Cambodia#
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.
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.
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)
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.
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.
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)
- T1National Bank of Cambodia — <cite index="98-2">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. retrieved M4 binding in force
- T1National Bank of Cambodia — <cite index="8-2">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. retrieved M4 binding in force
- T1National Bank of Cambodia — 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. retrieved M4 binding in force
- T2Asia/Pacific Group on Money Laundering (APG) / FATF — 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. retrieved M3 non-binding
- T1National Bank of Cambodia (NBC) — 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. retrieved M4 binding in force new
- T3National Bank of Cambodia / Securities and Exchange Regulator of Cambodia — 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). retrieved M4 non-binding in force
- T2National Bank of Cambodia (NBC) — Commercial banks and payment settlement institutions may provide cryptoasset services subject to prior NBC approval under Prakas B7-024-735. retrieved M5 binding in force new
- T2Crypto Asset Service Provider (CASP) licence — 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. retrieved M4 binding enacted not yet effective new
- T4 · MonaquatoriumRoyal Group Exchange (RGX) / Cambodian Network Exchange (CNX) — Only RGX and CNX currently operate as authorised crypto platforms, under the NBC's FinTech Regulatory Sandbox. retrieved M3 non-binding new
- T3National Bank of Cambodia / SERC — NBC-supervised banks need central-bank approval for virtual-asset services; other entities need SERC licence; authorised firms become CAFIU reporting entities retrieved M4 binding in force new
- T3National Bank of Cambodia — 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 retrieved M3 binding in force
- T2Virtual-asset licensees (NBC/SERC framework) — 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 retrieved M4 binding in force new