1. Does Cambodia have a sanctions regime in place?

Yes, Cambodia has adopted laws and regulations in relation to a sanctions regime, notably the Law on Anti Money Laundering and Combating Terrorist Financing dated 27 June 2020 (the “AML Law”), the Law on Combating the Financing of Weapons of Mass Destruction Proliferation dated 27 June 2020 (the “LOCFW Law”), and other relevant Sub-Decrees, Prakas and Guidelines related to anti-money laundering and combating terrorist financing in order to implement UNSC Resolutions and recommendations of other international organizations.

2. Does Cambodia implement UN sanctions?

Yes, terrorists or organizations listed under UNSC Resolution 1267 are subject to immediate court orders for the freezing of their funds and property, pursuant to Article 4 of the Sub-decree on Freezing of Property of Designated Terrorists and Organisations (2014) (the “2014 Sub-decree”).

Further, individuals and entities listed under certain proliferation-related sanctions are subject to immediate court orders for the freezing and/or seizure of their funds and property pursuant to the LOCFW Law. These proliferation-related sanctions include those imposed under UNSC Resolutions 1718, 1737, 1874, 2087, 2094, 2231, 2270, 2321, 2371, 2375, 2397 and subsequent resolutions.

3. Does Cambodia implement an autonomous sanctions regime?

Yes, pursuant to Article 9 of the 2014 Sub-decree and Article 5 of the LOCFW Law, the Minister of Justice may order the General Prosecutor of the Appeal Court or the Prosecutor of the First Instance Court to identify and assess persons to be listed or delisted. When any person is listed by the Court, the Court will issue an order to freeze the properties and funds.

4. What is the nature of the sanctions regime in Cambodia?

As mentioned above, sanctions regime in Cambodia are governed by laws, regulations and guidelines and are enforced through Court orders. Pursuant to the 2014 Sub-decree and the LOCFW Law, any person holding targeted properties and funds shall freeze such properties and funds without delay after receiving a Court order.

5. Does Cambodia maintain a list of sanctioned individuals and entities?

Yes. The 2014 Sub-Decree states that the Ministry of Justice must publish the listing and delisting of designated persons on its website. The CAFIU must also disseminate the listing or delisting of UN designations to reporting entities, by publishing the list on its website.

6. Are there any other lists related to sanctions?

There are no other lists related to sanctions per se, but Cambodia maintains a highly confidential list of people who have had a suspicious action reported against them.

7. Does Cambodia have a licensing or authorization system in place?

The CAFIU has implemented an electronic reporting system that enables entities to report cash transactions and suspicious transactions more efficiently.

8. What are the consequences for a breach of sanctions in Cambodia?

Disciplinary punishment against reporting persons who fail to comply with Cambodian anti-money laundering laws may include warning, reprimand, prohibition or constraint of operation, confiscation of business license, request for termination of concerned manager or official, and fines. Violation of a Court order to freeze assets or ban the transfer of assets pursuant to the LOCFW Law may be subject to imprisonment of up to 15 years and fines of up to KHR 2 hundred million (approximately USD 50,000). Legal persons may be fined up to KHR 4 hundred million (approximately USD 100,000). Punishment against persons who are required to provide information to CAFIU may include a fine of between US$2,500 and US$25,000 and imprisonment of up to one month. The courts may order confiscation of property related to money laundering or terrorist financing offenses. Under the Criminal Code, individual money launderers may face imprisonment of two to five years, together with fines. Under the AML Law, a person engaging in the financing of terrorism may face imprisonment of ten to twenty years. Legal entities may be criminally responsible for offenses committed on their behalf.

9. Who are the relevant regulators in India and what are their contact details?

The National Coordination Committee on Anti-Money Laundering and Financing of Terrorism and Combating the Financing of Proliferation of Weapons of Mass Destruction (“NCC”) serve as the high-level coordination mechanism for implementing the AML Law and the LOCFW Law. The CAFIU within the National Bank of Cambodia is the secretariat of the NCC for sanctions and anti-money laundering enforcement. Cambodian Financial Intelligence Unit PO Box: 67, 22-24 Preah Norodom Boulevard, Phnom Penh Cambodia T: (+855) 23 427 933 F: (+855) 23 427 933 E: (for submitting reports) / (for other communications)


Contributor law firm

Nearirath Sreng

Deputy Head, Banking, Finance & Technology Practice Group

DFDL Cambodia

No. 30, Norodom Boulevard

4th Floor BRED Bank Building

Sangkat Phsar Thmey 3

Khan Daun Penh (PO Box 7)

120203 Phnom Penh


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