-unveil-regulatory-framework-for-crypto-firms) — Entities licensed/authorised under the NBC or SERC virtual-asset framework become AML/CFT reporting entities subject to the Cambodia FIU; specific penalty schedule for unlicensed provision not located ### Cambodia: C2 Token ClassificationAmberEnacted in forceModule confidence: Probable▾ Cambodia has no statutory token taxonomy distinguishing security tokens, e-money tokens, asset-referenced tokens, utility tokens, stablecoins or NFTs. The NBC's historical posture (a 2014 statement that it does not recognise cryptocurrencies) predates, and is not squarely reconciled with, the 2021 licensing expectation and 2024 Prakas. SERC's narrow security-token perimeter is the only classification-adjacent construct identified, and its content could not be independently verified. C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 8 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login) [View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Cambodia: C3 On-Chain Activity RegimeAmberEnacted in forceModule confidence: Probable▾ No dedicated Cambodian legal or regulatory treatment of staking, DeFi lending, DEX operation, mining, node operation, validator activity, or asset tokenization was identified in this research pass. The NBC's own blockchain deployment (Bakong) is a permissioned, centrally-operated payment backbone rather than a public on-chain activity the Prakas or Joint Statement contemplate regulating for private actors. C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Cambodia: C4 Stablecoin RegimeAmberEnacted in forceModule confidence: Probable▾ Cambodia has no statute governing private stablecoin issuance, reserve requirements, redemption rights, disclosure, or systemic designation. The NBC operates Bakong, a permissioned blockchain-based payment backbone; NBC officials have described it as a payment system rather than a central bank digital currency, and the BIS's central bank CBDC survey classifies Bakong as a prefunded electronic payment system rather than a true CBDC. This is a public-sector payments infrastructure, not a legal stablecoin regime applicable to private issuers such as fiat-backed or crypto-collateralised stablecoins. C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Cambodia: C5 Consumer ProtectionAmberEnacted in forceModule confidence: Probable▾ Cambodia's consumer-facing crypto protections are currently: (a) the 2021 Joint Statement's public risk warning on crypto-currency volatility, and (b) a newly-passed Law on Anti-Technology Fraud (approved by the National Assembly 30 March 2026, still awaiting Royal signature) which introduces criminal offences targeting online scams including crypto investment ('pig butchering') schemes. Separately, Cambodia-domiciled infrastructure (the Huione Group ecosystem) has been the subject of a U.S. FinCEN Section 311 finding and OFAC sanctions on a sitting Cambodian senator, indicating substantial real-world consumer-harm exposure that domestic consumer-protection law is only beginning to address. #### Consumer Protection Cambodia's crypto consumer-protection framework currently rests on a single binding rule under Prakas No. B7-024-735 Prokor: CASPs and licensed banks or payment institutions are prohibited from using customers' crypto-assets for their own institutional purposes. This custody-segregation prohibition has been in force since the Prakas took effect in late December 2024 and remains the operative consumer-protection safeguard today. The 23 September 2026 SERC-NBC joint statement names investor and consumer protection as a founding principle of the forthcoming comprehensive virtual-asset framework, suggesting an intent to build out protections beyond the current custody-segregation baseline. However, the statement does not itself specify what additional protections — such as market-abuse rules, order-handling standards, or disclosure requirements — would be introduced. As of this cycle, the custody-segregation prohibition remains the sole specific consumer-protection rule in force, and broader protections remain aspirational pending the comprehensive law targeted for completion in Q4 2026. #### Outlook The content of the subsequent regulatory release and the eventual comprehensive digital-asset law will determine whether Cambodia's consumer-protection framework expands beyond custody segregation to cover market conduct, disclosure, or dispute-resolution standards. Until then, the custody-segregation prohibition under Prakas B7-024-735 is the only specific protection a crypto-asset customer in Cambodia can rely upon. Read full sub-brief · 200 words No periodic updates recorded in this cycle Sources and findings (6) - T1[National Bank of Cambodia](https://www.nbc.gov.kh/english/news_and_events/news_info.php?id=380) — Investment in Crypto Currencies may incur losses due to volatility of its face value. - T4[The Block](https://www.theblock.co/post/396313/cambodias-parliment-passes-law-targeting-online-scam-compounds) — The Law on Anti-Technology Fraud introduces five new offenses aimed at rooting out modern online scams and crimes, like pig butchering and crypto investment schemes... All 112 members of Cambodia's parliament present voted to approve the legislation. - T4[The Block](https://www.theblock.co/post/396313/cambodias-parliment-passes-law-targeting-online-scam-compounds) — The new law, which still requires Cambodia's King Norodom Sihamoni for final signature, imposes two to five years in prison and fines of up to $125,000 for those convicted of online scams. - T2[U.S. Department of the Treasury / FinCEN](https://www.fincen.gov/news/news-releases/fincen-finds-cambodia-based-huione-group-be-primary-money-laundering-concern) — FinCEN's investigation identified that, in aggregate, Huione Group laundered at least $4 billion worth of illicit proceeds between August 2021 and January 2025. - T2[Cambodia CASP consumer-protection framework](https://www.dfdl.com/insights/legal-and-tax-updates/cryptoassets-regulation-introduced-by-the-national-bank-of-cambodia-nbc/) — No CASP-specific risk-disclosure or custody-segregation rules were identified for Cambodia this cycle. - T4[Cryptoasset Service Providers (CASPs)](https://www.datawallet.com/crypto/best-crypto-exchanges-cambodia) — CASPs may advertise services generally but are prohibited from promoting specific individual cryptoassets, and may not use customer assets for their own purposes ### Cambodia: C6 Tax TreatmentAmberEnacted in forceModule confidence: Probable▾ No crypto-specific tax guidance (capital gains, income tax, VAT/GST, withholding, or reporting obligation) was identified for Cambodia during this research pass. Cambodia's general Law on Taxation and VAT regime may in principle apply to crypto-related business income or supplies, but no primary source confirming application to cryptoasset transactions, mining income, or exchange fees was located. C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Cambodia: C7 Cross-Border TransferAmberEnacted in forceModule confidence: Probable▾ No domestic Cambodian statute imposing outbound crypto-asset transfer restrictions, cross-border reporting thresholds, or a cross-border travel-rule regime was identified. However, Cambodia-domiciled financial infrastructure has become a focal point of foreign enforcement: the U.S. FinCEN issued a Section 311 finding naming the Cambodia-based Huione Group a primary money-laundering concern, and OFAC has sanctioned a sitting Cambodian senator and dozens of associated entities tied to scam-compound networks operating partly via crypto. These are foreign (U.S.) regulatory/sanctions actions with a strong nexus to Cambodia rather than Cambodian domestic law, and are recorded here as sanctions-nexus context materially relevant to cross-border exposure. C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 7 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Cambodia: C8 AML/CFT RegimeGreenEnacted in forceModule confidence: Probable▾ Crypto subscribes to the FIM aml_ctf module fleet-wide; AML/CFT obligations are therefore NOT emitted as claims in this baseline. For disambiguation context only: Cambodia's general AML/CFT Law (2020) and Directive on Customer Due Diligence Measures (2021) apply to financial institutions and DNFBPs, supervised in part by the Cambodia Financial Intelligence Unit (CAFIU); FATF/APG reviewers found gaps in whether VA/VASP activity is captured with a risk-sensitive basis. This context is carried here for cross-reference only and should not be treated as a crypto_dr AML claim. C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Green), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Cambodia: C9 Commercial Activity unpopulated ▾ ## Commercial Activity The National Bank of Cambodia ordered the liquidation of Prince Bank PLC and suspended its operations on 8 January 2026. This followed the implication of Prince Bank's majority owner, Chen Bo, and Prince Group leader Chen Zhi in US fraud and money-laundering indictments. The event is recorded as a completed restructuring action, with Prince Bank PLC as the target and the National Bank of Cambodia as the acting authority; no transaction value or amount was disclosed in connection with the liquidation. The commercial significance of this action extends beyond conventional bank-resolution territory because of its direct crypto-sanctions nexus. The broader Prince Group network, of which Chen Zhi has been identified as leader, has separately been reported in connection with a US$14 billion bitcoin seizure carried out by the US Department of Justice in October 2025. The liquidation of a Cambodian bank tied to the same group and the same individual is therefore a domestic regulatory consequence running in parallel with an extraterritorial US enforcement action against the same network's digital-asset holdings, even though the two actions proceed under different authorities and different legal instruments. No further crypto-sector commercial transaction, such as an acquisition, investment round, or divestiture involving a Cambodian cryptoasset entity, was located this cycle beyond the Prince Bank liquidation itself. — Outlook: The matter to watch is whether any further Cambodian regulatory or judicial action follows the Prince Bank liquidation, particularly any asset-disposition process connected to the bank's cryptoasset-adjacent holdings or counterparties, and whether the US enforcement action against the broader Prince Group network produces any additional designation or asset action with a Cambodia nexus. Periodic update · new data 2026-10-25 #### Commercial Activity The single commercial-activity item identified this period is a partnership announcement between the National Bank of Cambodia and the Global Fintech Technology Network (GFTN), tied to the Black Swan Summit Cambodia scheduled for 15-16 November 2026. The stated purpose is to showcase the Bakong payment system and to discuss regulatory frameworks for digital-asset innovation. No capital amount was disclosed for this arrangement, and no equity, acquisition, or investment structure has been reported; the event is best characterised as an institutional convening and dialogue partnership rather than a disclosed financial transaction. As such, it does not itself alter the regulatory or licensing perimeter described elsewhere, though it does signal that the central bank is actively positioning Bakong and its digital-asset policy agenda within an international fintech-engagement context ahead of the comprehensive virtual-assets law expected later in the fourth quarter of 2026. #### Outlook No further commercial transactions, investment rounds, or disclosed-value deals involving a Cambodia-linked crypto-sector party were identified this period. The Black Swan Summit itself, scheduled for mid-November 2026, is the next dated event likely to surface additional commercial or regulatory signal, given its stated focus on digital-asset innovation frameworks. 1 earlier distinct update(s) Periodic update · new data 2026-10-19 #### Commercial Activity The principal commercial-activity event in Cambodia's virtual-asset space this cycle is not a transaction but a regulatory launch: the National Bank of Cambodia and the Securities and Exchange Regulator of Cambodia jointly launched a licensing and reporting framework for the virtual-asset sector around 23-25 September 2026. This is properly characterised as a regulatory event rather than a commercial one, since it establishes a permission structure rather than recording a deal, investment or funding round, and no transaction value attaches to it. The second notable development this cycle is the formation of an inter-ministerial working group tasked with drafting the comprehensive Law on the Management of Virtual Assets and Digital Assets, targeting a final draft in November 2026. Like the NBC/SERC framework launch, this is institutional and regulatory in character rather than commercial: it reflects government capacity-building around virtual-asset oversight rather than market activity by private participants. No disclosed mergers, acquisitions, investment rounds or funding transactions involving a Cambodian virtual-asset-sector party were identified in the material reviewed this cycle. The absence of commercial transaction activity should be read alongside the regulatory-perimeter developments above: Cambodia's virtual-asset market structure is currently being built from the regulatory side, with the private commercial layer not yet generating disclosed deal activity in the sources available this cycle. #### Outlook Whether the NBC/SERC licensing framework and the prospective comprehensive virtual-asset law will catalyse disclosed commercial activity, licensing applications, partnerships or investment, among virtual-asset firms targeting Cambodia is the principal item to watch. The scope-defining release expected to follow the September 2026 joint announcement may be the trigger point at which commercial entities begin to engage visibly with the new licensing tracks. Sources and findings (3) - T4[Prince Bank PLC](https://en.wikipedia.org/wiki/2026_in_Cambodia) — NBC ordered liquidation of Prince Bank PLC and suspended its operations on 8 January 2026, after majority owner Chen Bo and Prince Group leader Chen Zhi were implicated in US fraud/money-laundering indictments - T3[National Bank of Cambodia](https://cambodiainvestmentreview.com/2026/10/23/cir-partners-with-black-swan-summit-cambodia-2026-to-spotlight-fintech-and-global-connectivity) — NBC and GFTN announced a partnership tied to Black Swan Summit Cambodia (15-16 Nov 2026) to showcase Bakong and discuss regulatory frameworks for digital-asset innovation - T2[National Bank of Cambodia / Securities and Exchange Regulator of Cambodia](https://www.khmertimeskh.com/502030034/nbc-serc-unveil-regulatory-framework-for-crypto-firms) — NBC and SERC jointly launched a licensing and reporting framework for the virtual-asset sector (announced/in force as policy, pending scope-defining release); no transaction value as this is a regulatory event