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title: "Cambodia gambling licensing, cost and supervision | advennt.io"
canonical: https://advennt.io/jurisdictions/cambodia/
source_html: /jurisdictions/kh/index.html
description: "Cambodia gambling regulation by game: 1 open · 2 restricted · 15 closed · 2 uncertain."
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content_sha256: 08b2900bb3ffb895b7219d13f68138cd90f57154f66931e197a933c565380634
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# Cambodia gambling licensing, cost and supervision | advennt.io

[Jurisdictions](/jurisdictions/) › Cambodia

# Cambodia

National jurisdiction

Avoid except for well-capitalised, AML-robust land-based casino/B2B entry that excludes Cambodian nationals; no online pathway.

[1 open · 2 restricted · 15 closed · 2 uncertain → 20 classes](#products) Collected 25 Oct 2026 · Published 25 Oct 2026 · Changed 25 Oct 2026 [PDF](report.pdf) [Sign in for PDF](https://advennt.io/auth/) [Compare](/compare/?j=cambodia)

## Can we offer our product?

Every product class, in fixed taxonomy order. The band is what you can do; where the recorded legal status says something the band does not, it is shown beside the product.

### Player products

- CasinoProhibited · Models agreeXClosed
- PokerProhibited · Models agreeXClosed
- BingoProhibited · Models agreeXClosed
- LotteryProhibited · Models agreeXClosed
- Sports bettingProhibited · Models agreeXClosed
- Other event bettingProhibited · Models agreeXClosed
- Horse and greyhound racing bettingProhibited · Models agreeXClosed
- Esports bettingProhibited · Models agreeXClosed
- Exchange bettingProhibited · Models agreeXClosed
- Pool bettingProhibited · Models agreeXClosed
- Virtual event bettingProhibited · Models agreeXClosed
- Fantasy sportsProhibited · Models agreeXClosed
- Skill gamesProhibited · Models agreeXClosed
- Prediction marketsProhibited · Models agreeXClosed
- SweepstakesNot yet regulated?Uncertain
- Free playOutside the regulatory perimeter · Models agreeOOpen

### Supply roles

- Software / B2BRRestricted
- Affiliate marketingGrey zone?Uncertain
- Payments for gamblingRRestricted

### Settlement rail

- Crypto gamblingProhibitedXClosed

Class-level certainty is graded for 15 of 20 classes.

## Board briefing

Cambodia is a prohibition-family jurisdiction with a narrow land-based casino carve-out; online gambling is banned and AML/extraterritorial risk is severe.

#### What has changed

- The 2020 LMCG and online gambling ban replaced the prior unregulated environment; the China-facing online sector was dismantled. In 2025-2026, high-profile cross-border enforcement (Chen Zhi extradition, FinCEN Huione designation) and FATF re-listing warnings have sharpened the risk profile.

#### What to do now

- Do not pursue any online B2C or online-platform B2B route into or from Cambodia. Limit any consideration to land-based casino/B2B supply with full CGMC fit-and-proper, minimum-capital and AML compliance, and exclude Cambodian nationals. Escalate to counsel.

#### What to watch

- FATF/APG re-listing decision; CGMC online-supervision specification; further PRC/US extraterritorial actions against gambling-linked entities.

## 11 answers, each dated and graded

The weather grades favourability for an operator, not legality: legality is the product table above. The left rule is our confidence: solid confirmed, dashed probable, dotted uncertain.

01 · What kind of market is this?

### Overview

Unfavourable

Cambodia's gambling sector sits under intensifying enforcement pressure, anchored by two simultaneous threads: a nationwide, multi-agency inspection campaign targeting online gambling within casino premises, and the near US$1 billion domestic asset freeze and warrant action against Prince Group, whi…

Full analysis · 133 words Cambodia's gambling sector sits under intensifying enforcement pressure, anchored by two simultaneous threads: a nationwide, multi-agency inspection campaign targeting online gambling within casino premises, and the near US$1 billion domestic asset freeze and warrant action against Prince Group, which followed a prior US sanctions designation of that network. Against this backdrop, the Commercial Gambling Management Commission is advancing a draft Law on the Suppression of Illegal Gambling, currently under legal-council review with the Ministry of Economy and Finance, and is separately considering a digital duty-payment system to address a reported drop in gambling-duty revenue. No change has occurred to the underlying status of any regulated activity class; the movement is in enforcement intensity and in the legislative and administrative instruments being developed around the existing framework, rather than in the legal perimeter itself.

- Online gambling prohibited since 2020 — no legal online B2C pathway
- Severe AML/scam-compound reputational exposure and FATF re-listing risk
- Cross-border PRC and US extraterritorial enforcement targeting gambling-linked entities

Probable AI-generated [Read full analysis & tables →](/jurisdictions/cambodia/overview/)

02 · Can we get a licence?

### Licensing and regulation

Mixed

CGMC's General Secretariat met with the Ministry of Economy and Finance's legal council on 14 October 2026 to review the draft Law on the Suppression of Illegal Gambling for consistency with the existing Law on Commercial Gambling Management. The draft law has not been enacted, and its full text has…

Full analysis · 138 words CGMC's General Secretariat met with the Ministry of Economy and Finance's legal council on 14 October 2026 to review the draft Law on the Suppression of Illegal Gambling for consistency with the existing Law on Commercial Gambling Management. The draft law has not been enacted, and its full text has not been located in primary form; the finding rests on secondary reporting of the review meeting. This represents a live legislative process at the internal legal-consistency review stage rather than a settled instrument, and no enactment date has been disclosed. The existing Law on Commercial Gambling Management continues to govern licensed casino operations, and nothing in the evidence alters that statute's application to licensed premises. The draft illegal-gambling law appears aimed at strengthening the suppression regime that sits alongside, rather than replacing, the existing commercial gambling licensing framework.

Probable AI-generated [Read full analysis & tables →](/jurisdictions/cambodia/licensing/)

03 · How hard is entry, really?

### Market entry in practice

Mixed

Entry is feasible only for the land-based casino sector and only for well-capitalised investors able to meet the ~USD 100m+ minimum capital and CGMC fit-and-proper requirements; a locally registered Cambodian company is required. Online B2C entry is not legally available. The AML/reputational overla…

Full analysis · 45 words Entry is feasible only for the land-based casino sector and only for well-capitalised investors able to meet the ~USD 100m+ minimum capital and CGMC fit-and-proper requirements; a locally registered Cambodian company is required. Online B2C entry is not legally available. The AML/reputational overlay is severe.

Uncertain AI-generated [Read full analysis & tables →](/jurisdictions/cambodia/market-entry/)

04 · What do the licences cost?

### Licence fees

Mixed

Published fees centre on land-based casino licensing. For casinos inside an integrated commercial gambling resort, the application fee is ~KHR 4,000,000 (~USD 1,000) plus a study fee of ~KHR 80,000,000 (~USD 20,000); for casinos outside, ~USD 500 application plus ~USD 10,000 study fee. Minimum capit…

Full analysis · 73 words Published fees centre on land-based casino licensing. For casinos inside an integrated commercial gambling resort, the application fee is ~KHR 4,000,000 (~USD 1,000) plus a study fee of ~KHR 80,000,000 (~USD 20,000); for casinos outside, ~USD 500 application plus ~USD 10,000 study fee. Minimum capital requirements (KHR 400bn / ~USD 100m; ~USD 200m for integrated resorts) dominate the cost of entry. There is no published online-licence fee schedule because no online licence exists.

Uncertain AI-generated [Read full analysis & tables →](/jurisdictions/cambodia/fees/)

05 · What is the tax take?

### Tax

Mixed

Gross gaming revenue taxation reportedly ranges from 4% to 7% depending on the type and location of the gambling operation, layered over corporate income tax. The tax framework is light by international comparison but applies only to the licensed land-based sector.

Uncertain AI-generated [Read full analysis & tables →](/jurisdictions/cambodia/taxes/)

06 · Can we move player money?

### Payments and banking

Unfavourable

The economy is dollarised and the NBC oversees payment systems. AML/CFT obligations apply to casinos as designated non-financial businesses. Correspondent-banking and PSP de-risking pressure is elevated following the FinCEN Huione designation and ongoing scam-compound scrutiny. Crypto is used in gre…

Full analysis · 46 words The economy is dollarised and the NBC oversees payment systems. AML/CFT obligations apply to casinos as designated non-financial businesses. Correspondent-banking and PSP de-risking pressure is elevated following the FinCEN Huione designation and ongoing scam-compound scrutiny. Crypto is used in grey/illicit flows and crypto gambling is prohibited.

Uncertain AI-generated [Read full analysis & tables →](/jurisdictions/cambodia/payments/)

07 · Can we advertise?

### Marketing

Unfavourable

There is no permissive online marketing pathway: online gambling is banned, and the CGMC has identified and acted against online pages advertising casinos and gambling services on Facebook, Telegram and websites in violation of the LMCG and the 1996 LSG. Land-based casinos market to foreign tourists…

Full analysis · 54 words There is no permissive online marketing pathway: online gambling is banned, and the CGMC has identified and acted against online pages advertising casinos and gambling services on Facebook, Telegram and websites in violation of the LMCG and the 1996 LSG. Land-based casinos market to foreign tourists; advertising of gambling to Cambodian nationals is prohibited.

Probable AI-generated [Read full analysis & tables →](/jurisdictions/cambodia/marketing/)

08 · What must the platform meet?

### Technical compliance

Mixed

CGMC technical standards require registration and certification of gaming equipment and software, with games and rules pre-approved before operation and operated only by licensed special personnel. Online technical specifications are not published as no online licence exists; the regulator has signa…

Full analysis · 48 words CGMC technical standards require registration and certification of gaming equipment and software, with games and rules pre-approved before operation and operated only by licensed special personnel. Online technical specifications are not published as no online licence exists; the regulator has signalled possible future 'online supervision' but without specification.

Not recorded AI-generated [Read full analysis & tables →](/jurisdictions/cambodia/technical/)

09 · Can we ship through apps and platforms?

### Distribution and platforms

Unfavourable

App-store distribution of gambling apps targeting the Cambodian market is not a legal pathway given the online ban. The CGMC has acted against social-media advertising of online casinos. Affiliate marketing of online gambling carries enforcement risk and is not formally registrable.

Probable AI-generated [Read full analysis & tables →](/jurisdictions/cambodia/distribution/)

10 · How hard does the regulator enforce?

### Enforcement

Unfavourable

CGMC and CCOS launched nationwide multi-agency inspections of casinos across sixteen provinces to enforce the ban on online gambling within casino premises, with breaches drawing administrative sanctions and potential criminal referral. The practical effect is already visible: twenty-four casinos ac…

Full analysis · 189 words CGMC and CCOS launched nationwide multi-agency inspections of casinos across sixteen provinces to enforce the ban on online gambling within casino premises, with breaches drawing administrative sanctions and potential criminal referral. The practical effect is already visible: twenty-four casinos across three provinces are reported to have halted online gambling and removed related equipment under this enforcement drive. Separately, and on a larger scale, Cambodian courts issued thirty-two arrest warrants and froze close to US$1 billion in assets linked to Prince Group, seeking INTERPOL assistance against twenty-nine ringleaders who fled overseas. This domestic action followed a prior US sanctions designation of the Prince Group network, indicating that Cambodia's enforcement response in this instance has been reactive to external pressure. No Cambodian government primary notice of the Prince Group asset freeze has been located, so the finding rests on secondary reporting of court action. Together, the two enforcement threads demonstrate that Cambodian authorities are willing to deploy both administrative/criminal-referral powers under the gambling-specific framework and broader judicial asset-freezing and warrant powers against networks assessed as operating illegal or scam-linked gambling activity, at a scale not previously evidenced in the standing record.

Probable AI-generated 20 enforcement events [Read full analysis & tables →](/jurisdictions/cambodia/enforcement/)

11 · What is coming?

### Outlook

Unfavourable

Direction is tightening. Cambodia was removed from the FATF grey list in February 2023 but the NBC publicly warns (2026) that scam-compound and illegal online gambling exposure put it at risk of a third re-listing. The policy trajectory is toward stricter AML enforcement, casino-sector supervision a…

Full analysis · 61 words Direction is tightening. Cambodia was removed from the FATF grey list in February 2023 but the NBC publicly warns (2026) that scam-compound and illegal online gambling exposure put it at risk of a third re-listing. The policy trajectory is toward stricter AML enforcement, casino-sector supervision and suppression of illegal online gambling — not liberalisation. An online B2C pathway is not anticipated.

Probable AI-generated [Read full analysis & tables →](/jurisdictions/cambodia/outlook/)

Evidential record & source register 1 enforcement · 25 red flags · 11 sources · Expand full record

## Enforcement record

What the regulator has actually done, newest first. 1 recorded event.

- 1 Oct 2025Cambodian authorities / China · Chen Zhi (Prince Group)ConfirmedSource 9 · T3

## What gets operators fined

25 red flags (12 high, 6 medium, 2 low) and 3 controls that address them.

- highReliance on stable FATF statusRe-listing risk flagged by NBC in 2026.Source 8 · T3
- highOnline advertising of gambling in CambodiaCGMC acts against social-media gambling ads.Source 10 · T3
- highAdmitting Cambodian nationals to casinosNationals prohibited; foreign passport required.Source 5 · T3
- highCrypto-based gambling fundingCrypto gambling prohibited; crypto used in illicit flows.Source 2 · T1
- highUnderestimating minimum capital~USD 100m+ minimum capital for casino operation.Source 6 · T3
- highAssuming a B2B online platform pathwayNo online B2B licence class exists.Source 1 · T1
- highCorrespondent banking relianceDe-risking pressure from FinCEN actions.Source 2 · T1
- highLarge undeclared cash movementsCross-border cash seizures and arrests.Source 9 · T3
- highSihanoukville legacy associationSector linked to scam-compound repurposing.Source 2 · T1
- highInterpol/extradition exposureActive cross-border enforcement channels.Source 9 · T3
- highInformal facilitation paymentsEndemic corruption; anti-bribery exposure.Source 5 · T3
- highReliance on Chinese player demandDemand base dismantled by PRC enforcement.Source 10 · T3
- mediumOperating in a prohibited zoneCertain zones (e.g. Angkor Wat) bar all gambling.Source 3 · T2
- mediumUnregistered gaming equipment/softwareEquipment and software must be certified/registered with CGMC.Source 7 · T3
- mediumExpired or transferred licenceSub-Decree 102 transitional fines target these.Source 3 · T2
- mediumAssuming liberalising trajectoryDirection is tightening, not opening.Source 8 · T3
- mediumJunket/promoter without licencePromoter licence required; annual renewal.Source 1 · T1
- mediumOnsite CGMC inspectionRegulator has onsite offices at licensed casinos.Source 7 · T3
- lowNo affordability/RG techPlayer-protection regime is minimal.Source 1 · T1
- lowMisreading GGR rateRate varies 4%-7% by type/location.Source 11 · T3
- criticalOperating online gambling targeting any market from CambodiaOnline gambling banned since 2020; no online licence exists.Source 10 · T3
- criticalServing Chinese playersChina-Cambodia joint enforcement, deportations and extraditions.Source 10 · T3
- criticalGambling-linked cross-border payment flowsFinCEN Huione designation; severe AML/scam-compound exposure.Source 2 · T1
- criticalAssociation with scam-compound operatorsPrince Group / Chen Zhi precedent — extradition and liquidation.Source 9 · T3
- criticalStand-alone online-only ambitionsStand-alone online-only licences are not issued.Source 10 · T3

### Controls

- 001Online exclusion controlConfirm no online gambling product is offered into or from Cambodia.Source 10 · T3
- 002Nationals exclusion controlPassport-based exclusion of Cambodian nationals from casino premises.Source 5 · T3
- 003AML/scam-compound diligenceEnhanced due diligence on counterparties, ownership and payment rails to avoid scam-compound and FinCEN-designated exposure.Source 2 · T1

## Worked scenarios

5 entry scenarios, each with the move we would make.

#### Operator seeks to offer online casino to Asian players from a Cambodian base.

Online gambling banned since 2020; no online licence exists; CGMC and police actively enforce.

Do this: Do not proceed; no legal pathway.

Source 10 · T3

#### Investor wants a land-based casino in a promoted zone.

Feasible under LMCG with ~USD 100m+ minimum capital, CGMC fit-and-proper, nationals excluded; 20-year licence in ICGC.

Do this: Proceed only with full capital and AML compliance and counsel.

Source 6 · T3 Source 1 · T1

#### B2B supplier of gaming software to a licensed casino.

Supplier licence required; equipment/software must be certified and registered with CGMC.

Do this: Obtain CGMC supplier licence; certify products.

Source 7 · T3

#### Operator relies on correspondent banking for player flows.

De-risking pressure following FinCEN Huione designation; high payment-blocking risk.

Do this: Map banking exposure; avoid designated entities; counsel review.

Source 2 · T1

#### Conglomerate with gambling-adjacent ventures faces cross-border allegations.

Prince Group/Chen Zhi precedent — extradition to China and liquidation of Cambodian ventures.

Do this: Assess UBO and scam-compound nexus; avoid tainted partners.

Source 9 · T3

## What we looked for and could not find

Confirmed absence is a finding of its own. These are the questions we searched and could not answer from a citable source, with the searches we ran. Never behind the paywall.

Market opportunity. no credible published GGR point estimate for Cambodia's gambling sector located.

- searched: Cambodia gambling GGR estimate 2024
- searched: Cambodia casino gross gaming revenue annual
- searched: CGMC gaming revenue report
- checked: en.wikipedia.org

Competitive landscape. licensed operator count beyond ~10 (Jan 2025 CGMC figure) and unlicensed share not published.

- searched: CGMC licensed casino count 2025
- searched: Cambodia number of licensed casinos current
- searched: Cambodia unlicensed online gambling market share
- checked: ggrasia.com

Fees. full CGMC fee schedule (annual fees, levies) beyond casino application/study fees not located.

- searched: CGMC annual casino licence fee Cambodia
- searched: Cambodia gaming revenue contribution rate
- searched: LMCG fee schedule prakas
- checked: bnglegal.com

## Source register

Every source on a four-step tier scale. A claim is never shown at a stronger tier than the source it cites.

11 sources · 2 tier 1 · 2 tier 2 · 7 tier 3

No. Source Tier Verification

1 KH-LMCG-2020 T1 of 4 Source 1 · Open in drawer →

2 KH-FATF-MER-2023 T1 of 4 Source 2 · Open in drawer →

3 KH-LICENSING-BNG-2023 T2 of 4 Source 3 · Open in drawer →

4 KH-LAW-SUPPRESSION-GAMBLING-1996 T2 of 4 Source 4 · Open in drawer →

5 KH-LSG-1996 T3 of 4 Source 5 · Open in drawer →

6 KH-SUBDECREE-165-166-2021 T3 of 4 Source 6 · Open in drawer →

7 KH-CGMC-ONSITE-2025 T3 of 4 Source 7 · Open in drawer →

8 KH-SIGMA-FATF-2026 T3 of 4 Source 8 · Open in drawer →

9 KH-AGB-CHENZHI-2026 T3 of 4 Source 9 · Open in drawer →

10 KH-WIKI-ONLINEBAN-2026 T3 of 4 Source 10 · Open in drawer →

11 KH-LEGALPILOT-2025 T3 of 4 Source 11 · Open in drawer →