The KMaker team brings together experts in compliance technology, financial crime prevention, and regulatory intelligence to help …
Article 4 of Cambodia's AML Law: Who Qualifies as a Reporting Entity?
Cambodia’s Law on Anti-Money Laundering and Combating the Financing of Terrorism establishes a broad regulatory framework that extends well beyond traditional banking. Article 4 of the present Law defines the full scope of institutions and professions that are classified as “reporting entities” — organizations legally obligated to implement anti-money laundering controls, conduct customer due diligence, and file suspicious transaction reports with the Cambodia Financial Intelligence Unit (CAFIU).
Understanding exactly who falls under Article 4 is the first step toward compliance. Many businesses operating in Cambodia may not realize they are subject to these obligations.
The Full List of Reporting Entities Under Article 4
The present Law applies to fifteen categories of institutions and professions. For ease of reading, we have grouped them into four sectors below. Note that these groupings are editorial — Article 4 presents them as a single numbered list.
Banking and Core Financial Institutions
These institutions handle the bulk of financial transactions in the economy and are the first line of defense against money laundering.
| # | Reporting Entity | Key Note |
|---|---|---|
| 1 | Banks, including branches of foreign banks | All commercial banks — domestic and foreign branches |
| 2 | Non-bank financial institutions | Securities brokerage firms and insurance companies |
| 3 | Micro finance institutions | Significant category given the size of Cambodia’s micro finance sector |
| 4 | Credit cooperatives | Cooperative lending organizations providing credit to members |
| 5 | Leasing companies, investment and pension funds, investment companies and companies for managing investment funds | Any entity pooling, managing, or deploying capital on behalf of others |
Money Services and Value Transfer
These entities facilitate the movement of money and currency exchange — channels frequently exploited for ML/TF.
| # | Reporting Entity | Key Note |
|---|---|---|
| 6 | Exchange offices | Particularly relevant in Cambodia’s dual-currency economy (USD and KHR) |
| 7 | Remittance services | Cross-border remittance flows are a well-known ML channel |
| 8 | Trust | Trust arrangements can obscure beneficial ownership |
| 11 | Post office operating payment transactions | Same AML/CFT obligations as other financial service providers |
Designated Non-Financial Businesses and Professions (DNFBPs)
Article 4 extends well beyond banking to cover non-financial businesses and professions involved in high-risk activities.
| # | Reporting Entity | Key Note |
|---|---|---|
| 9 | Agents, companies and developers of immovable property, building and land | Cambodia’s rapidly growing property sector is a recognized ML vehicle |
| 10 | Dealers in precious metals, stones, and gems | High-value, easily transportable commodities attractive for ML |
| 12 | Lawyers, notaries, accountants, auditors, investment advisors, and asset managers | Conditional obligation — applies when facilitating transactions under Article 5 |
| 13 | Casinos and other gambling institutions | Cambodia’s border casino sector flagged internationally as high-risk |
Non-Profit Sector and Catch-All Provision
The final two categories ensure the framework is both comprehensive and adaptable.
| # | Reporting Entity | Key Note |
|---|---|---|
| 14 | Non-governmental organizations and foundations engaging in business activities and fund raising | Addresses potential misuse of the non-profit sector for financing of terrorism |
| 15 | Any other persons or professions that are designated by the Cambodia Financial Intelligence Unit to be governed under the scope of the present Law | Catch-all provision allowing scope expansion without legislative amendments |
What This Means in Practice
Being classified as a reporting entity under Article 4 triggers a series of legal obligations defined in other articles of the present Law, including:
- Customer Due Diligence (CDD): Identifying and verifying the identity of customers and beneficial owners before establishing a business relationship or conducting transactions.
- Record Keeping: Maintaining transaction records and customer identification data for the period specified by the present Law.
- Suspicious Transaction Reporting (STR): Filing reports with CAFIU when there are grounds to suspect that funds are the proceeds of crime or are related to terrorism financing.
- Internal Controls: Establishing internal policies, procedures, and training programs to prevent and detect money laundering and terrorism financing.
Why the Broad Scope Matters
Article 4 reflects Cambodia’s commitment to a comprehensive anti-money laundering framework. The inclusion of non-financial businesses and professions — agents and developers of immovable property, lawyers, dealers in precious metals, casinos, and NGOs — goes beyond a narrow focus on banking and addresses the channels through which illicit funds actually move.
For organizations operating in Cambodia, the practical implication is clear: compliance is not optional, and it is not limited to banks. Any entity falling within these fifteen categories needs to assess whether its current controls meet the requirements of the present Law.
How KMaker Supports Compliance Under Cambodia’s AML Law
KMaker’s platform is built to help reporting entities across all fifteen categories meet their obligations under Cambodia’s Law on Anti-Money Laundering and Combating the Financing of Terrorism:
- AML Transaction Monitoring — Real-time monitoring of transactions with machine learning detection to identify suspicious activity and support STR filing to CAFIU.
- Watchlists & PEPs Screening — Screen customers and counterparties against 100+ global watchlists and politically exposed persons databases to meet CDD requirements.
- Decision & Scoring Engine — Automated risk scoring and configurable business rules to assess and classify risk across all types of reporting entities.
Whether you are a bank, a micro finance institution, a developer of immovable property, or a casino — KMaker provides the tools to operationalize compliance under the present Law.
Understanding who is covered by Article 4 is the starting point. Building a compliance program that actually works is the next step.