IMF Rates Cambodia's Legal Framework for Blocking Criminals from Casino Ownership as "Deficient"

The International Monetary Fund (IMF) states that Cambodia's legal framework for preventing criminals from owning or controlling casinos is deficient and needs to be addressed urgently, according to its report published on Monday. The organization recommends improving the investigation process regarding ownership and taking advantage of the mass license renewal expected around 2027 to implement stricter requirements.

Diagnosis of the legal framework for casinos in Cambodia

The report highlights two key shortcomings: the absence of "fit-and-proper" requirements for beneficial owners and the lack of a mandate to verify the legitimate source of funds in licensing banks, payment entities, and casinos. The IMF describes both omissions as "a significant vulnerability" that should be prioritized.

"The absence of fit-and-proper requirements for beneficial owners, as well as the lack of a requirement to establish a legitimate source of funds... is a significant vulnerability," notes the IMF report.

The document states that the Law on the Management of Commercial Gambling requires significant shareholders — those with a stake of 10% or more — and senior executives to have a "good reputation" and traits of "honesty and integrity." However, in practice, the evaluation by the Commercial Gambling Management Commission of Cambodia (CGMC) "does not go beyond verifying criminal background certificates submitted by applicants," according to the IMF.

License review and timeline: the 2027 window

The IMF identifies 2027 as a turning point: most existing licenses are expected to be renewed around that year. The organization understands that this renewal process presents "a good opportunity" to assess license holders against updated requirements.

The Cambodian government, led by Prime Minister Hun Manet, has expressed an intention to gradually reduce the number of casinos and tighten licensing requirements for the sector. The Prime Minister described the current total as "excessive."

Cambodia still operates over 100 legally authorized casinos, as noted in the report and official statements.

Assessment of the regulatory authority: CGMC and its integrity framework proposal

The Commercial Gambling Management Commission of Cambodia (CGMC) is the entity responsible for evaluating license applications and renewals. The IMF criticizes that CGMC's practice is limited to verifying criminal background certificates and recommends subjecting beneficial owners and shareholders, as well as executives and managers, to a robust suitability test.

The CGMC has stated — and GGRAsia previously reported — that it is developing an integrity assessment framework to be used when considering license applications and renewals. The initiative aims to strengthen sector oversight and establish suitability requirements for operators.

Recent actions and penalties: revocations and suspensions

Cambodian authorities confirmed this month that they revoked the licenses of 18 casinos as part of a national campaign against online scam operations. In addition, operations of 9 casinos were suspended while further investigations are carried out.

These formal actions appear in the report and official statements as concrete measures of regulatory efforts to clean up the sector and act against illicit activities linked to certain gaming establishments.

Practical implications for regulators and operators

For authorities, the IMF recommends two concrete lines of action: broaden the definition and scope of suitability tests to include beneficial owners and require proof of the legitimate source of funds in banking, payment entity, and casino licenses. Including these requirements aims to cut off channels for dubious capital inflows.

For operators, the combination of a stricter integrity framework and reviews during the 2027 renewals will imply greater due diligence on shareholding structures and source of funds. Companies with shareholders exceeding 10% or with opaque ultimate beneficiaries may face more extensive investigative processes by the CGMC.

Where this places Cambodia on the regional agenda

The IMF report positions Cambodia among countries that need to strengthen their controls over gambling and finances to mitigate risks of money laundering and crime linked to the sector. The analysis directly links reforming the licensing regime with managing vulnerabilities affecting banks and payment providers.

For readers interested in the broader regulatory impact, the regulatory implications intersect with financial oversight and compliance issues in payments and licensing, making the topic relevant for compliance teams, platform providers, and tax authorities. For updates on regulatory reforms, we cover the regulations and their effects in the regulation section and operational news for the sector in news.