On 28 January 2026, Cambodia’s Non-Banking Financial Services Authority issued Prakas No. 009 on disciplinary sanctions for trust-sector reporting entities that fail to comply with AML/CFT obligations. The Prakas was reported by Rajah & Tann Asia in February 2026 and is another useful indicator of increasing AML/CFT formality in the region.
The Prakas is specific to reporting entities in the trust sector, but it sits within a broader non-bank financial services framework. Cambodia’s non-bank financial sector includes areas such as insurance and private pension, securities and exchange, social security, trust, accounting and auditing, real estate, pawnshop, and security-as-transfer sectors.
What the Prakas covers
According to the published summary, Prakas No. 009 sets out disciplinary measures that may be imposed for failures to comply with anti-money laundering and counter-terrorist financing obligations.
The obligations referenced include:
- conducting Know Your Client due diligence;
- paying special attention to certain transactions;
- maintaining records of customer identity and transactions for at least five years;
- reporting to the Cambodia Financial Intelligence Unit and other competent authorities;
- creating an AML/CFT program with policies, procedures and internal controls.
Potential administrative measures include restrictions, suspension or revocation of licence or approval, in addition to monetary fines where applicable.
Why this matters for non-bank businesses
The point is not that every non-bank business faces the same rules in the same way. The point is that AML/CFT supervision is becoming more structured across sectors that sit outside traditional banking.
That matters for insurance intermediaries, professional services firms, corporate services providers, fintechs, real estate-related businesses and other organisations that may need to show they have a practical customer due diligence process.
How Kyboa supports this type of workflow
Kyboa helps firms create a documented screening process for companies and individuals. It supports sanctions, PEP and watchlist screening, adverse media and web discovery, maintained entity records, monitoring alerts and audit-ready reports.
For teams that do not have large internal compliance departments, this can provide a structured way to record who was screened, what was found, what was reviewed and when the review took place.
Compliance is becoming more operational
The Cambodia Prakas is part of the same regional pattern seen in Malaysia, Singapore and Thailand: regulators are placing more emphasis on documented CDD, record keeping, review processes and the ability to evidence compliance activity.
For smaller regulated businesses, the practical challenge is not just knowing the rules. It is implementing a repeatable process that can be used consistently without enterprise-level complexity.
Sources: Rajah & Tann Asia summary of Prakas No. 009; Cambodia Non-Bank Financial Services Authority sector overview
