Cambodia’s Progress in Implementing Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Measures
Based on a thorough assessment, Cambodia has made significant progress in implementing the Financial Action Task Force (FATF) Recommendations related to AML/CFT. However, minor gaps still exist in the country’s framework.
Summary of Assessment
The assessment highlights Cambodia’s progress in addressing various FATF Recommendations, specifically:
Recommendation 15: Customer Due Diligence and Beneficial Ownership
- Partial Compliance (PC) in the 2017 Mutual Evaluation Report (MER)
- Addressed through the Law on AML/CFT, requiring financial institutions to verify the identity of the originator or beneficiary if not previously identified and verified
- The Remittance Directive also requires financial institutions to comply with these requirements
Recommendation 16: Wire Transfers
- Partial Compliance (PC) in the 2017 MER
- Addressed through the Law on AML/CFT, requiring financial institutions to have risk-based policies and procedures for determining whether to execute, reject, or suspend wire transfers lacking originator or beneficiary information
- The Remittance Directive also requires financial institutions to comply with these requirements
Recommendation 17: Correspondent Banking
- Partial Compliance (PC) in the 2017 MER
- Addressed through the Law on AML/CFT, requiring financial institutions to comply with all relevant requirements of the Directive whether they operate directly or through agents
Recommendation 18: Internal Controls
- Partial Compliance (PC) in the 2017 MER
- Addressed through the new Law on AML/CFT and the Directive on Internal Controls, which require internal policies, procedures, and systems for AML/CFT to be commensurate with the nature and size of the reporting entity
Conclusion
Based on these assessments, it can be concluded that Cambodia’s framework is largely compliant with FATF Recommendations 15, 16, 17, and 18. The country has made significant progress in implementing AML/CFT measures, but there are still some minor gaps that need to be addressed.