IMF: Cambodia’s rules to bar criminals from casino ownership are deficient

The International Monetary Fund says Cambodia’s legal framework for preventing criminals from owning or controlling casinos is "deficient" and must be fixed quickly, in a report published on Monday, 30 September 2026. The IMF urged Cambodian authorities to upgrade the ownership vetting process for casinos and flagged the approaching cluster of licence renewals around 2027 as the right moment to apply stronger checks.

IMF finding: deficient framework and a clear priority

The IMF’s report describes two core weaknesses. First, the Law on the Management of Commercial Gambling only requires major casino shareholders — defined as those holding 10 percent or more — and senior managers to have a “good reputation” and characteristics of “honesty and integrity”. Second, there is no general statutory requirement to establish a legitimate source of funds in the licensing of banks, payment institutions, and casinos. The IMF called the absence of fit-and-proper requirements for beneficial owners, and the lack of source-of-funds checks, "a significant vulnerability" that should be addressed as "a top priority".

"Most existing licences are expected to be renewed around 2027, offering a good opportunity to review the licensees against upgraded requirements," the IMF said.

The report records how, in practice, the Commercial Gambling Management Commission of Cambodia conducts a limited assessment that "does not go beyond reviewing certificates of criminal records submitted by applicants." That approach leaves potential gaps in identifying beneficial owners who may exert control through nominee structures or opaque arrangements.

Why 2027 is framed as the opportunity to act

The IMF pointed to timing as a practical lever. Most existing casino licences in Cambodia are expected to come up for renewal around 2027, which the Fund described as a chance to re-assess licensees under strengthened standards. Implementing higher vetting thresholds at renewal gives authorities a discrete administrative window to apply stricter checks without requiring immediate unilateral revocations across the entire industry.

Cambodian Prime Minister Hun Manet has announced policy intentions that align with the IMF's concerns. The Prime Minister said the government plans to reduce the number of casinos in the country gradually and to tighten licensing requirements for the sector. Cambodia still has more than 100 legally-licensed casinos in operation, a figure Hun Manet characterised earlier in September 2026 as "excessive." The IMF sees both the licensing and the broader financial-integrity framework as interconnected issues.

Specific legal gaps identified by the IMF and suggested changes

The IMF recommended amendments to ensure that beneficial owners and shareholders, as well as managers and directors, are subject to a robust fit-and-proper test. The Fund noted that current law focuses narrowly on major shareholders and senior staff, while oversight in practice is limited to criminal-record certificates.

Key vulnerabilities the IMF highlighted:

• absence of fit-and-proper tests for beneficial owners;

• no mandatory demonstration of legitimate source of funds for banks, payment institutions and casinos;

• practical vetting by the Commercial Gambling Management Commission of Cambodia that is limited to criminal-record checks.

Those points create a pathway for illicit actors to gain control without detection, according to the report, and the Fund classified remediation as a high priority for Cambodia’s authorities.

Regulatory response and enforcement actions this month

The Commercial Gambling Management Commission of Cambodia (CGMC) has told local media and industry interlocutors that it is developing an integrity assessment framework to apply when considering casino licence applications and renewals. The stated aim is to strengthen oversight and to establish clearer suitability requirements for operators.

Authorities have already taken enforcement steps in parallel. Earlier in September 2026, the government revoked the licences of 18 casinos as part of a nationwide campaign targeting online scam operations, and suspended operations at a further nine casinos pending inquiries. Those actions formed part of an effort to disrupt entities linked to fraud and to tighten control over the sector’s operations.

What operators and regulators should expect next

Operators with licences due for renewal around 2027 should prepare for more stringent integrity checks on ownership structures, including demands to identify beneficial owners and to provide documentary proof of funds. Regulators will need to define the scope of a "robust" fit-and-proper test, set thresholds for documentary evidence of funds, and build investigatory capacity to verify complex ownership chains.

For compliance teams, the immediate priorities are clearer record-keeping on ownership layers, readiness to disclose source-of-funds documentation, and alignment with any integrity assessment the CGMC finalises. Regulators will also need to clarify how new requirements intersect with licensing rules for banks and payment institutions.

Wider context and industry implications

The IMF framed its recommendations within Cambodia’s stated policy objective of gradually reducing casino numbers and tightening licensing. That objective, and the enforcement steps taken in September 2026, signal a policy environment moving toward stricter financial-integrity controls in the gaming sector. The CGMC’s integrity framework and the 2027 renewal timeline are likely to be the practical channels through which those changes are implemented.

Operators, platform providers and financial intermediaries active in Cambodia should follow developments closely and expect detailed regulatory guidance from the Commercial Gambling Management Commission of Cambodia and other Cambodian authorities over the coming months. The converging signals from the IMF and the government make ownership vetting an immediate compliance priority for the market.