Issue Description
The regulatory landscape for digital assets in Cambodia is currently defined by fragmentation and ambiguity, primarily stemming from conflicting stances between the National Bank of Cambodia (NBC) and the Securities and Exchange Regulator of Cambodia (SERC). While the NBC took a progressive step by issuing the Prakas B7-024-735 Prokor on Transactions Related to Cryptoassets in late 2024, which ostensibly allows banks to deal with certain asset classes (Group 1), the central bank still maintains a restrictive posture against unbacked cryptocurrencies and broader adoption. Conversely, the SERC has actively promoted innovation by issuing 7 Financial Sandbox Licenses to digital asset exchange operators, signaling an openness to treat these assets as regulated financial instruments. These differences in regulatory scope and institutional mandates between the NBC and SERC have contributed to regulatory uncertainty in implementation. Although digital asset service providers may be licensed by the SERC, access to banking services necessary for settlement and fiat conversion remains limited in practice, reflecting the NBC’s cautious supervisory stance and differing regulatory interpretations.
Impact on business
This unclear regulatory environment creates a diverse set of consequences by disadvantaging legitimate digital asset markets while inadvertently favouring misuse by ill-intentioned actors. Legitimate businesses face difficulties in securing reliable banking relationships, leading to legal and operational uncertainty and, in some cases, discouraging continued market participation. In the long run, Cambodia risks missing opportunities to benefit from fintech innovation and investment.
More critically, this lack of regulatory clarity has been aggressively exploited by illicit and criminal networks. The absence of a unified and consistently enforced framework has created opportunities for illicit actors to exploit Cambodia as a hotspot for crypto-related crimes. These activities have adversely affected the kingdom’s international reputation, discouraged institutional investment, and resulted in heightened scrutiny from global financial institutions and the Anti-Money Laundering Authority (AMLA), complicating cross-border transactions for Cambodian businesses.
Recommendation
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Establish a unified legal framework classifying digital assets as securities under the jurisdiction of SERC while harmonising their regulations with NBC.
To resolve this impasse and strengthen market confidence, we respectfully encourage the Royal Government to expedite the establishment of a unified legal framework that clearly classifies digital assets as securities under the jurisdiction of the SERC. We further recommend that the NBC and SERC harmonise their regulations to explicitly enable licensed digital asset exchanges to access banking services and conduct settlement operations with commercial banks. Such access should be contingent upon the robust implementation of Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures. By formalising banking relationships for licensed operators, the government can reduce opportunities for illicit activity, protect consumers, and foster a safe, transparent, and well-regulated digital asset ecosystem that contributes to sustainable economic growth.
Royal government of Cambodia
National Counterparts
Securities and Exchange Regulator of Cambodia
National Bank of Cambodia
Contributors
