International Monetary Fund Criticizes Cambodia’s Casino Ownership and Vetting Framework as Deficient

As reported by Inside Asian Gaming, the International Monetary Fund has described Cambodia’s legal framework for preventing criminals from owning or controlling casinos and its vetting processes as deficient. In its 2026 Article IV Consultation press release and staff report the IMF called for urgent attention to these gaps in the casino sector.

The Law on the Management of Commercial Gambling only requires major shareholders holding 10% or more and senior managers to meet standards of good reputation, characteristics, honesty and integrity. The Commercial Gambling Management Commission of Cambodia limits its assessment to reviewing certificates of criminal records submitted by applicants.

Core IMF Recommendations

The IMF recommended amending the Law on the Management of Commercial Gambling to subject beneficial owners and directors to robust fit and proper tests. It also called for the Commission to verify the lawful origin of funds before issuing any license. Most existing licenses are expected to be renewed around 2027 offering a good opportunity to review the licensees against upgraded requirements the IMF said.

These recommendations extend to information sharing across regulators of high-risk sectors that also include banks and payment institutions. The IMF stated that when conducting fit and proper tests for beneficial owners, directors and senior managers of an applicant and assessing the legitimacy of the source of funds the relevant authority should investigate the business linkages of companies and individuals involved in the applicant. It added that when an applicant’s other business is considered high-risk or is associated with a politically exposed person further due diligence may be needed including through information exchange between regulators.

Context of Ongoing Scam Enforcement

Cambodia has intensified efforts against scam centers that have used casino licenses as cover. In early September, Cambodia’s anti-scam agency released details of action it has taken against suspect casino locations, revealing it has annulled the licences of 18 casinos nationwide and suspended those of nine more, pending further investigation. Cambodia then hosted the International Conference on Combating Online Scams where 28 nations and seven international organizations signed the Phnom Penh Declaration outlining 11 key commitments to dismantle related criminal networks.

The IMF findings underscore specific limitations in current licensing rules that have allowed such overlaps to persist. Reforms must address these gaps directly before the 2027 renewal cycle to strengthen oversight without disrupting compliant operators.

Reporting: Inside Asian Gaming

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