Cambodia's National Assembly Passes the Anti-Technology Fraud Law — Life Sentences Now on the Books, but Operator Accountability Remains Elusive.

The legislation was drafted under direct supervision of the Ministry of Interior with input from the National Police, the General Department of Immigration, and the Anti-Money Laundering Unit at the National Bank of Cambodia. UK and US diplomatic pressure was a significant accelerant — the U.S. Treasury's October 2024 OFAC designation of Senator Kok An and 28 linked entities (which froze roughly US$700 million in cryptocurrency tied to the Chen Zhi network) had forced the Cambodian government into a public posture that demanded a codified legal response. The European External Action Service also raised the matter in two ASEAN dialogues during 2025.

King Norodom Sihamoni is expected to grant Royal Assent within two weeks, after which the law will be published in the Royal Gazette and take force. The Commercial Gambling Management Commission has already begun internal redrafting of its licensing conditions to align with the new criminal regime, and the National Bank of Cambodia will issue updated AML guidance for licensed casino operators within 60 days.

The accountability gap that observers continue to flag is that arrests under the existing enforcement regime have been concentrated at compound-worker level. Over 30,000 deportations have been processed since June 2025, and more than 1,100 mostly-foreign nationals were detained in raids between April 1 and April 6 alone, with thousands of phones and hundreds of computers seized. But the operators, license holders, and political networks behind those compounds have not faced criminal action. Amnesty International's April 2026 report — the most-cited independent assessment to date — noted that the new law's senior-tier penalties (life imprisonment, US$250,000 fines) exist on paper but have no Cambodian-side prosecutorial precedent. The OFAC designation remains the only public-record action against a senior figure.

For surveillance and compliance professionals, the operational read is that the licensed Cambodian casino segment is effectively unbankable through most U.S. and EU correspondent institutions. Enhanced due diligence will be the floor, not the ceiling, even for properties with no scam-compound association.

The 91 casino licenses revoked over the prior nine months are concentrated in Sihanoukville (54 properties), Poipet on the Thai border (22), and Bavet on the Vietnamese border (15). Most operated under the compound model — fenced complexes mixing online-scam call centres with licensed gaming tables — and most have already been physically dismantled or repurposed. Cross-border KYC sharing arrangements with China, Vietnam and Thailand are now operational and being expanded.

NagaCorp's compliance posture sits entirely outside the revoked properties. The HKEX-listed operator's FY2025 results (filed March 12) showed group revenue at US$709.7 million (+26.2%) and net profit at US$309.9 million versus US$109.6 million a year prior. The Q1 2026 voluntary trading update, expected April 8, will be the first post-law-passage signal of whether the new regime is constraining or supporting the legitimate segment. Goldman Sachs upgraded NagaCorp last week citing the broader Cambodia tourism recovery as a tailwind.