On 23 September 2026, the National Bank of Cambodia (“NBC“) and the Securities and Exchange Regulator of Cambodia (“SERC“) jointly issued a Statement on the Management of Virtual Assets and Virtual Asset Service Providers (“Joint Statement“), with the aim to provide guidance on the regulatory framework applicable to persons or entities providing services from within Cambodia, or offering services to persons or entities within Cambodia, in relation to Virtual Assets.
Below is a summary of the key aspects of the Joint Statement.
1. Background and Rationale
The NBC and the SERC have observed the rapid growth of virtual asset markets, used both as speculative investments and as a perceived means of payment. They flagged risks to macroeconomic stability, investor and consumer protection, market integrity, and financial crime, including fraud, price volatility, money laundering, sanctions evasion, terrorism financing, tax evasion and cyber-crime.
The Joint Statement builds on a 2018 statement by the SERC, NBC and General Commissariat of National Police, which warned of cryptocurrency risks and stated that unlicensed mobilization, buying, selling, trading or settlement of cryptocurrencies would be penalized under applicable law. The regulators noted these risks have since grown with the global expansion of Virtual Assets, their cross-border nature, and their growing links to mainstream finance.
At the same time, the Joint Statement recognizes that regulating Virtual Asset activities may boost market transparency, broaden access to financial services, support economic empowerment and contribute to public revenues, consistent with Cambodia’s Digital Economy and Society Policy Framework 2021-2035 and FinTech Development Policy 2023-2028.
2. Key Defined Term
Virtual Asset refers to a digital representation of value that depends primarily on cryptography and a distributed ledger or similar technology and can be digitally traded or transferred for payment or investment purposes. A Virtual Asset may also be referred to as a Digital Asset or Cryptoasset.
3. Core Regulatory Principles
The NBC and the SERC intend to develop a coordinated regulatory framework applicable to Virtual Asset-related activities, based on the following core principles: (a) investor and consumer protection; (b) market integrity; and (c) supporting innovation.
4. Licensing and Authorization Requirements
| Type of Provider | Requirement |
|---|---|
| Commercial banks licensed by the NBC | Must obtain prior authorization from the NBC before providing services to customers involving the use of Virtual Assets. |
| Entities other than NBC-licensed commercial banks | Must obtain a prior license from the SERC before providing services to customers involving the use of Virtual Assets. |
The scope of activities permitted under each authorization or license will be determined in separate regulations to be issued by the NBC and the SERC respectively.
5. AML/CFT Obligations as Reporting Entities
Entities licensed or authorized by the SERC or the NBC under the above frameworks will be designated as Reporting Entities and will be subject to the regime established by the Cambodia Financial Intelligence Unit, together with all related duties and obligations under the Law on Anti-Money Laundering and Combating the Financing of Terrorism and the Law on Combating the Financing of Proliferation of Weapons of Mass Destruction.
6. Collaboration, Coordination and Next Steps
The NBC and the SERC have committed to an efficient, coordinated supervisory framework for Virtual Asset-related financial instruments, market participants and infrastructure, focused on compliance, accountability, harmonization and enforcement. A key priority is clear rules on the issuance, exchange, trading and custody of Virtual Assets, while keeping bad actors out of the market.
The two regulators will consult regularly on matters of common interest and align requirements for licensed Virtual Asset-related services, to reduce regulatory burden and prevent arbitrage, under the “same activity, same risk, same regulation” principle. They will also periodically review the Joint Statement in light of industry feedback as the regime evolves.
7. Affirmation of Public Warnings
The public is reminded that, under the laws applicable in Cambodia, Virtual Assets are not recognized as legal tender and are not guaranteed by the government or the central bank. Virtual Assets are highly volatile and carry significant risks. The public is advised to carefully evaluate the risks associated with any dealings in Virtual Assets and to make informed investment decisions.
8. Scope Carve-Out
Entities that solely engage in the operation of a Virtual Asset network, such as hosting or offering internet network services and infrastructure, offering computing resources such as cloud services, and/or creating, validating and broadcasting blocks of transactions, and that do not directly provide trading, investment or payment services to customers in relation to Virtual Assets, fall outside the scope of the Joint Statement.
Please bear in mind that the Joint Statement signals the direction of the forthcoming Virtual Asset regulatory regime in Cambodia. Entities currently operating in, or planning to enter, the Virtual Asset space in Cambodia should monitor the forthcoming draft Law on the Management of Virtual Assets.
Please refer to our client alerts regarding the specific regulation issued by the SERC and NBC on virtual asset and crypto asset.
The information provided in this alert is for general information purposes only and does not constitute legal advice. Legal advice should be sought in relation to specific circumstances.