BGA Cambodia Director Dr. Siriwat Chhem wrote an update to clients on Cambodia’s new regulatory framework for virtual assets.

Context 

  • The Securities and Exchange Regulator of Cambodia (SERC) and the National Bank of Cambodia (NBC) issued a joint statement September 23 to establish a regulatory framework for virtual assets and virtual asset service providers. The framework marks an important shift from Cambodia’s predominantly cautionary stance toward a regulated model centered on investor and consumer protection, market integrity and support for innovation.
  • Under the framework, NBC-licensed commercial banks must obtain prior NBC authorization before providing virtual asset services, while other entities must obtain a prior license from SERC. Authorized or licensed providers will also become reporting entities subject to Cambodia’s requirements for anti-money laundering, countering the financing of terrorism and proliferation financing.
  • The joint statement applies to entities providing virtual asset services from Cambodia and to those offering such services to persons or entities within Cambodia. Virtual assets are broadly defined as cryptography and distributed ledger digital representations of value that can be traded, transferred or used for payment or investment purposes.

Significance 

  • The NBC will oversee commercial banks seeking to provide virtual asset services, while the SERC will license non-bank providers, with the precise scope of permitted activities to be defined through subsequent regulations. The authorities intend to develop clearer rules covering the issuance, exchange, trading and custody of virtual assets while coordinating supervision under a “same activity, same risk, same regulation” principle.
  • The authorities reaffirmed that virtual assets are not recognized as legal tender in Cambodia and are neither guaranteed by the government nor the central bank. The joint statement also reiterates concerns around consumer protection, price volatility, fraud, money laundering, terrorist financing, tax evasion and cybercrime.
  • Companies solely providing underlying infrastructure, including internet hosting, cloud computing, computing resources, transaction validation or network operations, are outside the scope if they do not directly provide virtual asset trading, investment or payment services to customers. This distinction is particularly important for global cloud, data center, blockchain infrastructure and enterprise technology providers operating in or serving Cambodia.

Implications

  • Multinational corporations offering payments, financial services, digital wallets, investment products or other solutions involving virtual assets should assess whether their activities fall within the NBC or SERC regulatory perimeter, including services offered cross-border to customers in Cambodia. Firms should anticipate licensing or authorization requirements, enhanced anti-money laundering and countering the financing of terrorism obligations, customer protection controls and potentially more detailed implementing regulations.
  • Technology companies appear to have greater regulatory clarity because pure infrastructure provision is expressly excluded, but the exemption may cease to apply where the company directly facilitates customer-facing trading, investment or payment services involving virtual assets. Technology firms should therefore distinguish carefully between infrastructure, software and technical enablement on the one hand and regulated financial or virtual asset services on the other.
  • The joint statement signals that Cambodia is moving toward regulated participation rather than an outright prohibition of virtual asset activity, potentially creating new opportunities for licensed financial institutions, fintech companies and technology providers. Multinational corporations should monitor forthcoming NBC and SERC regulations closely, because these will determine the permitted activities, licensing conditions and operational requirements that ultimately shape market entry and investment opportunities.

We will continue to keep you updated on developments in Cambodia as they occur. If you have any comments or questions, please contact BGA Cambodia Director Dr. Siriwat Chhem at schhem@bowergroupasia.com.

Best regards, 

BGA Cambodia Team

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Director

Siriwat is an advisor, a consultant and a former think tank director with expertise in digital transformation, artificial intelligence (AI) and cyberdiplomacy. His professional background includes board positions, executive roles, advisory work and consulting engagements across government, industry and academia. He helps BGA clients navigate the complex global cyberspace to harness digital technology innovation for sustainable development. Prior to joining BGA, Siriwat was founding director of the Asian Vision Institute Center for Inclusive Digital Economy, where he led a team of 50 members, directed the publication of two books and 80 policy papers and initiated national research projects and capacity-building ... Read More