The Non‑Bank Financial Services Authority of Cambodia has introduced Prakas 093 on the Licensing and Management of Digital Asset Businesses on 30 December 2026. The Prakas applies to all activities relating to digital asset business for investment purposes and explicitly excludes the application to payment transactions involving digital assets or virtual assets conducted in Cambodia.
Key definitions outlined in the new regulation are:
“Digital Asset” referring to the Cambodia Financial Technology Development Policy 2023-2028, means valuable digital units created on distributed ledger technology or similar technology or associated with a smart contract or contract in the various forms between digital asset holders and counterparts and can be traded or transferred, including Bitcoin. Digital Assets are classified as financial instruments and constitute a type of securities.
“Digital Asset Service Provider” means a company that has obtained a license from the Securities and Exchange Regulator of Cambodia (“SERC”) to conduct authorized digital asset business activities in accordance with this Prakas.
“Digital Asset Agent” refers to an individual employed by a Digital Asset Service Provider who is licensed by the SERC to perform the permitted activities set out under this Prakas.
Permitted Activities
A Digital Asset Service Provider is permitted to perform the following activities:
- trading related activities: acting as central counterparty, providing brokerage services, operating trading platforms and derivative instruments, providing person-to-person trading platforms, providing investment advisory, creating and selling Digital Assets directly on the trading platform and marketing and advertising;
- digital wallet related activities: custodial services and deposit, withdrawal and transfer related services between wallets, addresses and storage locations;
- borrowing and lending activities: transferring Digital Assets from a lender to a borrower who must return the same type of Digital Assets to the lender pursuant to the contractually agreed terms between the lender and the borrower;
- management related activities: administering and managing Digital Assets on behalf of the customers; and
- other activities as permitted by the SERC.
A Digital Asset Service Provider must partner with a cash settlement agent authorized for securities-related transactions for any conversion of Digital Assets to cash or cash to Digital Assets.
Licensing Requirements
All Digital Asset Service Providers must obtain a license from the SERC before commencing operations. The initial license is valid for two years and, following renewal, the license is valid for three years, noting that the renewal application must be submitted to the SERC at least 60 days prior to the expiration of the existing license.
Prakas 093 sets out comprehensive licensing requirements in terms of capital, human resources and operational aspects. These include, among others:
- having incorporated as a company in Cambodia;
- having completed tax registration in Cambodia;
- successful testing of IT systems, business models, products, or services relating to digital asset services in the securities regulatory sandbox environment;
- proper management structure and allocation of responsibilities for each business model;
- minimum capital of KHR 40,000,000,000 (approx. USD 1 million) for permitted activities (1), (3) and (4) and KHR 4,000,000,000 (approx. USD 100,000) for permitted activities (2);
- for permitted activities (1), (3) and (4), at least one director, chief executive officer, head of control committee, finance manager, operation manager, risk control manager, audit and internal control manager, head of IT, head of each business unit, head of Digital Asset Agents and legal officer and Digital Asset Agents;
- business guarantee deposit in the amount of 15% of the minimum capital paid to the SERC’s account
- a business plan covering three years from the date of submission of the application; and
- policies relating to cybersecurity, data protection and customer privacy.
Ongoing Obligations
- obtaining prior approval from the SERC for any specific changes such as changes of a corporate shareholder, corporate name, corporate form, board composition, registered address, articles of incorporation, merger, business transfer, suspension or cessation of any permitted digital asset businesses;
- segregation of client assets;
- compliance with anti‑money laundering and counter‑terrorism financing obligations;
- adherence to fair‑dealing and disclosure requirements;
- fulfillment of record‑keeping and reporting obligations; and
- periodic audits and inspections conducted by SERC.
What’s Next for Digital Assets/Crypto Assets
Nearly a year after the National Bank of Cambodia issued Prakas on Transactions Related to Cryptoassets on 26 December 2024 (click here for our client alert on this regulation), this regulation will enhance the development of legal framework required for the exchange, trading and transfer of digital assets in Cambodia.
Since Digital Asset Service Providers must cooperate with cash settlement agents (which are all commercial banks) for conversion of Digital Assets to cash and vice versus, cash settlement agents must be properly permitted by the National Bank of Cambodia to hold cryptoasset exposures. It is expected that the pending regulations regarding cryptoasset exposures by commercial banks will be issued by the National of Cambodia over the coming months.
The information provided here is for information purposes only and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.
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