Cambodia
Retail_Trading_Status
Status Changed
Previous status: Allowed-Regulated
Reconciled from live analysis after human review confirmed status as Gray-Zone. Original new analysis incorrectly classified as Allowed-Regulated. The corrected analysis maintains the Gray-Zone status because, while a licensed domestic trading avenue exists, individual retail trading is not explicitly legalized in a comprehensive manner. The environment remains restrictive with active enforcement against unlicensed operations, platform blocking, and an evolving regulatory framework that creates uncertainty for retail investors outside the sanctioned channel.
- Analysis ID
- #841
- Version
- Latest
- Created
- 2025-12-13 06:56
- Run
- 0d33a12f...
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- Reconciled
Executive Summary
Retail cryptocurrency trading in Cambodia exists in a 'Gray-Zone.' While not explicitly banned for individuals, the National Bank of Cambodia (NBC) and the Securities and Exchange Regulator of Cambodia (SERC) have implemented significant restrictions, particularly on financial institutions engaging in crypto transactions. The Prakas B7-024-735 Prokor on Transactions Related to Cryptoassets (December 2024) allows licensed institutions to handle specific 'Group 1' crypto-assets, but 'Group 2' assets like Bitcoin remain largely restricted. The environment is further shaped by the blocking of foreign exchanges and a focus on regulated local platforms, highlighting a cautious approach. Enforcement actions, such as the NBC revoking Huione Pay's license in December 2025 for non-compliance with the new crypto rules, demonstrate active policing of the boundary between regulated and unregulated activity.
Key Pillars
- Primary regulators: National Bank of Cambodia (NBC) and Securities and Exchange Regulator of Cambodia (SERC) oversee crypto activities.
- Approach: Restricting financial institutions' involvement in crypto, licensing requirements for service providers, and channeling activity towards regulated domestic platforms. Active enforcement against unlicensed entities.
- Core Compliance: Emphasis on KYC/AML measures for licensed entities operating within SERC's FinTech Regulatory Sandbox. Licensing required for entities involved in fund mobilization, trading, and settlements related to cryptoassets.
Landmark Laws
- Joint Statement on Cryptocurrencies (2018): Issued by the National Bank of Cambodia (NBC), Securities and Exchange Regulator of Cambodia (SERC), and General-Commissariat of National Police prohibiting the propagation, circulation, buying, selling, trading, and settlement of cryptocurrencies without a license.
- NBC Directive (2019): Banned financial institutions from engaging in crypto transactions.
- Prakas B7-024-735 Prokor on Transactions Related to Cryptoassets (December 26, 2024): Allows commercial banks and payment settlement institutions, with prior NBC approval, to provide services related to 'Group 1' crypto-assets (tokenized traditional assets and stablecoins). Mandates licensing for entities involved in crypto asset transactions (fund mobilization, trading, settlements). Classifies assets into Group 1 (tokenized/stablecoins) and Group 2 (unbacked crypto like Bitcoin).
- Fintech Regulatory Sandbox Guidelines (2022): SERC framework allowing innovative financial products, including digital asset exchanges, to operate in a controlled environment.
Considerations
- Crypto assets are classified into two categories: Group 1 (tokenized traditional assets and stablecoins) and Group 2 (unbacked cryptocurrencies like Bitcoin).
- Banks are generally barred from direct exposure to Group 2 assets for their own account but can facilitate customer transactions for licensed services.
- Regulators warn about risks associated with cryptocurrency investments, including volatility, cybercrime, and the potential for money laundering and terrorism financing.
- The Telecommunications Regulator of Cambodia (TRC) blocked access to numerous overseas cryptocurrency exchange websites in November 2024 for operating without licenses.
- There are ongoing AML/CFT concerns related to crypto activities.
- Strict enforcement against unlicensed entities continues, as evidenced by the NBC's revocation of Huione Pay's license in December 2025 for non-compliance with the 2024 Prakas.
Notes
- The legal framework for crypto is still evolving, with further regulations expected from the NBC and SERC.
- There appears to be some jurisdictional overlap or differing approaches between the NBC (focused on financial stability) and SERC (focused on securities and market development).
- Despite website restrictions, mobile applications of foreign exchanges might still be accessible, and users can bypass restrictions using VPNs.
- Thomas Schings of Royal Group Exchange (RGX) stated in January 2024 that it is not illegal for Cambodians to trade or own digital assets.
- Retail traders using unlicensed foreign platforms face risks related to a lack of local investor protection and potential future enforcement actions.
- The blocking of Binance in late 2024 marked a shift towards enforcing a local licensing model.
Remaining Uncertainties
- Specific taxation guidelines for retail crypto capital gains under the new 2024/2025 framework.
- Whether additional international exchanges have applied for or will be granted licenses to break the current local monopoly.
- The long-term status of 'Group 2' assets for banking integration beyond mere custody.
- The extent of jurisdictional coordination between the NBC and SERC in overseeing digital assets.
Detailed Explanation
Detailed Explanation
Cambodia's regulatory status for retail cryptocurrency trading is a 'Gray-Zone,' characterized by a cautious and restrictive approach rather than an explicit ban. The National Bank of Cambodia (NBC) and the Securities and Exchange Regulator of Cambodia (SERC) are the primary regulators shaping this environment. The foundational stance was established by a 2018 Joint Statement from the NBC, SERC, and the General-Commissariat of National Police, which prohibited the propagation, circulation, buying, selling, trading, and settlement of cryptocurrencies without a license. This was followed by a 2019 NBC Directive that explicitly banned financial institutions from engaging in crypto transactions. The regulatory framework has evolved with the December 2024 Prakas B7-024-735 Prokor on Transactions Related to Cryptoassets, which introduces a bifurcated system: it allows licensed commercial banks and payment institutions, with prior NBC approval, to handle 'Group 1' crypto-assets (tokenized traditional assets and stablecoins), while 'Group 2' assets like Bitcoin remain largely restricted for institutional exposure. This creates a channeled environment where activity is meant to flow through regulated domestic platforms, such as those operating under SERC's FinTech Regulatory Sandbox Guidelines from 2022. The regulatory intent is to manage risks like volatility, cybercrime, money laundering, and terrorism financing while fostering controlled innovation. Enforcement is active and demonstrates the boundaries of this gray zone. In November 2024, the Telecommunications Regulator of Cambodia (TRC) blocked access to numerous overseas cryptocurrency exchange websites for operating without licenses. A significant enforcement action occurred in December 2025 when the NBC revoked the license of Huione Pay for non-compliance with the 2024 Prakas, underscoring the consequences for entities that operate outside the prescribed regulatory perimeter. For retail traders, this means that while individuals are not explicitly banned from owning or trading digital assets, as noted by industry figures in 2024, the ecosystem is heavily constrained. The blocking of major platforms like Binance in late 2024 pushes users towards licensed local alternatives, though foreign mobile apps and VPNs provide workarounds. However, using unlicensed foreign platforms carries risks due to a lack of local investor protection and the potential for future enforcement. The legal framework continues to evolve, with further regulations expected, and there appears to be some jurisdictional nuance between the NBC's focus on financial stability and SERC's focus on securities and market development within this complex gray-zone landscape.
Summary Points
I. Regulatory Status
* Cambodia's retail cryptocurrency trading environment is classified as a 'Gray-Zone.'
* Trading is not explicitly banned for individuals, but significant restrictions are placed on financial institutions and service providers.
* The approach is cautious and restrictive, aiming to channel activity towards regulated domestic platforms.
* There is active enforcement against unlicensed entities and platforms.
II. Key Regulatory Bodies
* National Bank of Cambodia (NBC): Primary regulator for financial institutions and payment systems; focuses on financial stability and issued the key 2024 Prakas.
* Securities and Exchange Regulator of Cambodia (SERC): Oversees securities and market development, operates the FinTech Regulatory Sandbox for digital asset exchanges.
* Telecommunications Regulator of Cambodia (TRC): Enforced the blocking of overseas cryptocurrency exchange websites in November 2024.
* General-Commissariat of National Police: Co-signatory to the foundational 2018 Joint Statement prohibiting unlicensed crypto activities.
III. Important Legislation
* Joint Statement on Cryptocurrencies (2018): Issued by NBC, SERC, and National Police, prohibiting the propagation, circulation, buying, selling, trading, and settlement of cryptocurrencies without a license.
* NBC Directive (2019): Banned financial institutions from engaging in cryptocurrency transactions.
* Prakas B7-024-735 Prokor on Transactions Related to Cryptoassets (December 26, 2024): The cornerstone regulation that:
* Allows licensed commercial banks and payment institutions (with prior NBC approval) to provide services for 'Group 1' crypto-assets (tokenized traditional assets and stablecoins).
* Mandates licensing for entities involved in fund mobilization, trading, and settlements related to cryptoassets.
* Classifies crypto-assets into two groups: Group 1 (tokenized assets/stablecoins) and Group 2 (unbacked crypto like Bitcoin).
* Fintech Regulatory Sandbox Guidelines (2022): SERC framework allowing innovative financial products, including digital asset exchanges, to operate in a controlled testing environment.
IV. Compliance Requirements
* Licensing is required for any entity involved in fund mobilization, trading, and settlements related to cryptoassets.
* Entities operating within SERC's FinTech Regulatory Sandbox must adhere to specific operational guidelines.
* Emphasis on KYC/AML measures for licensed entities handling crypto transactions.
* Financial institutions require prior NBC approval to provide services for Group 1 crypto-assets.
V. Notable Restrictions or Limitations
* Financial institutions are generally barred from direct exposure to Group 2 assets (like Bitcoin) for their own account.
* Banks can only facilitate customer transactions for licensed crypto services.
* The Telecommunications Regulator of Cambodia (TRC) blocked access to numerous overseas cryptocurrency exchange websites in November 2024 for operating without licenses.
* Regulators consistently warn the public about risks including volatility, cybercrime, money laundering, and terrorism financing.
* Despite restrictions, mobile apps of foreign exchanges might be accessible, and users can employ VPNs to bypass website blocks.
VI. Recent Developments or Notes
* In December 2025, the NBC revoked the license of Huione Pay for non-compliance with the 2024 Prakas, demonstrating strict enforcement.
* The blocking of Binance in late 2024 marked a significant shift towards enforcing a local licensing model.
* The legal framework is still evolving, with further regulations expected from the NBC and SERC.
* There appears to be some jurisdictional overlap or differing approaches between the NBC (financial stability) and SERC (securities/market development).
* Retail traders using unlicensed foreign platforms face risks due to a lack of local investor protection and potential future enforcement actions.
Full Analysis Report
Full Analysis Report
Report on the Current Status of Retail Cryptocurrency Trading in Cambodia
Date: 2025-12-31 (Updated)
Topic: Retail_Trading_Status
Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity.
Retail_Trading_Status
Status: Gray-Zone
Narrative Explanation:
Retail cryptocurrency trading in Cambodia operates in a definitive 'Gray-Zone,' characterized by a restrictive and actively enforced regulatory framework that channels activity toward licensed domestic platforms while discouraging use of unlicensed foreign services. The legal foundation is the 2018 Joint Statement by the National Bank of Cambodia (NBC), Securities and Exchange Regulator of Cambodia (SERC), and National Police, which prohibits all cryptocurrency activities without a license. This was reinforced by a 2019 NBC directive banning financial institutions from crypto transactions.
A significant development was the NBC's Prakas B7-024-735 Prokor on Transactions Related to Cryptoassets (December 26, 2024). This regulation establishes a licensing regime for Cryptoasset Service Providers (CASPs) and allows commercial banks and payment institutions to handle 'Group 1' crypto-assets (tokenized traditional assets and stablecoins) with prior approval. 'Group 2' assets, including Bitcoin, remain restricted for these institutions. The Prakas mandates licensing for any entity involved in crypto asset transactions, including fund mobilization, trading, and settlements.
Critically, the Prakas and prior directives primarily target institutions and service providers. As Thomas Schings of Royal Group Exchange (RGX) noted in January 2024, it is not illegal for Cambodian individuals to trade or own digital assets. However, the government's enforcement actions create a restrictive environment. In November 2024, the Telecommunications Regulator of Cambodia (TRC) blocked access to 16 major offshore cryptocurrency exchange websites (including Binance, Coinbase, OKX) for operating without licenses. This action aims to direct users toward the regulated domestic ecosystem.
The primary licensed retail trading avenue is the Royal Group Exchange (RGX), which operates within SERC's FinTech Regulatory Sandbox launched in 2022. RGX requires full KYC/AML compliance. The regulatory distinction between permissible individual activity on licensed platforms and prohibited unlicensed service provision creates ambiguity. Enforcement remains active; in December 2025, the NBC revoked the license of payment provider Huione Pay Plc. for conducting cryptocurrency transactions that did not comply with the 2024 Prakas, signaling serious intent to police the regulated boundary.
In summary, individual Cambodians are not explicitly prohibited from buying, selling, or holding cryptocurrencies. However, the regulatory environment is restrictive, with access to unlicensed foreign platforms blocked and activity funneled toward a limited number of licensed domestic entities under evolving rules. This combination of non-explicit prohibition for individuals, stringent licensing for service providers, active enforcement against unlicensed operations, and ongoing regulatory development creates a clear 'Gray-Zone' status. Retail traders using unlicensed foreign platforms face risks including lack of local investor protection and potential enforcement actions, while the licensed domestic option remains part of a developing regulatory experiment.
**Report on the Current Status of Retail Cryptocurrency Trading in Cambodia** **Date:** 2025-12-31 (Updated) **Topic:** Retail_Trading_Status **Description:** Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity. **Retail_Trading_Status** **Status:** Gray-Zone **Narrative Explanation:** Retail cryptocurrency trading in Cambodia operates in a definitive 'Gray-Zone,' characterized by a restrictive and actively enforced regulatory framework that channels activity toward licensed domestic platforms while discouraging use of unlicensed foreign services. The legal foundation is the 2018 Joint Statement by the National Bank of Cambodia (NBC), Securities and Exchange Regulator of Cambodia (SERC), and National Police, which prohibits all cryptocurrency activities without a license. This was reinforced by a 2019 NBC directive banning financial institutions from crypto transactions. A significant development was the NBC's **Prakas B7-024-735 Prokor on Transactions Related to Cryptoassets (December 26, 2024)**. This regulation establishes a licensing regime for Cryptoasset Service Providers (CASPs) and allows commercial banks and payment institutions to handle 'Group 1' crypto-assets (tokenized traditional assets and stablecoins) with prior approval. 'Group 2' assets, including Bitcoin, remain restricted for these institutions. The Prakas mandates licensing for any entity involved in crypto asset transactions, including fund mobilization, trading, and settlements. Critically, the Prakas and prior directives primarily target institutions and service providers. As Thomas Schings of Royal Group Exchange (RGX) noted in January 2024, it is not illegal for Cambodian individuals to trade or own digital assets. However, the government's enforcement actions create a restrictive environment. In **November 2024**, the Telecommunications Regulator of Cambodia (TRC) blocked access to 16 major offshore cryptocurrency exchange websites (including Binance, Coinbase, OKX) for operating without licenses. This action aims to direct users toward the regulated domestic ecosystem. The primary licensed retail trading avenue is the **Royal Group Exchange (RGX)**, which operates within SERC's FinTech Regulatory Sandbox launched in 2022. RGX requires full KYC/AML compliance. The regulatory distinction between permissible individual activity on licensed platforms and prohibited unlicensed service provision creates ambiguity. Enforcement remains active; in **December 2025**, the NBC revoked the license of payment provider Huione Pay Plc. for conducting cryptocurrency transactions that did not comply with the 2024 Prakas, signaling serious intent to police the regulated boundary. In summary, individual Cambodians are not explicitly prohibited from buying, selling, or holding cryptocurrencies. However, the regulatory environment is restrictive, with access to unlicensed foreign platforms blocked and activity funneled toward a limited number of licensed domestic entities under evolving rules. This combination of non-explicit prohibition for individuals, stringent licensing for service providers, active enforcement against unlicensed operations, and ongoing regulatory development creates a clear 'Gray-Zone' status. Retail traders using unlicensed foreign platforms face risks including lack of local investor protection and potential enforcement actions, while the licensed domestic option remains part of a developing regulatory experiment.
Source Evidence
Primary and secondary sources cited in this analysis
"The propagation, circulation, buying, selling, trading and settlement of Crypto Currencies without obtaining license from competent authorities are illegal activities."
"The NBC has also identified cryptocurrency transactions... that do not comply with NBC Notification Number B7-024-735 Prokor dated 26 December 2024."
"The Prakas on Cryptoassets formally permits commercial banks and payment settlement institutions operating under the NBC supervision to provide services relating to crypto assets... subject to prior approval from the NBC."
"The Telecommunications Regulator of Cambodia (TRC) announced that it has blocked... crypto exchanges... due to licensing issues."
"First of all, let me clarify that there was never a full-on ban against crypto or digital assets in Cambodia. It’s not illegal to trade in cryptocurrencies or own digital assets in general..."
"RGX is currently licensed by, and operating within, the SERC's 'Fintech Regulatory Sandbox'."
"Although this ban [NBC directive of 2019 on financial institutions] does not apply to individuals willing to invest their money in cryptocurrency, it prevents any type of institutional investment or regulation from taking place."
Web Sources (15)
Sources discovered via web search grounding
Search queries used (6)
- Cambodia cryptocurrency regulation 2024 2025
- National Bank of Cambodia crypto joint statement 2018
- Royal Group Exchange RGX Cambodia license
- is crypto trading legal in Cambodia for individuals
- Binance Cambodia license status
- SERC Cambodia digital asset license list
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