The International Monetary Fund (IMF) has described Cambodia’s legal framework for preventing criminals from owning or controlling casinos – and vetting process for identifying them – as deficient and in need of urgent attention.
In its 2026 Article IV Consultation press release and staff report following a recent national assessment, the IMF identified a series of core concerns surrounding Cambodia’s casino framework including the fact that the Law on the Management of Commercial Gambling (LMCG) only requires major shareholders – those holding 10% or more shares – and senior managers of an applicant to have “good reputation, characteristics, honesty and integrity.”
It also noted that the assessment process of the gambling regulator, the Commercial Gambling Management Commission of Cambodia (CGMC), does not go beyond reviewing certificates of criminal records submitted by applicants.
The IMF has therefore recommended that the LMCG be amended to ensure that beneficial owners and directors, in addition to managers and directors, are subject to robust fit and proper tests and that the CGMC satisfies itself of the lawful origin of funds before issuing a license.
“Most existing licenses are expected to be renewed around 2027, offering a good opportunity to review the licensees against upgraded requirements,” it said.
The focus on Cambodia’s casino sector forms part of the IMF’s broader review of high-risk sectors, which also include banks and payment institutions. The IMF said it was critical that regulators of Cambodia’s various industries share information in order to better understand the business links of applicants.
Information sharing between licensing departments and supervision departments is also key in ensuring fit and proper on an ongoing basis by identifying potential concerns in supervision and addressing them in a timely manner, it added.
“When conducting fit and proper tests for beneficial owners, directors and senior managers of an applicant and assessing the legitimacy of the source of funds, the [relevant authority] should investigate the business linkages of companies and individuals involved in the applicant,” the IMF stated. “When an applicant’s other business is considered high-risk or is associated with a politically exposed person, further due diligence may be needed, including through information exchange between regulators.”
Aside from the casino sector, the IMF said Cambodia’s existing licensing requirements for banks and payment providers are inadequate to ensure that new entrants are not tied to criminal activities.
Concerns around Cambodia’s casino sector are nothing new, with the country currently focusing significant energy on combatting scam centers that have in recent years proliferated – in many cases using casino licenses as cover.
In early September, Cambodia’s anti-scam agency released details of action it has taken against suspect casino locations, revealing it has annulled the licences of 18 casinos nationwide and suspended those of nine more, pending further investigation.
Last week Cambodia hosted the International Conference on Combating Online Scams (ICCOS), where 28 nations and seven international organizations signed the “Phnom Penh Declaration” – a document outlining 11 key commitments aimed at dismantling criminal networks linked to online scam operations.
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