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Cambodia’s Anti-Money Laundering/Counter-Terrorist Financing (AML/CFT) Assessment
The Financial Action Task Force (FATF) has conducted an assessment of Cambodia’s implementation of anti-money laundering and counter-terrorist financing recommendations. This article summarizes the key points related to Recommendation 24 and 25.
Recommendation 24: Beneficial Ownership
Beneficial ownership is a critical aspect of AML/CFT regulations, and FATF assesses countries based on several criteria. Here are the results for Cambodia:
- Criterion 24.1: Mostly met
- Criterion 24.2: Mostly met
- Criterion 24.3: Mostly met
- Criterion 24.4: Mostly met
- Criterion 24.5: Mostly met
- Criterion 24.6: Mostly met
- Criterion 24.7: Partly met (due to limitations in periodically updating customer due diligence)
- Criterion 24.8: Mostly met
- Criterion 24.9: Met
- Criterion 24.10: Mostly met
- Criterion 24.11: Met
- Criterion 24.12: Partly met (gaps remain in filing nominee shareholder contracts)
- Criterion 24.13: Partly met (dissuasive penalties are not available for filing relevant instruments with tax authorities)
- Criterion 24.14: Partly met
- Criterion 24.15: Not met (no monitoring of the quality of assistance regarding international cooperation)
Recommendation 25: Transparency and Beneficial Ownership
Cambodia’s rating for Recommendation 25 remains unchanged since its last assessment in 2017:
- Rating: Partially Compliant
The reasons for this rating are:
- Lack of trusts governed by Cambodian law.
Remaining Deficiencies
Despite some progress, Cambodia still faces several remaining deficiencies under Recommendation 24, including:
- Risk assessment of legal persons
- Sub-decree on nominee shareholder contracts yet to enter into force
- Insufficient dissuasive penalties for filing company registration information
- No monitoring of the quality of assistance regarding international cooperation