--- title: "Cambodia (KH) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/cambodia/ source_html: /jurisdictions/cambodia/index.html description: "Financial integrity intelligence for Cambodia (KH): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: e48667caecd0e4d7c409890735fb936d01c771e62099d4f08bc4a0c00cbb509d generator: "fe-fleet/md-twin@1.0" --- # Cambodia (KH) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Cambodia KH Domains covered 8 of 8 Sources 158 Role actions 8 Horizon <90d 2 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Permissive Cambodia operates under the 2020 AML/CFT Law and 2021 CDD Directive, supervised by CAFIU (FIU), the National Bank of Cambodia, and the Ministry of Economy and Finance. More Delisted from the FATF grey list in February 2023, but casino, real estate, DNFBP and virtual-asset supervision remain weak amid a cash-based, dollarized economy that enables large-scale scam-compound and crypto-laundering infrastructure operating with apparent elite protection. Key deficiencies - Limited regulation and oversight of casino, real estate and financial sectors exploited for laundering scam proceeds - No comprehensive public beneficial ownership registry; shell-company layering (100+ entities in the Prince Group case) obscures true ownership - Weak fit-and-proper and risk-based supervision of DNFBPs per successive APG follow-up reports - Elite/political protection of scam-compound operators (senators, oknha, family ties to senior officials) undermining domestic prosecution - No dedicated virtual asset service provider (VASP) licensing/supervision regime commensurate with the scale of crypto-enabled fraud Recent developments (18m) - October 14, 2025: coordinated OFAC/OFSI/DOJ/FinCEN action - Prince Group TCO designation (146 targets), Chen Zhi indictment, $15bn bitcoin forfeiture, Huione Group Section 311 final rule - January 2026: Chen Zhi arrested in Cambodia and extradited to China rather than the United States - April 23, 2026: OFAC designation of Cambodian Senator Kok An and 28 individuals/entities including Heng Feng Cambodia Bank - June 2026: UK widened sanctions on additional Prince Group-linked individuals and London properties; OFAC added further Prince Group TCO designations and issued an OFAC-OFSI comparative guidance overview Brief ## Lead signal #### Lead Signal Cambodia remains the focal point of a widening, but legally divergent, sanctions campaign against the Prince Group and associated Jin Bei Group network. On 23 June 2026 the US Treasury's Office of Foreign Assets Control expanded its transnational-criminal-organisation designation of the Prince Group, adding nine individuals and twenty-six entities and naming Hu Xiaowei as the networks second-in-command, with a parallel FinCEN Section 311 action reported alongside it. The European Union moved separately, designating Prince Holding Group and its chairman Chen Zhi under the EU Global Human Rights Sanctions Regime on 31 July 2026, citing at least ten scam compounds built and operated throughout Cambodia, with a further listing reported in early August adding the Jin Bei Group, an associated individual, and an armed group operating in the border region. The two actions rest on different legal bases, run on different timetables, and have not yet been reconciled into a single multilateral designation list, which is itself the structurally significant fact: enforcement pressure on Cambodia's scam-compound economy is intensifying, but through parallel unilateral tracks rather than a coordinated international framework. Read full brief #### Lead Signal Cambodia remains the focal point of a widening, but legally divergent, sanctions campaign against the Prince Group and associated Jin Bei Group network. On 23 June 2026 the US Treasury's Office of Foreign Assets Control expanded its transnational-criminal-organisation designation of the Prince Group, adding nine individuals and twenty-six entities and naming Hu Xiaowei as the networks second-in-command, with a parallel FinCEN Section 311 action reported alongside it. The European Union moved separately, designating Prince Holding Group and its chairman Chen Zhi under the EU Global Human Rights Sanctions Regime on 31 July 2026, citing at least ten scam compounds built and operated throughout Cambodia, with a further listing reported in early August adding the Jin Bei Group, an associated individual, and an armed group operating in the border region. The two actions rest on different legal bases, run on different timetables, and have not yet been reconciled into a single multilateral designation list, which is itself the structurally significant fact: enforcement pressure on Cambodia's scam-compound economy is intensifying, but through parallel unilateral tracks rather than a coordinated international framework. This matters because the underlying conduct, the operation of scam compounds under cover of Cambodian corporate and casino licensing, sits precisely at the intersection of sanctions architecture and the enabler-jurisdiction weaknesses that Cambodia has struggled to close. The divergence between the US and EU legal bases for action against what appears to be an overlapping set of principals and entities is worth tracking as its own pattern, since it shapes how financial institutions build sanctions-screening logic when authoritative lists do not converge. #### Other Developments Domestic licence enforcement continues alongside foreign sanctions pressure. Cambodia's Commercial Gambling Management Commission revoked Casino Licence No. 248 held by Casino YING HUANG in Preah Sihanouk province, after finding links to online-scam activity and the illegal possession of weapons and narcotics. This is a confirmed, primary-sourced action by the domestic regulator and sits alongside the foreign designations as part of the same broader enforcement picture, even though it proceeds under wholly separate domestic legal authority. FATF follow-up findings remain unresolved even as Cambodia reports efforts to avoid re-listing. Cambodia exited the FATF grey list in February 2023, having been listed twice previously, and is a member of the Asia/Pacific Group on Money Laundering. A FATF follow-up report from August 2023 continued to find weaknesses in fit-and-proper testing of casinos, lawyers and accountants, the professional and sectoral gatekeepers most exposed to the scam-compound economy. Trade press reporting characterises Cambodia as intensifying enforcement ahead of a further evaluation cycle specifically to avoid a third grey-list placement, but FATF itself has not yet re-assessed the jurisdiction on this point, so the enforcement-intensity narrative and the formal compliance record have not yet converged. A sole operative crypto-AML gateway persists while a broader digital asset law is drafted. The National Bank of Cambodia's Prakas B7-024-735 remains the only functioning crypto-asset AML gateway for bank and payment-service-provider channel activity, under which authorised firms become financial-intelligence-unit reporting entities. Trade press reporting indicates a comprehensive Digital Asset Law is targeted for a final draft in November 2026, with legislative approval anticipated by the end of 2026, which would extend regulatory perimeter beyond the current bank/PSP-channel Prakas gateway to a wider range of digital-asset activity. #### Cross-Monitor Connections The Prince Group and Jin Bei Group designations connect directly to conflict-finance and state-capture concerns tracked elsewhere in the fleet: the scam-compound economy operates in border areas with reported links to an armed group, placing financial-integrity findings here adjacent to territorial-control and extractive-economy signals followed by sibling monitors. The sanctions divergence between Washington and Brussels is also a useful case study for any monitor tracking multilateral-versus-unilateral enforcement architecture, since the same underlying conduct is being addressed through non-aligned legal instruments on non-aligned timetables. Separately, the prospective Digital Asset Law sits at a natural seam with payment-infrastructure tracking, since a widened crypto perimeter in Cambodia would affect how payment and banking channels interact with digital-asset activity going forward, though that connection is noted here only as a structural adjacency, not a finding in its own right. #### Outlook The sanctions picture is likely to keep escalating on parallel tracks: further OFAC and EU Council actions against the Prince Group/Jin Bei Group network should be expected given the pattern established across 2025 and 2026, without assurance that the two regimes will align on scope or named entities. Cambodia's domestic casino-licence revocation campaign is probable to continue as the visible enforcement response to FATF-identified weaknesses, but whether this satisfies FATF's own re-assessment criteria will not be clear until FATF conducts its next evaluation; the gap between enforcement activity and formal compliance recognition is the element to watch. On the crypto side, the targeted November 2026 final draft of the Digital Asset Law, with legislative approval anticipated by the end of 2026, as scheduled, would mark a material extension of Cambodia's regulatory perimeter beyond the existing bank/PSP Prakas gateway; confirmation of enactment would be the next material trigger for this domain. Earlier periodic briefs (6) 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Cambodia's sanctions exposure escalated materially on two separate tracks that share a common target set but no common legal basis. The United States Treasurys Office of Foreign Assets Control, on 23 June 2026, expanded its October 2025 Prince Group Transnational Criminal Organization designation by adding nine individuals and twenty-six entities, including Hu Xiaowei, described in the designation as second-in-command of the network. OFAC grounded the action in Executive Order 13581 as amended by Executive Order 13863. Separately, the EU Council designated Prince Holding Group and its chairman Chen Zhi under its Global Human Rights Sanctions Regime on 31 July 2026, with a related designation of Jin Bei Group and Zhu Zhongbiao following in early August 2026; the supporting reporting describes at least ten scam compounds operated throughout Cambodia. The two actions target overlapping networks on different legal footing and on different timetables, which is itself the structurally significant finding: two major sanctioning authorities converging independently on the same Cambodia-based scam-compound architecture is a stronger signal of structural entrenchment than either action alone, and the divergence in bases and dates is a standing feature of how cross-bloc sanctions architecture currently treats this target set rather than a one-off coincidence. The EU action rests on secondary reporting tiered below the OFAC press release itself: no Official Journal primary instrument was retrieved, so the EU designation is carried as probable rather than confirmed, while the OFAC designation is directly evidenced by Treasurys own release and stands as confirmed. #### Other Developments Overlapping target sets, divergent legal bases. The practical consequence of the US and EU proceeding on separate instruments against the same Cambodia-linked scam-compound networks is that obliged entities screening against sanctions lists face two distinct designation records, with different effective dates and different underlying predicate conduct descriptions, for what is substantively the same underlying illicit-finance architecture. #### Cross-Monitor Connections The scam-compound sanctions activity sits squarely at the intersection of financial-crime enforcement and the physical and human-trafficking infrastructure that generates the proceeds being laundered; the designations themselves cite human-trafficking and scam-operation conduct as the predicate, which is a conflict-finance and state-capture-adjacent pattern that a conflict-finance-focused monitor would track on the compound-operator side even though the sanctions action itself is the financial-integrity signal here. The overlapping-but-divergent US/EU designation pattern is also relevant to any payments-focused reading of Cambodia, insofar as the entities named sit within or adjacent to the same commercial and banking environment that payment-system developments in Cambodia operate in, though no payments-specific finding is drawn from this sanctions substrate here. #### Outlook The near-term signal to watch is whether the EU designation is followed by a retrievable Official Journal instrument, which would allow the current probable-confidence EU finding to be confirmed on a primary-source basis. Given that OFAC has already expanded its designation once since the original October 2025 action, a further expansion naming additional individuals or entities tied to the same network, as scam-compound operations in Cambodia remain under active scrutiny from multiple sanctioning authorities, is a plausible continuation of the pattern rather than a certainty. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Cambodian courts have frozen close to US$1 billion in assets linked to Prince Group, issued thirty-two arrest warrants, and sought INTERPOL assistance against twenty-nine ringleaders who have fled overseas. This domestic action follows, rather than leads, a sequence of US Treasury sanctions action: OFAC had already imposed sweeping sanctions on 146 targets within the Prince Group Transnational Criminal Organization, with related designations continuing into 2026. The sequencing is itself the finding: Cambodia's largest domestic asset-freeze and arrest-warrant action of the period arrived only after sustained foreign sanctions pressure on the same network, a pattern consistent with a reactive rather than self-initiated enforcement posture toward transnational scam-finance operations based on its territory. #### Other Developments A virtual-asset licensing framework emerges alongside the enforcement push. The National Bank of Cambodia and the Securities and Exchange Regulator of Cambodia are reported to have launched a joint oversight framework, in effect from late September 2026, under which NBC-supervised banks require central-bank approval to provide virtual-asset services, other firms require a SERC licence, and authorised firms become reporting entities to Cambodia's Financial Intelligence Unit. This finding rests on a single secondary source, and the underlying prakas or circular establishing the framework has not been independently retrieved, so its precise legal form and scope remain to be confirmed. Cambodia's standing position outside the FATF list of jurisdictions under increased monitoring continues. As of the FATF statement published 19 June 2026, the list of jurisdictions under increased monitoring contains 22 countries, and Cambodia is not among them, continuing its status since removal from that list in February 2023. Cambodia remains a member of the Asia/Pacific Group on Money Laundering. Separately, casinos and other gambling institutions are understood to be designated reporting entities under Article 5 of the 2020 AML/CFT Law, a standing feature of the regime rather than a new development. #### Cross-Monitor Connections The Prince Group asset-freeze action connects directly to gambling-sector enforcement activity in Cambodia this period, where casino inspections and online-gambling prohibitions are being enforced in parallel with the scam-network asset freeze, suggesting overlapping jurisdiction between gambling regulators and financial-crime enforcement bodies. The emerging virtual-asset licensing framework also connects to payments-sector developments, where the central bank has separately tightened oversight of non-bank e-money issuers; together these signal a single regulatory posture tightening across gambling, payments, and crypto sectors at once, each reinforcing the others' enforcement rationale. #### Outlook The FATF's October 2026 plenary outcome for Cambodia postdates the list consulted for this brief and should be checked for any change to Cambodia's monitoring status. The draft Law on the Management of Virtual Assets and Digital Assets, reported as targeted for a final draft in the fourth quarter of 2026, would also materially affect the digital-asset architecture described above if it supersedes the current prakas-based approach. Absent a Cambodian national risk assessment citation and absent independent verification of the underlying virtual-asset prakas, both the sanctions-enforcement narrative and the crypto-licensing narrative should be read as provisional pending further primary-source confirmation. 19 Oct 2026 · fim-2026-10-19 #### Lead Signal Cambodia's financial-integrity profile this cycle is defined by a widening gap between external sanctions and enforcement architecture and the pace of domestic Cambodian action. On 23 June 2026, OFAC expanded sanctions on the Prince Group Transnational Criminal Organization, designating nine individuals, including Hu Xiaowei as alleged second-in-command, and 26 entities spanning the UK, BVI, Hong Kong, Singapore and Thailand, under Executive Order 13581 as amended by Executive Order 13863. This expanded tranche builds on earlier designations and signals that the US and UK regard Prince Group's international financial-services footprint as a continuing target. Domestically, Cambodia's National Bank revoked the payment service provider licence of Tian Xu International Technology Plc, known commercially as CoolCash, on 3 August 2026, a licence that had been issued only in May 2024. The revocation follows the UK's March 2026 sanctioning of the company over its alleged links to the Prince Group and its alleged provision of financial services to the group, a sequence that places the Cambodian regulator's domestic licence action roughly five months behind the triggering UK sanctions action. #### Other Developments Casino-sector AML/CFT enforcement invoked directly. A 7 October 2026 Cambodian government press statement explicitly names the Anti-Money Laundering and Counter-Financing of Terrorism Law, alongside the Law on Anti-Online Scams, as the legal basis for a nationwide multi-agency casino inspection sweep across 16 provinces, framing unregulated online gambling as itself a form of technology-enabled scamming. This is a Confirmed, Tier 1 government statement and formally brings licensed casinos within AML/CFT reporting-entity enforcement focus. Long Bay allegations test enforcement completeness. An Al Jazeera investigative broadcast on 10 October 2026 alleges continuing online fraud, coercion, trafficking and drug activity at the Long Bay resort in Dara Sakor, Koh Kong, with alleged official protection, despite the stated October crackdown. This is probable-tier reporting from a single investigative broadcast, not yet corroborated by a Cambodian government document addressing the specific allegations, and it sits alongside continued independent reporting, including from Amnesty International, disputing the completeness of prior crackdown claims. Virtual-asset oversight brought within the AML/CFT perimeter. The National Bank of Cambodia and the Securities and Exchange Regulator of Cambodia published a joint virtual-asset oversight framework around 23-25 September 2026, splitting licensing between NBC (for banks) and SERC (for non-bank crypto-asset service providers) and bringing licensed entities within AML/CFT reporting-entity status to the Cambodia Financial Intelligence Unit. A draft Law on the Management of Virtual Assets and Digital Assets is targeted for a final draft in November 2026, stated to align with FATF VASP expectations. FATF posture stable but watched. Cambodia was removed from the FATF increased-monitoring list in February 2023 and remains off it as at this cycle. The Cambodia Financial Intelligence Unit's 2026 operational plan, dated 5 February 2026, reportedly seeks direct financial-sanctions tooling and expanded cooperation hotlines with China, Singapore and Mekong states ahead of FATF's fifth-round mutual evaluation scheduled for 2028, though this rests on a single Tier 3 secondary source without a located primary FIU document. #### Cross-Monitor Connections The casino-sector enforcement sweep and its explicit AML/CFT legal basis connect directly to world-payments' tracking of the National Bank of Cambodia's parallel tightening of the non-bank payments perimeter, including the Tian Xu licence revocation and the closed-loop e-money notification regime, both of which touch the same institutions now facing heightened AML/CFT scrutiny. The virtual-asset oversight framework likewise overlaps with world-payments' and crypto's tracking of the NBC/SERC split licensing announcement, read here specifically through the lens of the AML/CFT reporting-entity obligations that licensure creates. The advennt monitor's parallel tracking of the casino inspection sweep and the Long Bay allegations shares the same underlying factual basis as this brief's enabler-jurisdiction assessment, though advennt frames it through gambling-regulatory consequences rather than financial-crime architecture. #### Outlook The principal item to watch is whether Cambodian domestic enforcement action against Prince Group-linked entities accelerates to narrow the gap with US and UK sanctions designations, or whether the pattern of lagged domestic response, illustrated by the five-month gap between UK sanctions and the Tian Xu licence revocation, persists. The scope-defining virtual-asset regulatory release promised by NBC and SERC, and the targeted November 2026 final draft of the comprehensive virtual-asset law, will determine how quickly the new AML/CFT reporting perimeter for crypto-asset service providers becomes operationally meaningful. Cambodia's preparation for FATF's fifth-round mutual evaluation, scheduled for 2028, provides a structural deadline against which this cycle's casino-sector and virtual-asset developments should be read. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Cambodia's financial-integrity picture this cycle is defined by a widening gap between the architecture of its anti-money-laundering reporting system and its enforcement follow-through, set against an escalating foreign sanctions track targeting a Cambodia-based conglomerate. The Cambodia Financial Intelligence Unit, CAFIU, disseminates fraud-related financial intelligence that accounts for roughly 20 to 25 percent of its total disseminations, yet few of these spontaneous disclosures result in investigations, according to IMF-linked reporting. This structural pattern, where financial intelligence is generated but not consistently converted into enforcement action, is the more analytically significant finding this cycle than any single case outcome, because it describes how the system as a whole is functioning rather than one event within it. Running in parallel, the US Office of Foreign Assets Control expanded its sanctions against the Prince Group transnational criminal organisation on 23 June 2026, designating nine individuals and 26 entities and unmasking Hu Xiaowei as a key figure. This expands an October 2025 designation and sits alongside independent sanctions actions taken by the United Kingdom and South Korea against figures connected to the same network, indicating a broadening, multi-jurisdictional sanctions architecture responding to a single Cambodia-linked conglomerate. #### Other Developments CAFIU dissemination-to-investigation gap. IMF-linked reporting finds that fraud-related disclosures made up approximately 20 to 25 percent of CAFIU's total disseminations in recent years, but that few spontaneous disclosures resulted in investigations. The recommendation accompanying this finding calls for closer integration of Cambodia's AML strategy with its national anti-scam strategy, including greater use of FIU-to-FIU channels. The underlying IMF staff report itself was not independently retrieved this cycle; the finding rests on secondary press reporting of the IMF's assessment. FATF grey-list status unchanged. Cambodia remains off the FATF grey list, a status it has held since February 2023. The FATF/APG fifth-round mutual evaluation calendar places a possible onsite visit around November 2028 with plenary discussion potentially in July 2029, meaning no near-term FATF mutual-evaluation action is scheduled for Cambodia. Sanctions regime divergence. The United States, the United Kingdom and South Korea have each independently sanctioned individuals or entities connected to Prince Group, while Thailand, Taiwan and Singapore are separately pursuing domestic enforcement action. This pattern of parallel, uncoordinated national responses to a single network is itself a structural signal about the current state of international sanctions coordination on Cambodia-linked financial crime. #### Cross-Monitor Connections The Prince Group sanctions expansion connects directly to gambling-sector and crypto-sector monitoring: Prince Group's designation as a transnational criminal organisation has been separately linked to Cambodia-based casino and gambling-adjacent operations, and to a Cambodian bank, Prince Bank PLC, whose liquidation was ordered by the National Bank of Cambodia in January 2026 following related US indictments. The CAFIU enforcement-follow-through gap also bears on gambling-sector oversight, since the scam-centre activity generating the fraud disclosures CAFIU receives substantially overlaps with casino-linked enforcement actions being tracked separately. #### Outlook The principal indicator to watch is whether Cambodia's new Law on Combating Technology-Enabled Scams, which creates a dedicated scam-related money-laundering offence, produces a measurable increase in the proportion of CAFIU fraud disclosures that convert into investigations, which would address the IMF's core finding. On the sanctions track, further coordinated or independent designations from the US, UK, South Korea or other jurisdictions against Prince Group-linked individuals or entities would extend the current pattern of sanctions regime divergence rather than resolve it, absent a formal multilateral coordination mechanism. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Cambodia's casino-scam enforcement architecture moved from targeted licence action to confirmed sector-wide compliance this cycle. The Royal Government, acting through the CCOS Secretariat under Royal Government Order No. 01 BB (14 July 2025), revoked 18 casino licences and suspended 9 further licences pending investigation for links to online scam activity. In parallel, the CCTC Secretariat confirmed that 24 casinos across Preah Sihanouk, Banteay Meanchey and Svay Rieng provinces had ceased online and live-streamed casino betting, football betting, digital lotteries and virtual-cockfighting products following a 30 September 2026 deadline. Read as architecture rather than incident, this represents a structural escalation in enforcement capacity against the casino-enabled money-laundering channel, though the underlying scam-compound financial infrastructure that the casino sector has serviced remains only partially dismantled by these actions alone. #### Other Developments A parallel supervisory build-out in digital assets arrived alongside the casino enforcement. The National Bank of Cambodia and the Securities and Exchange Regulator of Cambodia issued a joint statement, dated 23 September 2026, establishing a dual-gateway supervisory intent for virtual-asset activity: NBC-licensed banks require NBC prior approval for crypto-asset services, while non-bank entities will require an SERC licence. The statement explicitly cites money-laundering risk as a driver, and is positioned ahead of a comprehensive Law on the Management of Virtual Assets and Digital Assets targeted for completion by end-2026. This sits on top of the existing interim Prakas B7-024-735 regime rather than replacing it outright, and marks a material build-out of the virtual-asset supervisory perimeter. Payment-sector supervision also tightened. The National Bank of Cambodia revoked the payment-institution licence of Tian Xu International Technology Plc (CoolCash Cambodia), the sixth such payment-institution licence revocation in nine months. Although resting on a single secondary-press source, this pattern of repeated revocations is consistent with, and plausibly connected to, the broader enforcement push against financial channels enabling the casino-scam nexus. #### Cross-Monitor Connections The casino licence revocations and online-betting cessation connect directly to the gambling-regulatory monitor's enforcement and payments findings, where the same CCOS and CCTC actions are read through a market-entry and licence-revocation-risk lens rather than an illicit-finance lens. The NBC-SERC joint statement on virtual assets connects to the crypto monitor's licensing coverage, where the same dual-gateway supervisory intent is read as a licensing-framework development rather than a money-laundering-risk driver. The payments monitor separately tracks the Tian Xu/CoolCash licence revocation as a payments-regulatory event; here it is read as one data point in a sustained enforcement pattern against financial channels serving illicit flows. #### Outlook Watch for whether the CCOS and CCTC enforcement actions extend beyond the 24 confirmed casinos and 18 revoked licences to additional venues, and whether any published CCOS/CCTC/CGMC gazette notice emerges to corroborate the press-reported enforcement narrative with a primary instrument. On the digital-asset side, the comprehensive Law on the Management of Virtual Assets and Digital Assets targeted for completion by end-2026 will determine whether the NBC-SERC dual-gateway intent becomes a binding statutory licensing perimeter or remains an interim supervisory posture layered on Prakas B7-024-735. 5 Sep 2026 · fim-2026-08-21 #### Lead Signal The United States Treasury has moved in two escalating tranches against the Prince Group transnational criminal organization headquartered in Cambodia, sanctioning 146 targets in October 2025 and expanding the designation on 23 June 2026 to nine individuals and 26 entities beneath principal Chen Zhi, including Hu Xiaowei. In parallel, FinCEN finalized a Section 311 rule severing Huione Group from the US financial system. Read together, this is not an isolated enforcement action but the systematic dismantling of a layered corporate architecture that used scam-compound proceeds to build a multinational financial footprint, and it anchors this cycle's material-change assessment for Cambodia's sanctions exposure. Both actions are assessed at high confidence, resting on primary Treasury press releases rather than secondary reporting. #### Other Developments A second-tranche designation exposes the offshore layering structure. OFAC's 23 June 2026 action named Hu Xiaowei as controller of BVI holding companies and a Hong Kong-based financial cluster used, per Treasury's designation, to route scam-victim proceeds beneath Chen Zhi's network, illustrating how the Prince Group architecture depended on enabler-jurisdiction opacity in the British Virgin Islands and Hong Kong rather than concealment within Cambodia itself. Cambodia's central bank has moved to contain crypto-enabled laundering channels. The National Bank of Cambodia's Prakas B7-024-735 channels licensed cryptoasset activity through two authorised platforms, while Cambodia's telecommunications regulator has blocked domestic access to Binance, Coinbase, and OKX, an infrastructure-level containment strategy assessed at high confidence as responsive to the virtual-asset laundering typologies associated with Huione Group. The containment strategy reflects a deliberate policy choice to restrict access to unlicensed offshore venues rather than to build out a comprehensive on-chain supervisory regime, a distinction that matters for how durable the containment proves against future circumvention. A reported liquidation order against Prince Bank remains only lightly sourced. Reporting attributes to the National Bank of Cambodia an order liquidating and suspending Prince Bank's operations following Chen Zhi's indictment; this rests on a single lower-tier source and should be treated as assessed rather than confirmed pending primary regulator confirmation. #### Cross-Monitor Connections The crypto-containment strategy documented here, Prakas-based licensing paired with exchange-access blocking, sits directly adjacent to the World Payments Monitor's coverage of Cambodia's evolving virtual-asset and e-wallet oversight, and to the Crypto monitor's tracking of the same Prakas licensing regime from a digital-asset-market perspective; both should be read as complementary lenses on a single regulatory event rather than independent developments. The underlying scam-compound network that generated the proceeds now subject to sanction also intersects with the Advennt gambling-regulatory monitor's coverage of Cambodia's casino-sector enforcement wave, where licensed and unlicensed venues alike have faced closure amid the same anti-scam crackdown; the sanctions and casino-enforcement tracks are best read as two faces of the same underlying network rather than unrelated developments. #### Outlook The pace of this cycle's designations, two tranches within roughly eight months, moving from the top-level organization to second-tier BVI and Hong Kong facilitators, suggests further downstream designations targeting remaining layering vehicles are plausible, though not yet evidenced. Cambodia's crypto-containment posture, built on infrastructure blocking rather than a comprehensive licensing statute, carries structural durability risk: exchange-access blocking is more easily circumvented than a codified licensing prohibition, and watch for whether the two-platform sandbox model expands or hardens into fuller statutory form. The unresolved sourcing gap around the Prince Bank liquidation is the most consequential single item to confirm next cycle, given its implications for the domestic banking sector's exposure to the same network. Domain intelligence (D1–D8) #### Sanctions Cambodia sits at the centre of an escalating but structurally divergent sanctions campaign targeting the Prince Group and the associated Jin Bei Group network. The US Treasury's Office of Foreign Assets Control, acting on 23 June 2026, expanded its October 2025 transnational-criminal-organisation designation of the Prince Group by adding nine individuals and twenty-six entities, and for the first time named Hu Xiaowei as the networks second-in-command. A parallel FinCEN Section 311 action was reported alongside the OFAC move, indicating coordinated action within the US government even where the two agencies rely on different statutory tools. On the European side, the EU Council designated Prince Holding Group and its chairman Chen Zhi under the EU Global Human Rights Sanctions Regime on 31 July 2026, with the designation record citing at least ten scam compounds built and operated throughout Cambodia. A further listing, reported in early August, added the Jin Bei Group, an associated individual named Zhu Zhongbiao, and the Democratic Karen Benevolent Army, an armed group operating in Cambodia's border region. Continue reading The analytically significant feature of this picture is not any single designation but the fact that the US and EU actions proceed on wholly separate legal bases, under separate statutory regimes, and on non-aligned timetables, targeting an overlapping but not identical set of entities and individuals. The US basis is rooted in transnational organised crime and fraud; the EU basis is rooted in human rights violations connected to trafficking and forced criminality within the scam compounds themselves. This is a sanctions-regime-divergence pattern worth tracking in its own right: institutions building sanctions-screening logic against Cambodia-linked counterparties cannot rely on a single consolidated list, and the absence of a unified multilateral instrument means screening gaps are likely to persist even as both tracks continue to add names. Domestically, Cambodia's own licence-enforcement apparatus has continued to move against the casino sector that underpins much of this activity. The Commercial Gambling Management Commission revoked Casino Licence No. 248 held by Casino YING HUANG in Preah Sihanouk province, citing links to online-scam activity and the illegal possession of weapons and narcotics. This is a confirmed domestic enforcement action, operating under separate domestic legal authority from either the US or EU sanctions tracks, but addressing the same underlying scam-compound economy that both foreign sanctions programmes target. Read together, the domestic licence-revocation campaign and the dual foreign sanctions tracks describe a jurisdiction under sustained, multi-pronged external and internal pressure on the same commercial architecture, without yet showing convergence into a single enforcement framework. #### Outlook Further additions to both the OFAC and EU Council designation lists against the Prince Group/Jin Bei Group network should be expected, consistent with the pattern of incremental expansion already observed across 2025 and 2026 on each respective track. There is no indication that the US and EU intend to formally align their designation lists or legal bases, so institutions should expect the divergence itself to persist rather than resolve. Cambodia's domestic casino-licence revocation campaign is likely to continue as the visible enforcement response to the same scam-compound economy, and further revocations beyond Casino YING HUANG are a reasonable expectation given the pattern already established, though confirmation of any additional action will depend on future reporting from the Commercial Gambling Management Commission. Judgment: US and EU sanctions architecture against the Cambodia-based Prince Group / Jin Bei Group network continues to expand on separate legal bases and timetables (OFAC TCO/fraud basis; EU Global Human Rights Sanctions Regime), indicating sustained multilateral pressure on Cambodia's scam-compound economy. Probable #### Beneficial Ownership and Corporate Transparency Cambodia sits outside the European Union AML architecture altogether: it is not an EU or EEA member state, so the directly applicable AML Regulation, the transposed sixth AML Directive, and the AMLA Regulation supervisory perimeter do not apply to Cambodian entities. The directly relevant beneficial-ownership development for Cambodia this cycle is domestic: the use by Prince Group of a network of more than 100 shell companies to layer laundering flows, exploiting the absence in Cambodia of a comprehensive public beneficial-ownership registry. The 2020 AML/CFT Law and the 2021 Customer Due Diligence Directive in Cambodia impose beneficial-ownership identification duties on financial institutions and designated non-financial businesses and professions, but no comprehensive public registry exists, and successive Asia/Pacific Group follow-up reports have flagged persistent legal-entity-transparency deficiencies as a standing weakness in the Cambodian AML/CFT framework. This registry gap, not the Prince Group case in isolation, is the structural finding: it is the enabling condition that permits large-scale shell-company layering regardless of which specific criminal network exploits it. Continue reading Compounding the registry gap is the economic-citizenship, or payment-for-passports, scheme operated in Cambodia, which allowed Chinese-born scam-network figures to acquire Cambodian nationality and, with it, an additional layer of obscured beneficial-ownership trails. Following 2023 scrutiny of the scheme, the government stopped publishing new-citizen names in the royal gazette, a decision that deepened rather than resolved the underlying transparency deficit. Read alongside the shell-company finding, this evidences a state-administered mechanism intersecting with beneficial-ownership opacity, suggestive of state institutions facilitating rather than merely failing to prevent concealment. Globally, the EU AML Package sets the structural direction for beneficial-ownership and corporate-transparency reform, and it is worth stating as durable backdrop against which the registry gap in Cambodia is read. The Package comprises three distinct instruments: the AML Regulation, Regulation (EU) 2024/1624, which is directly applicable across Member States without national transposition; the sixth AML Directive, which each Member State transposes into domestic law; and the AMLA Regulation, Regulation (EU) 2024/1620, which establishes the Anti-Money Laundering Authority and a hybrid EU-level supervisory perimeter under which AMLA will directly supervise a defined set of high-risk cross-border obliged entities while indirectly supervising the remainder through national authorities, shifting AML/CFT supervision away from a purely national model. The only structural link between Cambodia and this architecture remains the European Commission high-risk third-country delegated-regulation mechanism, Regulation 2016/1675 as amended by 2026/46 and 2026/83, in force from December 2025, on which Cambodia does not currently appear, notwithstanding the scale of Prince Group and Huione enforcement action documented since October 2025. A further development bears on the compliance consequence of any future change in the international standing of Cambodia: the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 in the UK, in force from 30 June 2026, narrowed the statutory definition of high-risk third country under Regulation 33 of the Money Laundering Regulations 2017 to the FATF Call for Action (blacklist) list only, removing the broader Increased Monitoring (grey list) tier from the automatic enhanced-due-diligence trigger. This is structurally significant for Cambodia specifically: should Cambodia return to the FATF grey list at a future plenary, this narrowed UK definition would no longer automatically trigger EDD obligations that would previously have applied, reducing the practical compliance consequence of any renewed grey-listing decision for UK-regulated firms. The active-scheme inventory characterises the combined citizenship-for-sale and shell-layering configuration as a discrete scheme of preliminary high severity, spanning this domain and the enabler-jurisdiction domain, with a documented red-flag indicator, layered use of over 100 shell companies to obscure beneficial ownership of laundering proceeds, most observable at onboarding for fund-structure and corporate customer typologies. The standing beneficial-ownership-register tracker for Cambodia is assessed as worsening, reflecting the compounding effect of the registry gap itself and the loss of citizenship-grant transparency, rather than any single new event this cycle. Firm-type exposure under this domain spans banks and cross-sector obliged entities, with customer-typology exposure concentrated in high-net-worth individuals, corporate structures and fund structures, precisely the typologies through which shell-company layering and citizenship-acquisition opacity operate. #### Outlook The most consequential near-term horizon event for this domain is not a Cambodia-specific instrument but the already-in-force narrowed UK high-risk-third-country definition, which will condition how any future FATF re-listing decision translates into UK EDD obligations. The next periodic high-risk third-country list update by the European Commission remains a second, slower-moving horizon event, structurally decoupled from Cambodia-specific enforcement given the continued reliance of the EU on the FATF-tracking delegated-regulation mechanism rather than an autonomous listing tool. Judgment: No KH-specific beneficial-ownership register development located this cycle. Uncertain #### Enabler Jurisdictions Cambodia's standing as an enabler jurisdiction continues to rest on an unresolved gap between domestic enforcement activity and the formal compliance assessment conducted by the Financial Action Task Force. Cambodia exited the FATF grey list in February 2023, after two prior grey-list periods running from 2011 to 2015 and from 2019 to 2023, and the jurisdiction remains a member of the Asia/Pacific Group on Money Laundering, the FATF-style regional body responsible for mutual evaluation in the region. That listing history is well established and not in dispute. What remains open is the substance of the follow-up assessment conducted after Cambodia's 2023 exit: a FATF follow-up report from August 2023 continued to find weaknesses specifically in the fit-and-proper testing applied to casinos, lawyers and accountants, the professional gatekeeper categories most directly implicated in the facilitation of the scam-compound economy documented under the sanctions track covered elsewhere in this brief. Continue reading Trade press reporting characterises Cambodia as actively intensifying enforcement in order to avoid a third grey-list placement ahead of a further evaluation cycle in 2026, framing the domestic licence-revocation campaign, including the Commercial Gambling Management Commission's revocation of Casino YING HUANG's licence, as part of a deliberate effort to close the fit-and-proper gaps that FATF previously identified. This is a reasonable inference but it is not yet a FATF finding: FATF itself has not published a new assessment this cycle confirming that the identified weaknesses have been remediated. The distinction matters because enforcement intensity and formal compliance recognition are not the same thing, and a jurisdiction can visibly step up domestic action without that action yet registering in the next mutual-evaluation or follow-up cycle. The architecturally significant point for an enabler-jurisdiction assessment is therefore that Cambodia's gatekeeper-sector weaknesses, specifically around casino, legal, and accountancy fit-and-proper testing, remain the identified structural vulnerability, and the domestic response to date has not yet been externally validated as sufficient to close it. This gatekeeper-sector weakness is also the structural link between Cambodia's enabler-jurisdiction profile and the sanctions architecture covered elsewhere: the scam compounds targeted by US and EU sanctions action operate through corporate and casino structures that depend precisely on the kind of fit-and-proper gaps FATF has flagged. An enabler jurisdiction is, in this framing, not simply one that under-enforces, but one whose structural gatekeeper weaknesses create the permissive conditions that a separately-sanctioned criminal network can exploit. #### Outlook The next material development to watch is any formal FATF or APG reassessment of Cambodia's casino, legal, and accountancy fit-and-proper regime, which would either validate or contradict the trade-press narrative of successful remediation ahead of the 2026 evaluation cycle. Until such an assessment is published, the domestic licence-revocation campaign should be read as enforcement activity rather than confirmed structural remediation. A third grey-list placement remains a live possibility if the identified weaknesses are found to persist at the next evaluation point, and this is the single most consequential open question in Cambodia's enabler-jurisdiction profile going into the remainder of 2026. Judgment: FATF's August 2023 follow-up report continues to find weaknesses in fit-and-proper testing of casinos, lawyers and accountants; Cambodia is reported intensifying enforcement ahead of a further 2026 evaluation cycle to avoid a third grey-list placement. Probable #### Conflict Finance and Extractive-Industry Integrity Applying the F4 conflict-finance trace, source, channel, deployment, to this cycle findings for Cambodia identifies a durable elite patronage network rather than a single transaction or scheme. The source is state-issued natural-resource concessions: forestry, land and riverine or coastal sand-dredging rights granted to politically connected individuals. The channel is a small group of Cambodian senators and oknha tycoons, including Mong Reththy, Ly Yong Phat, Lao Meng Khin, Try Pheap, and Kun Kim, who use political protection across forestry, military, police and customs agencies to run illegal logging operations, sand-dredging exports, notably to the Singapore market, and land-concession grabs. The deployment is personal enrichment that in turn bankrolls the ruling patronage system, converting state natural-resource assets into a durable funding mechanism for political power rather than a one-off enrichment event. Continue reading This is not a new phenomenon this cycle so much as a persistent architecture that prior enforcement action has only partially addressed. Try Pheap and Kun Kim were previously designated under the US Global Magnitsky programme, evidencing that the United States has identified individual network figures as sanctionable, but the broader patronage network, spanning multiple senators and oknha tycoons across multiple extractive sectors, remains active and largely undisturbed by that partial action. This is consistent with an F1 state-capture read: state agencies, forestry, military, police, customs, function as instruments of the extractive activity of the network rather than as independent regulators of it, an architecture finding that a designation targeting one or two individuals cannot by itself resolve. The customer-typology and firm-type exposure for this domain centres on politically exposed persons, high-net-worth individuals and corporate structures, reflecting the fact that the mechanism operates through formally licit corporate and export vehicles, land concessions, logging permits, sand-export licences, rather than through overtly illicit financial instruments. This is precisely the pattern that makes extractive-industry corruption difficult to distinguish from licit commercial activity using transaction-monitoring alone; the relevant red-flag indicator is state-issued land or forestry concessions converted into export revenue flowing to politically connected corporate vehicles, an indicator most observable in trade documentation rather than in financial-transaction data. This domain intersects directly with the enabler-jurisdiction finding elsewhere in this brief and with the state-capture flag raised for WDM: the same political-business elite structure that permits scam-compound operators like Kok An to control a domestic bank also permits senators and oknha tycoons to convert state natural-resource concessions into personal and party wealth, suggesting a single underlying institutional condition, the fusion of state office and private enrichment, expressed across financial-crime, extractive-industry and banking-control channels rather than three unrelated phenomena. No obligation-reference framework applies directly to the extractive-industry conduct itself in the current research window, since export-licensing and land-concession decisions occur at the level of Cambodian domestic administrative law rather than international AML/CFT instrument; the two prior Global Magnitsky designations remain the only sanctions-based obligation reference tied to this network. #### Outlook No regulatory-horizon event targeting this network was identified this cycle, and the trajectory of this domain is assessed as stable rather than deteriorating or improving, reflecting a persistent rather than actively worsening or actively resolving architecture. The partial nature of prior US Global Magnitsky action against only two of the network figures suggests that further designation activity, should it occur, would need to address the structural breadth of the network, multiple senators and oknha tycoons operating across multiple extractive sectors, rather than further individual designations, to have a materially different effect on the underlying patronage architecture. Judgment: No conflict-finance development located for KH this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Cambodia's digital-asset regulatory architecture currently rests on a single operative instrument: the National Bank of Cambodia's Prakas B7-024-735, which functions as the sole crypto-AML gateway for activity channelled through banks and payment service providers. Under this Prakas, firms authorised to conduct Group 1 crypto-asset activity through the bank/PSP channel become reporting entities to Cambodia's financial intelligence unit, placing them inside the standard AML reporting perimeter that applies to regulated financial institutions more broadly. This is a narrow but functioning gateway: it covers bank- and PSP-channel activity specifically, and does not purport to be a comprehensive digital-asset regulatory framework covering the full range of crypto-asset activity that may occur outside that channel. Continue reading That gap is the context for the most significant development this cycle: trade press reporting indicates that a comprehensive Digital Asset Law is being drafted, with a final draft targeted for November 2026 and legislative approval anticipated by the end of 2026, as scheduled. If enacted on that timetable, this would represent a material extension of Cambodia's crypto-asset regulatory perimeter beyond the current Prakas gateway, bringing a wider range of digital-asset activity, potentially including activity outside the bank/PSP channel, within a dedicated statutory framework for the first time. This is a structural development rather than an incremental one: a single sector-specific Prakas applicable only to the regulated banking and payments channel is a materially different regulatory posture from a comprehensive cross-sectoral digital-asset statute, and the shift from one to the other would be a defining feature of Cambodia's financial-innovation regulatory landscape going into 2027. It is important to be precise about the confidence level attached to this development: the existence and substance of the Prakas is corroborated by commentary citing the instrument, and the Digital Asset Law timeline rests on trade-press reporting of a targeted drafting and approval schedule, rather than on a published bill text or an NBC or government confirmation reviewed directly this cycle. The direction of travel, from a narrow bank/PSP crypto-AML gateway toward a comprehensive digital-asset statute, is consistent with regional trends and with Cambodia's own stated interest in developing its digital-asset sector, but the November 2026 and year-end 2026 dates should be treated as reported targets rather than confirmed statutory milestones until the draft itself is published or passed. #### Outlook The clearest marker to watch is whether the targeted November 2026 final draft of the Digital Asset Law materialises, and whether the drafting timetable holds through to the anticipated year-end 2026 legislative approval, as scheduled. Should the law pass broadly on this timetable, the next material question becomes how it interacts with the existing Prakas B7-024-735 gateway, whether it supersedes, supplements, or formally incorporates the bank/PSP-channel reporting-entity regime that currently governs Group 1 crypto-asset activity. Firms and counterparties with Cambodia-linked digital-asset exposure should treat the current Prakas-based gateway as the operative regime until any new statute is confirmed, while anticipating that the regulatory perimeter is likely to widen materially before the end of 2026 if the reported drafting timetable holds. Judgment: NBC's Group1/Group2 Prakas remains the sole operative crypto-AML gateway; a comprehensive Digital Asset Law is reported targeted for a final draft in November 2026 with legislative approval expected by year-end. Probable #### Compliance Technology and Active Defence No RegTech, AI or ML compliance-technology, or perpetual-KYC development specific to Cambodia was identified in this cycle research window. This is a null finding for the domain rather than an oversight: the crypto-enabled fraud exposure documented at scale under the crypto and digital-asset domain continues to be met with an absence of a dedicated virtual-asset-service-provider licensing and supervision regime in Cambodia, a standing structural gap rather than a new development. Under the enablement-as-signal principle, this absence is itself analytically relevant: a jurisdiction hosting infrastructure that processed over 98 billion dollars in crypto inflows, including at least 4 billion dollars in illicit proceeds, without a commensurate domestic compliance-technology or supervisory-technology build-out represents a persistent rather than resolving condition. No enforcement action, regulatory instrument, or industry compliance-technology initiative targeting the supervisory capacity of Cambodia in this domain was identified this cycle. This gap register limitation is noted honestly rather than filled with invented content: absent a published Cambodia National Risk Assessment or a CAFIU-issued virtual-asset sector risk assessment, any characterisation of domestic RegTech or supervisory-technology capacity beyond the licensing-regime absence itself would exceed what the evidence this cycle supports. Continue reading #### Outlook No Cambodia-specific regulatory-horizon event applicable to compliance technology or active defence was identified this cycle. The trajectory of this domain is assessed as stable, reflecting the persistence of the underlying supervisory gap rather than any new deterioration or improvement; this stability should be read against, not independently of, the deteriorating trajectory documented in the crypto and digital-asset domain, since the absence of compliance-technology development is a structural condition that permits the crypto-integrity risk documented elsewhere in this brief to continue unaddressed at the domestic supervisory level. Should any RegTech, transaction-monitoring-technology, or VASP-supervisory-technology development emerge for Cambodia in a future cycle, it would represent a genuinely new datapoint against this currently empty baseline, rather than an incremental extension of an existing standing development. Judgment: No RegTech/AI compliance-technology development located for KH this cycle. Uncertain IMF reports fraud-related disclosures account for ~20-25% of CAFIU's total disseminations but few lead to investigations; recommends tighter CAFIU-police cooperation and integration of AML/anti-scam strategy. Judgment: Cambodia is an APG member and exited the FATF grey list in February 2023 after two prior listings (2011-2015, 2019-2023); the standing AML/CTF regime record is unchanged this cycle. Probable Judgment: No commercial transaction among integrity-infrastructure firms or de-risking event located for KH this cycle. Uncertain Regulatory horizon Consultation 2026-Q4 · ±half_year ### NBC CASP-licensing and bank crypto-exposure implementing regulations Formal licence conditions and procedures for Crypto Asset Service Providers, and explicit bank cryptoasset-exposure limits, are expected to be published. [National Bank of Cambodia Source](https://www.dfdl.com/insights/legal-and-tax-updates/cryptoassets-regulation-introduced-by-the-national-bank-of-cambodia-nbc/) Consultation 2026-Q4 · ±quarter ### Cambodia Digital Asset Law (comprehensive) A full digital-asset law would extend KH's crypto perimeter beyond the bank/PSP Prakas gateway toward a licensed CASP-style regime split between NBC and SERC, per trade-press reporting. [National Bank of Cambodia / Securities and Exchange Regulator of Cambodia (joint drafting, per reporting) Source](https://www.disruptionbanking.com/2026/10/16/cambodia-crypto-regulation-enters-a-decisive-quarter-ahead-of-black-swan-summit-cambodia/) Proposed 2029-Q3 · ±multi_year ### FATF/APG 5th-round Mutual Evaluation of Cambodia A new onsite evaluation is scheduled for around November 2028 with possible plenary discussion in July 2029 [APG (FATF-style regional body) Source](https://www.fatf-gafi.org/en/countries/global-network/asia-pacific-group-on-money-laundering--apg-.html) 3 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Parallel US and EU sanctions tracks against the Prince Group/Jin Bei Group network continue to expand on non-aligned legal bases. Screening systems calibrated against either list alone risk missing names captured only on the other track; the absence of a single consolidated list is itself the operational fact to plan around, alongside the confirmed domestic casino-licence revocation campaign targeting the same network. 3 evidence refs Compliance ### Cambodia's fit-and-proper weaknesses in casinos, lawyers and accountants remain FATF-flagged pending a further evaluation cycle. Enhanced due diligence postures toward Cambodia-linked gatekeeper-sector counterparties should reflect that domestic enforcement activity has not yet been matched by a published FATF reassessment confirming remediation. 1 evidence refs Legal ### Divergent US and EU legal bases for sanctioning the same Cambodia-based network create distinct liability-exposure questions on each side. Counsel assessing exposure to Prince Group/Jin Bei Group-linked counterparties needs to separately assess OFAC transnational-crime-based liability and EU human-rights-sanctions-based liability, since the two regimes do not share a single designation list or legal theory. 2 evidence refs Board ### Sustained multilateral pressure on Cambodia's scam-compound economy is intensifying across separate US and EU enforcement tracks. This is a structural, multi-year enforcement trend rather than an isolated incident, with material reputational implications for any institution carrying Cambodia-linked counterparty exposure in this sector. 2 evidence refs CTO ### A comprehensive Digital Asset Law targeted for a November 2026 final draft could materially widen Cambodia's crypto regulatory perimeter beyond the current bank/PSP gateway. Technical architecture built around the existing Prakas B7-024-735 reporting-entity model may need to accommodate a broader statutory perimeter if the reported drafting and approval timetable holds through year-end 2026, as scheduled. 1 evidence refs Risk ### Sanctions-regime divergence between the US and EU on the same Cambodia-based network is an emerging pattern worth tracking as a standalone risk category. Exposure-concentration assessments should treat non-aligned unilateral sanctions tracks as a distinct risk vector from coordinated multilateral action, since name-matching and timing will differ structurally between the two. 2 evidence refs Operations ### Casino Licence No. 248 held by Casino YING HUANG was revoked following findings of links to online-scam activity. Transaction-monitoring and counterparty-screening workflows with exposure to Cambodian casino-sector entities should reflect the revocation in counterparty-status checks going forward. 1 evidence refs Audit ### The evidentiary basis for the EU Council designation of Prince Holding Group rests on secondary reporting rather than a primary EU Official Journal instrument retrieved this cycle. Control-testing scope for sanctions-screening coverage of EU designations should note that the underlying Official Journal instrument was not independently retrieved this cycle, which is a documentation gap worth tracking for future verification. 1 evidence refs Scenario sketches ### Hybrid EU-level supervision reshaping cross-border obliged-entity exposure Illustrative scenario for analytical orientation only: as the EU AML Package moves from purely national supervision toward AMLA direct and indirect supervision of cross-border obliged entities under the AMLA Regulation, alongside the directly applicable AML Regulation and per-state transposition of the sixth AML Directive, obliged entities with cross-border exposure to higher-risk corridors could face a supervisory environment where evasion techniques calibrated to exploit gaps between national regulators become less effective as supervisory authority consolidates at the EU level. This is architecture-over-incident framing describing a possible structural mechanism, not an observed fact or a prediction of how any specific entity will be treated. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture stable T2 · EU AML Package / AMLA no_change KH is a non-EEA autonomous jurisdiction; AMLR/6AMLD/AMLA do not apply. T3 · FATF Grey List watch Cambodia remains off the FATF grey list (exited Feb 2023) but is stepping up enforcement ahead of a further 2026 evaluation to avoid a third listing. T4 · Beneficial-Ownership Register Status stable T5 · Crypto & Digital-Asset Integrity watch NBC Group1/Group2 Prakas remains operative gateway; comprehensive Digital Asset Law targeted for November 2026 draft. T6 · Sanctions Regime Divergence escalating US (E.O. 13581) and EU (Global Human Rights Sanctions Regime) sanctioned overlapping Cambodia-based Prince Group/Jin Bei Group targets on different legal bases and dates. Registers ### Enforcement actions - 14 Oct 2025 - 14 Oct 2025 - 14 Oct 2025 - 23 Apr 2026 - 8 Jan 2026 - 1 Jun 2026 - 23 Jun 2026 - 23 Jun 2026 - 25 Sep 2026 - 3 Aug 2026 - 28 May 2026 - 3 Apr 2026 - 28 May 2026 - 3 Apr 2026 - Coordinated designation of the Prince Group TCO and Chen Zhi under Global Magnitsky/TCO authority, alongside a DOJ wire-fraud/money-laundering indictment of Chen Zhi and the largest-ever US civil forfeiture (127,271 BTC, ~$15bn), plus a FinCEN Section 311 final rule against Huione Group. 14 Oct 2025 - UK coordinated sanctions under the Global Human Rights Sanctions Regulations 2020 against the Prince Group network operating Cambodia-based scam centres, freezing a £12m North London mansion and other UK assets. 14 Oct 2025 - Final rule under Section 311 of the USA PATRIOT Act imposing a special measure severing Cambodia-based Huione Group's access to the US financial system, following a May 2025 NPRM finding it a primary money-laundering concern. 14 Oct 2025 - OFAC designated Cambodian senator Kok An's business empire and network under E.O. 13694/14390 for operating scam compounds tied to at least $73 million laundered from US victims, including direct control of a Cambodian bank. 23 Apr 2026 - Cambodia's interior ministry arrested Chen Zhi in early January 2026 following his sanctioning and US indictment, and extradited him to China rather than to the United States, which held the outstanding criminal indictment. 8 Jan 2026 - UK widened its Prince Group sanctions package, adding further individuals identified operating under multiple aliases and freezing additional London properties including a £9m penthouse, building on the October 2025 designations. 1 Jun 2026 ### Sanctions changes - 14 Oct 2025 - 14 Oct 2025 - 23 Apr 2026 - 1 Jun 2026 - 4 Dec 2025 - 23 Jun 2026 - 23 Jun 2026 - 23 Jun 2026 - 14 Oct 2025 - 23 Jun 2026 - 31 Jul 2026 - 14 Oct 2025 - 23 Jun 2026 - 31 Jul 2026 - OFAC designated the Prince Group Transnational Criminal Organization and 146 associated Cambodia-linked targets under Global Magnitsky/TCO sanctions authority, later expanded with 25 additional bitcoin addresses. 14 Oct 2025 - UK Global Human Rights sanctions regime listed Prince Group, Jin Bei Group, Golden Fortune Resorts, Byex Exchange and named individuals (Chen Zhi et al.), coordinated with the US action of the same date. 14 Oct 2025 - OFAC designated Cambodian senator Kok An and 28 individuals/entities including Heng Feng Cambodia Bank for operating scam-compound and money-laundering infrastructure. 23 Apr 2026 - UK widened its Prince Group-related sanctions list to add Hu Xiaowei and other alias-holding individuals, plus associated UK companies and properties. 1 Jun 2026 - As of the December 2025 EU high-risk third country delegated regulation update (EU 2026/46, EU 2026/83), Cambodia remains absent from the EU AML high-risk list, and no EU autonomous sanctions regime designation of Cambodia-linked scam-network entities has been identified, in contrast to the coordinated US/UK action. 4 Dec 2025 ### Regulatory horizon (register) - NBC CASP-licensing and bank crypto-exposure implementing regulations - NBC CASP-licensing and bank crypto-exposure implementing regulations - FATF/APG 5th-round Mutual Evaluation of Cambodia - Draft Law on the Management of Virtual Assets and Digital Assets - Cambodia Digital Asset Law (comprehensive) - FinCEN final rule on H-Pay Service PLC / Huione successor entities - Next FATF Plenary review point for Cambodia AML/CFT standing - Next periodic EU high-risk third country list update ### Active schemes - [CRITICAL] Cambodia scam-compound pig-butchering crypto fraud complex - [CRITICAL] Huione Group crypto-fiat guarantee-marketplace laundering hub - [HIGH] DPRK cyber-heist to crypto laundering corridor via Cambodia - [HIGH] Elite patronage network monetising extractive-industry corruption - [HIGH] Citizenship-for-sale and shell-layering BO opacity exploitation Sources - [JOINT STATEMENT: NBC-UN Convening Multi-stakeholder Consultation Process on Microfinance in Cambodia | United Nations in Cambodia](https://cambodia.un.org/en/274693-joint-statement-nbc-un-convening-multi-stakeholder-consultation-process-microfinance) - [https://home.treasury.gov/news/press-releases/sb0538](https://home.treasury.gov/news/press-releases/sb0538) - [https://home.treasury.gov/news/press-releases/sb0278](https://home.treasury.gov/news/press-releases/sb0278) - [https://en.wikipedia.org/wiki/2026_in_Cambodia](https://en.wikipedia.org/wiki/2026_in_Cambodia) - [https://agbrief.com/news/27/01/2026/cambodia-aims-to-avoid-fatf-grey-listing/](https://agbrief.com/news/27/01/2026/cambodia-aims-to-avoid-fatf-grey-listing/) - [https://www.dfdl.com/insights/legal-and-tax-updates/cryptoassets-regulation-introduced-by-the-national-bank-of-cambodia-nbc/](https://www.dfdl.com/insights/legal-and-tax-updates/cryptoassets-regulation-introduced-by-the-national-bank-of-cambodia-nbc/) - [https://kh.usembassy.gov/press-release-regarding-prince-group-transnational-criminal-organization/](https://kh.usembassy.gov/press-release-regarding-prince-group-transnational-criminal-organization/) - [https://www.hsfkramer.com/notes/sanctions/2026-posts/ofac-expands-sanctions-on-prince-group-tied-to-global-scam-operations](https://www.hsfkramer.com/notes/sanctions/2026-posts/ofac-expands-sanctions-on-prince-group-tied-to-global-scam-operations) - [https://bankingjournal.aba.com/2026/06/fincen-takes-further-steps-to-sever-cambodian-firm-from-u-s-financial-system/](https://bankingjournal.aba.com/2026/06/fincen-takes-further-steps-to-sever-cambodian-firm-from-u-s-financial-system/) - [https://www.fatf-gafi.org/en/countries/detail/Cambodia.html](https://www.fatf-gafi.org/en/countries/detail/Cambodia.html) - [https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/) - [https://asgam.com/2026/08/19/cambodia-says-20-casino-licenses-revoked-amid-significant-progress-in-scam-center-crackdown/](https://asgam.com/2026/08/19/cambodia-says-20-casino-licenses-revoked-amid-significant-progress-in-scam-center-crackdown/) - [AKP](https://www.akp.gov.kh/post/detail/380563) - [SERC](https://www.serc.gov.kh/english/index.php/khmer/ep/ep/popbox/m77.php?pn=8&no=223) - [Phnom Penh Post](https://phnompenhpost.com/national/online-bets-are-off-at-least-24-casinos-halt-digital-gambling-by-deadline/) - [FATF](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Khmer Times](https://www.khmertimeskh.com/tag/nbc/) - [https://www.akp.gov.kh/post/detail/368511](https://www.akp.gov.kh/post/detail/368511) - [https://www.state.gov/wp-content/uploads/2026/09/701264_2026-Cambodia-Investment-Climate-Statement.pdf](https://www.state.gov/wp-content/uploads/2026/09/701264_2026-Cambodia-Investment-Climate-Statement.pdf) - [https://www.khmertimeskh.com/502032824/imf-urges-cambodia-to-tighten-fiscal-governance-to-combat-scam-related-money-laundering](https://www.khmertimeskh.com/502032824/imf-urges-cambodia-to-tighten-fiscal-governance-to-combat-scam-related-money-laundering) - [https://www.fatf-gafi.org/en/countries/global-network/asia-pacific-group-on-money-laundering--apg-.html](https://www.fatf-gafi.org/en/countries/global-network/asia-pacific-group-on-money-laundering--apg-.html) - [https://www.latintimes.com/300-million-frozen-86-compounds-closed-real-scorecard-cambodias-scam-crackdown-599446](https://www.latintimes.com/300-million-frozen-86-compounds-closed-real-scorecard-cambodias-scam-crackdown-599446) - [Wikipedia](https://en.wikipedia.org/wiki/2026_in_Cambodia) - [https://thediplomat.com/2026/06/us-government-imposes-fresh-sanctions-against-alleged-cambodian-scam-network/](https://thediplomat.com/2026/06/us-government-imposes-fresh-sanctions-against-alleged-cambodian-scam-network/) - [https://cambodianess.com/article/nbc-places-chief-bank-under-administration-suspends-depositor-withdrawals](https://cambodianess.com/article/nbc-places-chief-bank-under-administration-suspends-depositor-withdrawals) - [https://www.khmertimeskh.com/502023783/nbc-revokes-tian-xu-payment-service-licence](https://www.khmertimeskh.com/502023783/nbc-revokes-tian-xu-payment-service-licence) - [https://www.state.gov/reports/2025-investment-climate-statements/cambodia](https://www.state.gov/reports/2025-investment-climate-statements/cambodia) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofcambodia.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofcambodia.html) - [https://www.lexology.com/library/detail.aspx?g=cfdbf541-eb73-4f6a-b30f-1b6a10d40b9c](https://www.lexology.com/library/detail.aspx?g=cfdbf541-eb73-4f6a-b30f-1b6a10d40b9c) - [https://english.cambodiadaily.com/2026/10/15/cambodia-faces-fresh-scrutiny-over-scam-compounds-despite-crackdown/](https://english.cambodiadaily.com/2026/10/15/cambodia-faces-fresh-scrutiny-over-scam-compounds-despite-crackdown/) - [https://www.nbc.gov.kh/download_files/legislation/prakas_eng/36.pdf](https://www.nbc.gov.kh/download_files/legislation/prakas_eng/36.pdf) - [https://www.akp.gov.kh/post/detail/383280](https://www.akp.gov.kh/post/detail/383280) - [https://www.nbc.gov.kh/english/](https://www.nbc.gov.kh/english/) - [https://asgam.com/2026/10/23/cambodia-freezes-nearly-us1-billion-in-prince-group-assets-as-scam-crackdown-intensifies/](https://asgam.com/2026/10/23/cambodia-freezes-nearly-us1-billion-in-prince-group-assets-as-scam-crackdown-intensifies/) - [https://www.disruptionbanking.com/2026/10/16/cambodia-crypto-regulation-enters-a-decisive-quarter-ahead-of-black-swan-summit-cambodia/](https://www.disruptionbanking.com/2026/10/16/cambodia-crypto-regulation-enters-a-decisive-quarter-ahead-of-black-swan-summit-cambodia/) - [https://checklynx.com/en/resources/knowledge-base/fatf-grey-list](https://checklynx.com/en/resources/knowledge-base/fatf-grey-list) - [https://www.ezine.eversheds-sutherland.com/global-aml-guide/cambodia](https://www.ezine.eversheds-sutherland.com/global-aml-guide/cambodia) - [US Department of the Treasury (OFAC)](https://home.treasury.gov/news/press-releases/sb0538) - [US Department of the Treasury (OFAC)](https://home.treasury.gov/news/press-releases/sb0469) - [Business & Human Rights Resource Centre](https://www.business-humanrights.org/en/latest-news/cambodia-eu-sanctions-company-and-its-chairman-for-human-trafficking-and-scam-operations/) - [Steptoe LLP](https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-august-3-2026.html) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofcambodia.html) - [The Diplomat](https://thediplomat.com/2025/07/fatf-is-behind-the-curve-on-cambodias-cyber-scam-compounds/) - [AGBrief](https://agbrief.com/news/27/01/2026/cambodia-aims-to-avoid-fatf-grey-listing/) - [Disruption Banking](https://www.disruptionbanking.com/2026/10/16/cambodia-crypto-regulation-enters-a-decisive-quarter-ahead-of-black-swan-summit-cambodia/) - [Agence Kampuchea Presse (AKP)](https://www.akp.gov.kh/post/detail/371578) - [https://home.treasury.gov/news/press-releases/sb0469](https://home.treasury.gov/news/press-releases/sb0469) - [https://www.business-humanrights.org/en/latest-news/cambodia-eu-sanctions-company-and-its-chairman-for-human-trafficking-and-scam-operations/](https://www.business-humanrights.org/en/latest-news/cambodia-eu-sanctions-company-and-its-chairman-for-human-trafficking-and-scam-operations/) - [https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-august-3-2026.html](https://www.steptoe.com/en/news-publications/international-compliance-blog/weekly-sanctions-update-august-3-2026.html) - [https://thediplomat.com/2025/07/fatf-is-behind-the-curve-on-cambodias-cyber-scam-compounds/](https://thediplomat.com/2025/07/fatf-is-behind-the-curve-on-cambodias-cyber-scam-compounds/) - [https://www.akp.gov.kh/post/detail/371578](https://www.akp.gov.kh/post/detail/371578) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Cambodia](https://www.fatf-gafi.org/en/countries/detail/Cambodia.html) - [Mutual Evaluation of Cambodia](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofcambodia.html) - [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Jurisdictions under Increased Monitoring - 24 February 2023](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Increased-monitoring-february-2023.html) - [Documents - Financial Action Task Force (FATF)](https://www.fatf-gafi.org/countries/a-c/cambodia/documents/mutualevaluationofcambodia.html) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [OFAC Sanctions Cambodian Senator and Scam Center Network Targeting Americans With Digital Asset Fraud | TRM Labs](https://www.trmlabs.com/resources/blog/ofac-sanctions-cambodian-senator-and-scam-center-network-targeting-americans-with-digital-asset-fraud) - [U.S. Crackdown on Southeast Asian Crypto Scam Centers](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [OFAC Sanctions Tracker: How Sanctions Impact Crypto Crime - Chainalysis](https://www.chainalysis.com/blog/ofac-sanctions/) - [U.S. Launches New Strike Force to Combat $10 Billion Scam Industry](https://www.chainalysis.com/blog/ofac-targets-pig-butchering-scams-november-2025/) - [Crypto Sanctions: 2026 Crypto Crime Report](https://www.chainalysis.com/blog/crypto-sanctions-2026/) - [Blog - Chainalysis](https://www.chainalysis.com/blog/) - [Organized Crime and Corruption Reporting Project | OCCRP](https://www.occrp.org/en) - [Cambodia: Over 48,000 Scammers Deported amid Scam Center Crackdown | OCCRP](https://www.occrp.org/en/news/cambodia-over-48000-scammers-deported-amid-scam-center-crackdown) - [UK and US take joint action to disrupt major online fraud network - GOV.UK](https://www.gov.uk/government/news/uk-and-us-take-joint-action-to-disrupt-major-online-fraud-network) - [1 Cambodia Business Advisory on High-Risk Investments and Interactions](https://ofac.treasury.gov/media/914466/download?inline=) - [Questions swirl around US plans for record $15B Prince Group crypto seizure - ICIJ](https://www.icij.org/investigations/coin-laundry/questions-swirl-around-us-plans-for-record-15b-prince-group-crypto-seizure/) - [DOJ Seizes $15 Billion in Bitcoin](https://www.chainalysis.com/blog/southeast-asia-crypto-scam-network-mining-pig-butchering-october-2025/) - [Operation Prince: Inside the Global Effort That Led to the Largest Forfeiture in US History | TRM Labs](https://www.trmlabs.com/resources/blog/operation-prince-inside-the-global-effort-that-led-to-the-largest-forfeiture-in-us-history) - [$15 billion seized by US originates from Iran/China bitcoin miner "theft"](https://www.elliptic.co/blog/15-billion-us-seizure-reveals-prince-groups-connection-to-iran-china-bitcoin-mining-theft) - [Prince Group targeted with $15B crypto seizure and sanctions for pig butchering operations](https://www.elliptic.co/blog/prince-group-targeted-with-crypto-sanctions-for-global-pig-butchering-operations) - [US Seizes Bitcoin Worth $15 Billion in ‘Pig-Butchering’ Case - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-14/cambodian-corporate-chairman-charged-in-15-billion-crypto-fraud) - [How Cambodia Became A Haven For Criminals | OCCRP](https://www.occrp.org/en/feature/how-cambodia-became-a-haven-for-criminals) - [Politically Connected Crypto Project Pursued Resort With Alleged Scam Syndicate Figures | OCCRP](https://www.occrp.org/en/investigation/politically-connected-crypto-project-pursued-resort-with-alleged-scam-syndicate-figures) - [Cambodia Extradites Chair of Alleged ‘Criminal’ Conglomerate to China | OCCRP](https://www.occrp.org/en/news/chairman-of-alleged-criminal-conglomerate-arrested-in-cambodia-and-extradited-to-china) - [` 3rd Follow-Up Report Mutual Evaluation of Cambodia July 2021](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/APG-Follow-Up-Report-Cambodia-2021.pdf.coredownload.inline.pdf) - [Prakas on Anti- Money Laundering and Combating the ...](https://sherloc.unodc.org/cld/uploads/res/document/prakas-on-anti--money-laundering-and-combating-the-financing-of-terrorism-relating-to-all-reporting-entities-not-regulated-by-the-national-bank-of-cambodia_html/AML-CFR_Prakas_for_DNFBP_Eng.pdf) - [` 6th Follow-Up Report Mutual Evaluation of Cambodia August 2022 October 2023](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Cambodia-2023-FUR.pdf.coredownload.inline.pdf) - [Cambodia's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-cambodia-2022.html) - [` 5th Follow-Up Report Mutual Evaluation of Cambodia August 2022 August 2022](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/APG-Follow-Up-Report-Cambodia-2022.pdf.coredownload.inline.pdf) - [Fatf-gafi](https://www.fatf-gafi.org/media/fatf/documents/reports/fur/APG-Follow-Up-Report-Cambodia-2021.pdf) - [1 Cambodia Business Advisory on High-Risk Investments and Interactions](https://ofac.treasury.gov/media/914466/download) - [Follow-up report to Cambodia's assessment of anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-cambodia-2019.html) - [Cambodia's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-cambodia-2017.html) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council by identifying high-risk third countries with strategic deficiencies (Text with EEA relevance) (c. 1675)](https://www.legislation.gov.uk/eur/2016/1675/2020-07-09/data.xht?view=snippet&wrap=true) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [Anti-Money Laundering and Terrorist Financing Directive 4 - Finance](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en) - [Anti-money laundering: the Commission updates its list of high-risk third-country jurisdictions to strengthen the international fight against financial crime - Finance](https://finance.ec.europa.eu/news/anti-money-laundering-commission-updates-its-list-high-risk-third-country-jurisdictions-strengthen-2022-12-20_en) - [FinCEN Finds Cambodia-Based Huione Group to be of Primary Money Laundering Concern, Proposes a Rule to Combat Cyber Scams and Heists | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-finds-cambodia-based-huione-group-be-primary-money-laundering-concern) - [FinCEN Issues Final Rule Severing Huione Group from the U.S. Financial System | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-severing-huione-group-us-financial-system) - [US Treasury takes 311 action against Huione Group: What this means for you](https://www.elliptic.co/blog/us-treasury-takes-311-action-against-huione-group-what-this-means-for-you) - [Huione Group Shutdown and the Future of Crypto Scam Infrastructure](https://www.chainalysis.com/blog/huione-group-shutdown-future-of-crypto-scam-infrastructure/) - [Treasury Moves Against Huione Group in Landmark Action Targeting Global Cybercrime Infrastructure | TRM Blog](https://www.trmlabs.com/resources/blog/treasury-moves-against-huione-group-in-landmark-action-targeting-global-cybercrime-infrastructure) - [FinCEN Proposes to Sever H-Pay Service PLC and Other Huione Group Successor Entities from the U.S. Financial System | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-proposes-sever-h-pay-service-plc-and-other-huione-group-successor) - [Imposition of Special Measure regarding Huione Group as a Foreign Financial Institution of Primary Money Laundering Concern | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/federal-register-notices/imposition-special-measure-regarding-huione) - [Huione Carries On: Chinese-Language Platform’s Persistence Reveals the Complexity of On-chain Financial Crime Disruption - Chainalysis](https://www.chainalysis.com/blog/huione-guarantee-still-active-despite-shutdown/) - [Statement by FinCEN Director Andrea M. Gacki before the House Committee on Financial Services, Subcommittee on National Security, Illicit Finance, and International Financial Institutions | FinCEN.gov](https://www.fincen.gov/news/testimony/statement-fincen-director-andrea-m-gacki-house-committee-financial-services) - [1 (BILLINGCODE: 4810-02-P) DEPARTMENT OF THE TREASURY](https://www.fincen.gov/system/files/2026-06/HPay-NPRM.pdf) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2) - [HM Treasury publish updated list of high risk third jurisdictions](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasury-publish-updated-list-of-high-risk-third-jurisdictions) - [High-risk third countries](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries) - [RPC opinion: The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 - GOV.UK](https://www.gov.uk/government/publications/rpc-opinion-the-money-laundering-and-terrorist-financing-amendment-regulations-2026) - [The Money Laundering and Terrorist Financing (High-Risk ...](https://www.legislation.gov.uk/uksi/2024/69/made) - [Updated casino guidance to include proliferation financing](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/updated-casino-guidance-to-include-proliferation-financing?es_id=36c0030f75) - [The Money Laundering and Terrorist Financing (Amendment) Regulations 2026](https://www.legislation.gov.uk/ukdsi/2026/9780348281743) - [Q&A with Governor, National Bank of Cambodia, H.E. Dr. Serey Chea | Insights | Bloomberg Professional Services](https://www.bloomberg.com/professional/insights/markets/qa-with-dr-serey-chea/) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Current State of Central Bank Digital Currencies (CBDCs)](https://www.chainalysis.com/blog/central-bank-digital-currencies-cbdc/) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [FATF urges stronger global action to address Illicit Finance Risks in Virtual Assets](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2025.html) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Crypto Adoption Accelerates in APAC Region](https://www.chainalysis.com/blog/asia-pacific-crypto-adoption-2025/) - [FSB thematic review 2025: Global crypto regulation remains fragmented despite market growth](https://www.elliptic.co/blog/fsb-thematic-review-2025) - [Virtual Assets](https://www.fatf-gafi.org/en/topics/virtual-assets.html) - [1 Financial Sanctions Notice 14/10/2025 Global Human Rights Introduction](https://assets.publishing.service.gov.uk/media/68edf4d5e7b6794c076bbdc1/Notice_Global_Human_Rights_141025.pdf) - [The UK Sanctions List - GOV.UK](https://www.gov.uk/government/publications/the-uk-sanctions-list) - [CONSOLIDATED LIST OF FINANCIAL SANCTIONS TARGETS IN THE UK](https://assets.publishing.service.gov.uk/media/68edf492a8398380cb4acffe/Global_Human_Rights.pdf) - [UK Widens Sanctions on Suspected Prince Group Scam Operators | OCCRP](https://www.occrp.org/en/news/uk-widens-sanctions-prince-group) - [Transnational Criminal Organizations Designations; Cuba Designations; Russia-related Designations Removals; Issuance of TCO-related General License; Publication of OFAC-OFSI Comparative Overview | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260623) - [Historic U.S.–U.K. Operation Targets Southeast Asia’s Scam Compounds with Record $15 Billion Bitcoin Seizure | TRM Labs](https://www.trmlabs.com/resources/blog/historic-u-s--u-k-operation-targets-southeast-asias-scam-compounds-with-record-15-billion-bitcoin-seizure) - [CHEN Zhi - FCDO - UK Sanctions List Search - GOV.UK](https://search-uk-sanctions-list.service.gov.uk/designations/GHR0179/Individual) - [Designation - FCDO - UK Sanctions List Search - GOV.UK](https://search-uk-sanctions-list.service.gov.uk/designations/GHR0175/Individual) - [Who profits from the death of Cambodia’s democracy? | Global Witness](https://www.globalwitness.org/en/campaigns/cambodia/who-profits-death-cambodias-democracy/) - [Global Witness in Cambodia | Global Witness](https://www.globalwitness.org/en/archive/global-witness-cambodia/) - [Global Witness statement on US Government sanctions on Try Pheap and Kun Kim | Global Witness](https://globalwitness.org/en/press-releases/global-witness-statement-on-us-government-sanctions-on-try-pheap-and-kun-kim/) - [Cambodian Democracy Act is a major step forward in the fight against corruption | Global Witness](https://www.globalwitness.org/en/press-releases/cambodian-democracy-act-major-step-forward-fight-against-corruption/) - [Global Witness’ new report, “Taking a Cut” blows lid off systemic corruption in Cambodia’s forest sector | Global Witness](https://www.globalwitness.org/en/archive/global-witness-new-report-taking-cut-blows-lid-systemic-corruption-cambodias-forest/) - [Sacking of Cambodia’s forest chief unconvincing as move against illegal logging | Global Witness](https://www.globalwitness.org/en/archive/sacking-cambodias-forest-chief-unconvincing-move-against-illegal-logging/) - [Shifting Sand: how Singapore’s demand for Cambodian sand threatens ecosystems and undermines good governance | Global Witness](https://www.globalwitness.org/en/archive/shifting-sand-how-singapores-demand-cambodian-sand-threatens-ecosystems-and-undermines-good/) - [Search | Global Witness](https://www.globalwitness.org/en-gb/campaigns/cambodia/) - [Global Witness welcomes Cambodia sand export ban | Global Witness](https://globalwitness.org/en/campaigns/forests/campaign-success-global-witness-welcomes-cambodia-sand-export-ban/) - [Campaign Success: Global Witness Welcomes Cambodia Sand Export Ban | Global Witness](https://www.globalwitness.org/en/archive/campaign-success-global-witness-welcomes-cambodia-sand-export-ban/) - [JOINT STATEMENT | Progress Update: NBC-UN Convening Multi-Stakeholder Consultation on Microfinance in Cambodia | United Nations in Cambodia](https://cambodia.un.org/en/288279-joint-statement-progress-update-nbc-un-convening-multi-stakeholder-consultation-microfinance) - [International Cooperation for Investigation of Corruption ...](https://www.unodc.org/roseap/uploads/archive/documents/topics/anti-corruption/ASEAN_International_Cooperation_Guidebook_-_final.pdf) - [Supporting Financial Investigations into Corruption in Cambodia](https://www.unodc.org/southeastasiaandpacific/en/what-we-do/anti-corruption/topics/2020/corruption-cambodia.html) - [JOINT STATEMENT: NBC-UN Convening Multi-stakeholder Consultation Process on Microfinance in Cambodia | United Nations in Cambodia](https://cambodia.un.org/en/274693-joint-statement-nbc-un-convening-multi-stakeholder-consultation-process-microfinance) - [FATF / Asia-Pacific Group on Money Laundering (APG)](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Cambodia-2023-FUR.pdf.coredownload.inline.pdf) - [National Bank of Cambodia](https://www.nbc.gov.kh) - [US Department of the Treasury / OFAC](https://ofac.treasury.gov/media/914466/download?inline=) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-issues-final-rule-severing-huione-group-us-financial-system) - [UK Foreign, Commonwealth & Development Office (OFSI)](https://assets.publishing.service.gov.uk/media/68edf4d5e7b6794c076bbdc1/Notice_Global_Human_Rights_141025.pdf) - [European Commission](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [OCCRP](https://www.occrp.org/en/feature/how-cambodia-became-a-haven-for-criminals) - [Global Witness](https://www.globalwitness.org/en/campaigns/cambodia/who-profits-death-cambodias-democracy/) - [TRM Labs](https://www.trmlabs.com/resources/blog/ofac-sanctions-cambodian-senator-and-scam-center-network-targeting-americans-with-digital-asset-fraud) - [ICIJ](https://www.icij.org/investigations/coin-laundry/questions-swirl-around-us-plans-for-record-15b-prince-group-crypto-seizure/) - [UK Government (HM Treasury / legislation.gov.uk)](https://www.legislation.gov.uk/ukdsi/2026/9780348281743) Coverage gaps fim-int-2026-07-07-G001: No current, publicly available Camb… fim-int-2026-07-07-G001: No current, publicly available Cambodia National Risk Assessment or CAFIU-published virtual-asset sector risk assessment was identified; sector risk characterisations rely on FinCEN/OFAC third-country framing rather than a Cambodian-authored NRA. [resolved] fim-int-2026-07-07-G002: Domestic Cambodian prosecution and … fim-int-2026-07-07-G002: Domestic Cambodian prosecution and conviction data for senior scam-network financiers is largely absent, limiting independent verification of enforcement-asymmetry claims beyond deportation statistics. [resolved] fim-int-2026-07-07-G003: Continued post-designation activity… fim-int-2026-07-07-G003: Continued post-designation activity attributed to Huione successor entities (H-Pay) rests on single-vendor blockchain-analytics reporting; independent corroboration from a second analytics provider or a regulator statement would raise confidence above Possible. [resolved] fim-int-2026-07-07-G004: No EU-specific primary source confi… fim-int-2026-07-07-G004: No EU-specific primary source confirms whether AMLA or an EU Member State has separately assessed Cambodia-linked scam-network exposure outside the delegated-regulation high-risk-list mechanism. [resolved] fim-int-2026-07-07-G005: No documented instance of a confirm… fim-int-2026-07-07-G005: No documented instance of a confirmed Russia-sanctions-evasion nexus through Cambodia was found; absence-of-evidence for the T1 standing tracker would benefit from a dedicated dark-fleet/correspondent-banking screening pass specific to Cambodia. [resolved] fim-int-2026-08-21-G001: D4 conflict finance carries no Camb… fim-int-2026-08-21-G001: D4 conflict finance carries no Cambodia-specific material this cycle; genuine coverage gap rather than absence of activity. [resolved] fim-int-2026-08-21-G002: Prince Bank liquidation rests on a … fim-int-2026-08-21-G002: Prince Bank liquidation rests on a single Tier-4 source (Wikipedia aggregation); NBC primary confirmation not yet located. [resolved] fim-int-2026-08-21-G003: Tier-D watch checks for LA, MX, CO … fim-int-2026-08-21-G003: Tier-D watch checks for LA, MX, CO were not actively re-run this cycle; search budget concentrated on KH. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): Cambodia-specific beneficial-ownership registry status was not established this cycle. [resolved] fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): Cambodia-specific enabler network beyond the Prince Group corporate web (HK/SG/BVI shells) was not independently researched this cycle. [resolved] fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): The underlying FinCEN Federal Register notice for the proposed H-Pay Section 311 extension was not directly retrieved this cycle. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No primary CGMC/CCOS/CCTC gazette notice was independently opened this cycle; enforcement findings rest on press reporting of official statements rather than a published instrument. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): No new KH-linked OFAC/OFSI/EU sanctions designation was located within the 5 Sep - 4 Oct 2026 window, and no evidence was found to confirm or deny whether this reflects a genuine quiet period or a coverage gap. [resolved] fim-int-2026-10-04-G003: LA/MX/CO Tier-D jurisdictions were … fim-int-2026-10-04-G003: LA/MX/CO Tier-D jurisdictions were not independently researched this cycle to avoid carrying material from outside the bound KH jurisdiction. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D4'}): No conflict-finance-relevant development was located for Cambodia this cycle (D4). [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D6'}): No AI/ML transaction-monitoring compliance-technology development specific to Cambodia was located this cycle (D6). [resolved] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): Underlying IMF staff report/Article IV text on CAFIU-police follow-through was not directly retrieved; finding rests on secondary Khmer Times reporting. [resolved] fim-int-2026-10-19-G001: Cambodia's current status on the EU… fim-int-2026-10-19-G001: Cambodia's current status on the EU list of high-risk third countries (post 29 Jan 2026 list) could not be verified against a primary EU source this cycle. [resolved] fim-int-2026-10-19-G002: LA/MX/CO Tier D watch jurisdictions… fim-int-2026-10-19-G002: LA/MX/CO Tier D watch jurisdictions were not actively pursued this cycle; search budget was concentrated on KH as the bound jurisdiction. [resolved] fim-int-2026-10-25-G001: No Cambodia national risk assessmen… fim-int-2026-10-25-G001: No Cambodia national risk assessment (NRA) citation was located this cycle. [resolved] fim-int-2026-10-25-G002: FATF October 2026 plenary outcome f… fim-int-2026-10-25-G002: FATF October 2026 plenary outcome for Cambodia post-dates the last published FATF list consulted this cycle. [resolved] fim-int-2026-10-25-G003: No RegTech/AI-transaction-monitorin… fim-int-2026-10-25-G003: No RegTech/AI-transaction-monitoring guidance specific to Cambodia was located this cycle, a gap given FATF's continuing scrutiny of casino-sector AML effectiveness. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No domain-update located this cycle for D2 Beneficial Ownership. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D6'}): No domain-update located this cycle for D6 Compliance Technology & Active Defence. [open] fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): NBC Prakas B7-024-735 full text surfaced by URL but not opened for body-text quotation this cycle; corroborated only by T3 commentary. [open] fim-int-2026-11-01-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G004 ({'scheme': 'financial_integrity', 'value': 'D1'}): No EU Official Journal primary citation located for the EU Council Prince Holding/Jin Bei designations; relying on T2/T3 secondary reporting, confidence capped at Probable. [open] FIM-GAP-001 (D3): Despite the scale of the scam-compound eco… FIM-GAP-001 (D3): Despite the scale of the scam-compound economy documented by US/UK enforcement (billions in laundered proceeds), domestic Cambodian ML prosecutions and convictions of senior network figures remain minimal; the government's dismantling of scam centres has focused on deporting low-level foreign workers (48,000+ deported) rather than prosecuting owners/financiers. FIM-GAP-002 (D1): Cambodia extradited sanctioned/indicted Pr… FIM-GAP-002 (D1): Cambodia extradited sanctioned/indicted Prince Group chairman Chen Zhi to China rather than to the United States, which held the operative criminal indictment and forfeiture interest, reflecting state-level diplomatic prioritisation over international law-enforcement cooperation with the sanctioning jurisdictions. FIM-GAP-003 (D2): OFAC's own business advisory notes limited… FIM-GAP-003 (D2): OFAC's own business advisory notes limited regulation and oversight of Cambodia's financial, casino and real estate sectors, a largely cash-based dollarized economy, and absence of a comprehensive beneficial ownership framework, allowing illicit cash to move directly into land, luxury goods and property without passing through the banking sector. FIM-GAP-004 (D1): The UK's Money Laundering and Terrorist Fi… FIM-GAP-004 (D1): The UK's Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (in force 30 June 2026) narrowed the statutory definition of 'high-risk third country' to only the FATF 'Call for Action' (blacklist) list, removing the broader 'Jurisdictions Under Increased Monitoring' (grey list) from automatic mandatory EDD triggers under UK MLR Regulation 33. FIM-GAP-005 (D2): No current, publicly available Cambodia Na… FIM-GAP-005 (D2): No current, publicly available Cambodia National Risk Assessment (NRA) document or dedicated CAFIU-published virtual-asset sector risk assessment was identified in this research window; NRA reference fields for sector-specific virtual asset supervision rely primarily on FinCEN/OFAC third-country characterisations rather than a Cambodian-authored NRA. ## Evidence #### Confidence-tiered claims 18 casino licences revoked and 9 further licences suspended pending investigation for links to online scam activity, under Royal Government Order No. 01 BB (14 July 2025). [[Source 1]](#sec-sources) Probable · 1 source 24 casinos across Preah Sihanouk (12), Banteay Meanchey (7) and Svay Rieng (5) confirmed to have ceased online/live-streamed casino betting, football betting, digital lotteries and virtual-cockfighting products after a 30 September 2026 deadline. [[Source 1]](#sec-sources) Probable · 1 source NBC and SERC issued a joint statement (23 September 2026) establishing a dual-gateway supervisory intent for virtual-asset activity - NBC-licensed banks need NBC prior approval, non-bank entities need an SERC licence - explicitly citing money-laundering risk, ahead of a comprehensive Law on the Management of Virtual Assets and Digital Assets targeted for completion by end-2026. [[Source 1]](#sec-sources) Probable · 1 source NBC revoked the payment-institution licence of Tian Xu International Technology Plc (CoolCash Cambodia), the sixth such payment-institution licence revocation in nine months. [[Source 1]](#sec-sources) Uncertain · 1 source Off FATF grey list since February 2023; next possible onsite November 2028, plenary discussion July 2029 [[Source 1]](#sec-sources) Probable · 1 source Fraud-related disclosures account for ~20-25% of CAFIU's total disseminations; few spontaneous disclosures result in investigations [[Source 1]](#sec-sources) Probable · 1 source Designated 9 individuals and 26 entities linked to Prince Group TCO, unmasking Hu Xiaowei [[Source 1]](#sec-sources) Probable · 1 source NBC ordered liquidation and suspension of Prince Bank on 2026-01-08 following Chen Zhi/Chen Bo US indictments [[Source 1]](#sec-sources) Uncertain · 1 source CAFIU and NBC oversight of two sandboxed crypto exchanges under Prakas B7-024-735 continues unchanged Probable Al Jazeera broadcast (10 Oct 2026) alleges continuing online fraud, coercion, trafficking and officials allegedly protecting operations [[Source 1]](#sec-sources) Probable · 1 source NBC revoked payment service provider licence on 3 August 2026, UK had sanctioned the firm in March 2026 over alleged Prince Group links [[Source 1]](#sec-sources) Probable · 1 source 23 June 2026 tranche designated 9 individuals (incl. Hu Xiaowei as second-in-command) and 26 entities in UK/BVI/Hong Kong/Singapore/Thailand under EO 13581/13863 [[Source 1]](#sec-sources) Probable · 1 source FIU 2026 operational plan (5 Feb 2026) seeks direct financial-sanctions tooling, expands cooperation hotlines with China/Singapore/Mekong states, and stands up a joint government task force ahead of FATF's fifth-round mutual evaluation scheduled 2028 [[Source 1]](#sec-sources) Uncertain · 1 source Nationwide multi-agency casino inspection sweep across 16 provinces launched October 2026, citing the Law on Anti-Online Scams and AML/CFT Law as legal basis, framing unregulated online gambling as a form of tech scamming [[Source 1]](#sec-sources) Probable · 1 source Joint virtual-asset oversight framework published c. 23-25 September 2026 splitting licensing between NBC (banks) and SERC (non-bank CASPs); entities become AML/CFT reporting entities to the Cambodia FIU [[Source 1]](#sec-sources) Probable · 1 source Draft Law on the Management of Virtual Assets and Digital Assets targeted for final draft November 2026; three pillars include AML/CFT, stated to match FATF VASP expectations [[Source 1]](#sec-sources) Probable · 1 source Cambodian courts froze ~US$1bn in assets, issued 32 arrest warrants, sought INTERPOL assistance against 29 fled ringleaders [[Source 1]](#sec-sources) Probable · 1 source Imposed sweeping sanctions on 146 targets within the Prince Group Transnational Criminal Organization [[Source 1]](#sec-sources) Probable · 1 source Joint licensing/reporting framework for virtual-asset firms launched late September 2026; NBC-supervised banks need central-bank approval, other firms need SERC licence, authorised firms become CAFIU reporting entities [[Source 1]](#sec-sources) Uncertain · 1 source Not on the FATF list of 22 jurisdictions under increased monitoring as of 19 June 2026 statement; removed from grey list Feb 2023 [[Source 1]](#sec-sources) Probable · 1 source Casinos and other gambling institutions are designated reporting entities under Art. 5 [[Source 1]](#sec-sources) Uncertain · 1 source OFAC added Hu Xiaowei and 9 individuals/26 entities to Prince Group TCO designation [[Source 1]](#sec-sources) Probable · 1 source EU Council designated Prince Holding Group and chairman Chen Zhi under Global Human Rights Sanctions Regime [[Source 1]](#sec-sources) Probable · 1 source Weaknesses remain with fit and proper tests of casinos, lawyers, and accountants per FATF's August 2023 follow-up report [[Source 1]](#sec-sources) Probable · 1 source Final draft targeted November 2026; legislative approval expected by end of 2026 [[Source 1]](#sec-sources) Probable · 1 source Expanded Prince Group TCO designation on 2026-06-23 adding Hu Xiaowei (named second-in-command) and 9 individuals / 26 entities [[Source 1]](#sec-sources) Probable · 1 source Designated Prince Holding Group and chairman Chen Zhi under the EU Global Human Rights Sanctions Regime on 2026-07-31, citing at least 10 scam compounds operated throughout Cambodia [[Source 1]](#sec-sources) Probable · 1 source NBC Prakas B7-024-735 remains the sole operative crypto-AML gateway for bank/PSP-channel Group 1 crypto-asset activity; authorized firms become FIU reporting entities [[Source 1]](#sec-sources) Probable · 1 source Cambodia is an APG member, exited the FATF grey list in February 2023; August 2023 follow-up report found continuing weaknesses in casino/lawyer/accountant fit-and-proper testing [[Source 1]](#sec-sources) Probable · 1 source Revoked Casino Licence No. 248 for Casino YING HUANG after finding links to online-scam activity and illegal possession of weapons/narcotics [[Source 1]](#sec-sources) Probable · 1 source