Financial Crime World

Cambodia’s Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Efforts: An Assessment

Assessment of Risks

Cambodia has a mixed level of understanding of its Money Laundering/Terrorist Financing (ML/TF) risks, which varies across competent authorities and the private sector. The country’s first National Risk Assessment (NRA) was completed in 2016 but had limitations.

  • Medium to low risk assessment: Cambodia’s ML/TF risks are assessed as medium to low.
  • Limited risk assessment: The NRA did not consider risks associated with:
    • Legal persons
    • Foreign trusts
    • Non-profit organizations (NPOs)
    • NGOs
    • Dealers in precious metals and stones

Coordination and Policy Setting

Cambodia has well-established inter-agency cooperation and coordination at a policy level through the National Coordination Committee (NCC). However, there is no coordination mechanism to execute NCC decisions or for broader operational-level coordination on AML/CFT issues between relevant agencies.

  • Policy-level coordination: The NCC provides a framework for inter-agency cooperation.
  • Operational-level gaps: There are gaps in coordination and execution of NCC decisions.
  • Statistics: Cambodia lacks statistics on the effectiveness and efficiency of its AML/CFT systems.

Financial Intelligence, Money Laundering, and Confiscation

Cambodia has a minimal use of financial intelligence and information across competent authorities investigating ML/TF or predicate offenses. The Financial Intelligence Unit (CAFIU) produces limited operational analysis and no strategic analysis due to resource constraints.

  • Limited financial intelligence: CAFIU’s resources are insufficient for effective analysis.
  • Broad powers: Cambodia’s legal system provides broad powers and responsibilities for law enforcement agencies to investigate and prosecute ML offenses, but effectiveness has not been demonstrated.

Confiscation

There is an absence of coordination and effective cooperation at the operational level across Law Enforcement Agencies (LEAs). Only three ML investigations were conducted, none of which proceeded to prosecution.

  • Coordination gaps: LEAs lack coordination and cooperation on confiscation matters.
  • Limited investigations: Few ML investigations have been conducted, with no resulting prosecutions.