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Cambodia’s Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Measures

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Assessment of Risks, Coordination, and Policy Setting


Cambodia has made efforts to assess its Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) risks. However, there are areas for improvement.

Understanding of ML/TF Risks

  • Cambodia has a mixed level of understanding of its ML/TF risks.
    • Working group members, banks, and microfinance institutions have a reasonable understanding of the risks.
    • Other authorities, however, have low levels of understanding.
  • The National Risk Assessment (NRA) is based solely on identified criminal activities and does not include information from credible sources such as research or trends analysis.

Financial Intelligence, Money Laundering, and Confiscation


Financial intelligence plays a crucial role in AML/CFT efforts. However, Cambodia faces challenges in this area.

Use of Financial Intelligence

  • There is minimal use of financial intelligence across competent authorities investigating ML/TF or predicate offences.
  • CAFIU produces very limited operational analysis and no strategic analysis due to resource constraints, significantly undermining the use of financial intelligence by competent authorities.
  • Cambodia’s legal system provides a broad set of powers for LEAs to investigate and prosecute ML offences, but effectiveness has not been demonstrated.

Coordination Mechanisms


Effective coordination is essential for AML/CFT efforts. However, Cambodia faces challenges in this area.

Inter-Agency Cooperation

  • There is well-established inter-agency cooperation at a policy level through the National Coordination Committee (NCC).
  • No coordination mechanism exists for executing decisions or operational-level coordination on AML/CFT issues.
  • Major shortcomings exist in statistics provided by Cambodia on matters relevant to the effectiveness and efficiency of its AML/CFT systems.

Recommendations


Based on the assessment, some potential recommendations are:

  1. Improve understanding of ML/TF risks: Provide training and capacity building for all authorities to enhance their understanding of ML/TF risks.
  2. Conduct a comprehensive NRA: Include information from credible sources such as research or trends analysis in the National Risk Assessment (NRA).
  3. Enhance use of financial intelligence: Improve the use of financial intelligence across competent authorities investigating ML/TF or predicate offences.
  4. Develop strategic analysis at CAFIU: Provide more effective support to competent authorities through the development of strategic analysis at CAFIU.
  5. Improve coordination and cooperation: Establish a coordination mechanism for executing decisions and operational-level coordination on AML/CFT issues between LEAs.

Note that these recommendations are based on a limited text and may not be exhaustive or comprehensive.