Cambodia Struggles to Access Accurate Shareholder Information, Despite Efforts to Combat Money Laundering

Progress Made, but Challenges Remain

PHNOM PENH, Cambodia - The Cambodian government has made significant progress in combating money laundering (ML) and terrorist financing (TF), but remains plagued by issues related to accessing accurate shareholder information. According to a recent report by the Asia-Pacific Group on Money Laundering (APG), Cambodia’s efforts to combat ML/TF are hindered by limited understanding of its risks, gaps in data collection, and lack of coordination among relevant agencies.

Limitations of National Risk Assessment

The APG report highlights that while Cambodia has completed its first National Risk Assessment (NRA) exercise, the assessment has limitations. The NRA is based solely on information from identified criminal activities and does not include other credible sources. Additionally, the assessment failed to consider risks posed by legal persons, foreign trusts, and the non-profit/NGO sector.

Challenges in Financial Intelligence Unit

The report also notes that Cambodia’s financial intelligence unit (CAFIU) produces limited operational analysis and no strategic analysis due to resource constraints. This significantly undermines the use of financial intelligence by competent authorities in investigating ML/TF.

Lack of Coordination Among Agencies

Furthermore, the APG report highlights that there is a lack of coordination between relevant agencies at an operational level. There is no mechanism for executing decisions made by the National Coordination Committee (NCC) or broader operational-level coordination on AML/CFT issues.

Government Efforts Praised, but More Work Needed

Despite these challenges, Cambodia’s government has been praised for its efforts to combat ML/TF, including the development of a national anti-money laundering and countering the financing of terrorism strategy from 2013 to 2017. However, more work needs to be done to address the identified gaps and limitations in order to effectively combat ML/TF.

Commitment to Review AML/CFT Policies

The Cambodian government has committed to reviewing its AML/CFT policies and strategies based on the results of the NRA exercise, but it remains unclear when this review will take place.

International Organizations Urge Action

In the meantime, international organizations and experts are urging Cambodia to address the identified shortcomings in order to strengthen its efforts to combat ML/TF.