Obligations of Banks and Financial Institutions in Providing Customer Account Information and Account Freezing/Unfreezing

September 4, 2026

On August 10, 2026, the National Bank of Cambodia (“NBC”) issued Circular No. B37.026.006 on the obligations of Banks and Financial Institutions (“BFI”) to provide customer account information and to implement account freezing or unfreezing customer account.

The Circular aims to strengthen cooperation between BFIs and competent authorities while ensuring the proper handling of customer account information and account restrictions in accordance with applicable laws and regulations. Under the Circular, banking and financial institutions are required to:

• Direct compliance with competent authorities: The BFIs are required to directly review and comply with court orders or requests from competent authorities regarding customer account information and account freezing or unfreezing. The competent authorities are not required to obtain further confirmation from the NBC before taking action in accordance with such orders or requests. The NBC also clarified that it has no authority to interpret or provide further explanations regarding actions taken by competent authorities.
• Confidentiality obligations: The BFIs are bound by professional confidentiality obligations. Disclosure of customer information is permitted only to competent judicial authorities acting within the framework of criminal proceedings. It’s must also retain all documents and information relating to relevant orders or requests, their responses, and the information provided to competent authorities. Such records must be made available to the NBC upon request.

In this regard, the BFIs shall ensure to act swiftly and transparently in response to competent authority requests. By balancing confidentiality obligations with compliance requirements, the measure reinforces trust in the financial system.