IMF flags gaps in Cambodia casino ownership safeguards
The International Monetary Fund (IMF) has called for urgent reforms to Cambodia’s framework for preventing criminals from owning or controlling casinos, describing existing ownership safeguards and vetting procedures as deficient.
The assessment formed part of the IMF’s 2026 Article IV Consultation on Cambodia, which examined financial integrity risks across several sectors. The IMF said weaknesses in casino ownership controls should be addressed alongside broader gaps involving banks and payment institutions.
The findings place Cambodia’s casino licensing framework under renewed scrutiny as authorities prepare to strengthen oversight of the gaming sector and existing casino licences approach their expected renewal period in 2027.
Cambodia Casino Ownership Rules Face Closer Scrutiny
Under Cambodia’s Law on the Management of Commercial Gambling (LMCG), major shareholders holding at least 10% of a casino applicant and senior managers are required to demonstrate a good reputation and characteristics including honesty and integrity.
However, the IMF said the existing process conducted by the Commercial Gambling Management Commission of Cambodia (CGMC) does not extend sufficiently beyond reviewing criminal-record certificates submitted by applicants.
The IMF recommended strengthening the legal framework so that beneficial owners and directors, in addition to managers and shareholders already covered by existing requirements, are subject to robust fit-and-proper assessments.
It also called for the relevant authority to establish the lawful origin of funds before issuing a casino licence.
Source-of-funds checks also targeted
The IMF highlighted source-of-funds verification as another significant weakness in Cambodia's licensing framework.
It said authorities should investigate the business relationships and activities of companies and individuals connected to casino applicants when assessing beneficial ownership, management suitability and the legitimacy of funds.
Additional due diligence may be warranted where an applicant has links to other high-risk businesses or politically exposed persons, the IMF said, with information-sharing between regulators identified as an important component of the process.
The recommendation fits within the IMF's wider assessment of Cambodia's financial-integrity framework. In its overall Article IV assessment, the Fund said stronger cooperation among relevant agencies was necessary to address potential links between criminal activity and financial institutions and to strengthen licensing frameworks.
2027 licence renewals could provide reform window
The IMF pointed to the expected renewal of most existing casino licences around 2027 as an opportunity for Cambodia to apply upgraded requirements.
That could allow regulators to reassess existing operators against strengthened ownership, integrity and source-of-funds standards rather than limiting the reforms to new licence applications.
The CGMC has already been working on a new integrity and quality evaluation framework for casino licence renewals. In September, the regulator said the framework was intended to establish minimum suitability conditions for obtaining a casino licence and strengthen the country's commercial gambling sector.
The timing of the regulatory work also coincides with Cambodia's broader campaign against online scam operations. Authorities have taken action against casino locations alleged to have connections to such activities, while the government has been tightening controls around online betting and gaming operations.
Casino oversight linked to wider financial-integrity concerns
The IMF's casino recommendations form part of a wider concern about Cambodia's ability to prevent criminal proceeds and illicit activity from entering regulated financial and commercial sectors.
The Fund said authorities need to improve their understanding of how proceeds from scam activities and human trafficking are laundered and strengthen cooperation between agencies responsible for licensing and supervision.
Cambodia's existing anti-money laundering framework already places casinos within the country's reporting-entity regime. The Cambodia Financial Intelligence Unit lists specific customer-due-diligence requirements for casinos and other gambling institutions among its regulatory measures.
However, an earlier Financial Action Task Force Asia/Pacific Group follow-up assessment identified shortcomings in Cambodia's ability to ensure that criminals or their associates could be prevented from holding significant or controlling interests, beneficial ownership positions or management functions in casinos.
The IMF's latest assessment therefore adds further international scrutiny to an area that Cambodian regulators have already identified for reform.
Cambodia casino regulation enters a reform phase
For Cambodia's casino industry, the IMF recommendations point toward a regulatory approach that places greater emphasis on who ultimately owns and controls licensed gambling businesses, how their funds were obtained and whether those relationships create broader financial-integrity risks.
The expected 2027 licence-renewal cycle could become an important test of how the country translates those recommendations into operational requirements for existing casino operators.
The CGMC's planned integrity framework, combined with stronger inter-agency information sharing and ownership due diligence, could form part of that process as Cambodia seeks to reinforce oversight of its casino sector.
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