Cambodia has gradually moved towards freeing itself from the grey list of high-risk countries for money laundering after the Kingdom was listed for three consecutive years from 2020-2022.

The potential for removal from the list comes through the work of the Financial Action Task Force (FATF) – an intergovernmental organisation tasked with developing policies to combat international money laundering and the funding of terrorism – according to Pech Pisey, executive director of Transparency International Cambodia (TI Cambodia).

“The positive progress is the result of introducing legal principles, creating a general department that is leading the fight against money laundering and the establishment of new international and regional cooperation combating money laundering.

“Recently there was the establishment of an inter-ministerial committee to combat money laundering led by the Ministry of Justice, and the Anti-Corruption Unit [ACU] has recently provided training on investigations to the tax general department,” he said.

According to Pisey, despite the positive progress, Cambodia has not yet fully implemented some of the recommendations of the FATF, which is why Cambodia is still on the grey list.

“Although we have legal principles, the implementation of the law is still limited as the investigations, arrests and punishment of suspects is still weak. Another weakness is the sharing of secret information related to these crimes with other countries. Generally, we need international cooperation and our Cambodian officials’ capacity is still limited,” he said.

Pisey urged the government to speed up its efforts to take Cambodia off the grey list for the 2023 assessment, because otherwise it could affect investor confidence in Cambodia.

“High risk areas for money laundering include gambling, casinos, real estate and shadow investments which are not properly registered,” he said.

Pisey made the remarks at the same time that the representatives of the International Monetary Fund (IMF) were sharing their experiences with Cambodian customs officials on investigating techniques, money laundering and terrorist financing at a joint workshop between the General Department of Customs and Excise of Cambodia (GDCE) and the IMF under the financial support of the Japanese government on October 24-28.

Stephen Cox, the IMF’s adviser to customs in Cambodia, and Tom Hansen, the IMF’s adviser on anti-money laundering and the countering of financing for terrorism, spoke to the GDCE on some important topics such as investigating techniques, financial investigation plans and identifying criminal enterprises pretending to be legitimate businesses.

GDCE director-general Kun Nhem emphasised that combating money laundering is an activity that the Cambodian government is highly committed to.

Cambodia became a member of the Asia/Pacific Group on Money Laundering (APG) in 2004.

Through this group, Cambodia must report its anti-money laundering and anti-terrorism financing obligations on a regular basis in accordance with the latest issues and measures set by the APG and the FAFT, he said.

He added Cambodia has had a draft law on anti-money laundering and financing of terrorism since 2020, but their ranking had not significantly improved.

Justice minister Koeut Rith – who is also deputy chairman of the National Committee to Combat Money Laundering and the Financing of Terrorism and Proliferation of Weapons of Mass Destruction – also mentioned that clear working procedures at relevant ministries and institutions is key to ensuring the effectiveness and sustainability of anti-money laundering efforts in Cambodia, both now and in the long term.

Article 1 of the law on anti-money laundering and financing of terrorism promulgated in June 2020 states that the law “aims to ensure the prevention of money laundering and financing of terrorism by setting measures to control, prevent, suppress and eliminate them”.

In 2019, Cambodia confiscated more than $10 million in cash illegally imported by foreigners. At that time, customs officials at Phnom Penh International Airport arrested three Chinese nationals who were importing $900,000 in cash in their luggage without any clear source, which came shortly after the arrest of two Koreans with more than $2 million in cash at Siem Reap International Airport on July 7, 2019.