Sector: Corporate M&A

On July 1, 2026, the Ministry of Economy and Finance issued Interministerial Prakas No. 450 introducing a legal framework to govern the importation of goods suspected of being produced by forced labor. It establishes procedures for investigation, verification, and enforcement, and sets out the responsibilities of importers and the competent authorities in ensuring compliance.

Per the Interministerial Prakas, the term “forced labor” refers to any work or service exacted from a person under the threat of a penalty and for which that person has not offered themself voluntarily, which is consistent with the definition under the Cambodian Labor Law.

Import prohibition

The Interministerial Prakas applies to all imported goods suspected of being produced, extracted, harvested, manufactured, processed, or assembled, in whole or in part, through the use of forced labor.

Goods found to be associated with forced labor at any stage of the supply chain are prohibited from being:

• Imported into Cambodia;
• Used or circulated within Cambodia; and
• Supplied or distributed to the Cambodian market.

Importers whose goods become subject to investigation are required to submit an explanation and supporting evidence within 10 working days from the date of receiving official notification of such. Supporting documentation may include:

• Proof of the origin of the goods and production location
• Details of the manufacturers and other entities in the supply chain
• Details of the production, extraction, harvesting, processing, assembly, or other relevant manufacturing activities
• Purchase agreements, payment records, ownership transfer documents, and other relevant commercial documents
• Compliance audit reports, due diligence assessments, or other evidence demonstrating that the goods are not associated with forced labor

Where imported goods are determined to be associated with forced labor, the goods will be prohibited as mentioned above. In addition, importers may be subject to further administrative measures, including:

• Suspension of import and export activities.
• Suspension of the issuance of certificates of origin.
• Other measures as may be imposed under applicable laws and regulations.

Importers are encouraged to review supplier contracts, compliance audit reports, and supply chain traceability mechanisms to ensure they can respond promptly to any investigation initiated by the competent authorities.

1. Payroll Ledgers: Mandatory Overhaul Now in Effect

On May 6, 2025, the Ministry of Labor and Vocational Training (“MLVT”) issued Prakas No. 111/25 on Payroll Ledgers, repealing prior regulations and establishing new mandatory requirements for all entities to maintain and manage payroll records in a standardized template, either in a ledger or computerized format.

The Prakas is part of the MLVT’s effort to integrate payroll data into the Labor Automated Centralized Management System and requires entities to upload monthly payroll data using the prescribed template by the 20^th of the following month. It entered into effect on its issuance date, but up to now, some entities have not yet complied with this obligation.

For further details on this Prakas, please refer to our previous client alert: Reminder on the MLVT’s Requirements on Computerized Payroll Systems

2. Upcoming Self-Declared Labor Inspection due June 30, 2026

As part of annual labor compliance, entities are required to complete self-declared labor inspections through the MLVT’s Self-Inspection Centralized Management System twice each year, with the first round due by June 30, 2026.

The process involves entities assessing and rectifying compliance gaps before a physical inspection takes place. If an entity declares a point as non-compliant, the MLVT is automatically notified of the violation and the related penalty. In such cases, the MLVT will issue a corrective order requiring the entities to rectify the non-compliance before imposing the actual penalty. It is therefore essential that all self-declarations are complete and accurate.

While we have not yet seen strong enforcement of the above compliance matters at this stage, the obligations are already in force. Failure to comply may result in administrative fines and enforcement action. Entities are therefore encouraged to take prompt steps to ensure compliance.

If you have any questions or need any assistance with these requirements, please do not hesitate to contact us.

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The information included here is for information purposes only and does not represent legal, tax, or other advice.

On April 6, 2026, the Royal Government of Cambodia promulgated a Royal Decree announcing the Law on Combating Online Scams. As digital technology becomes increasingly integrated into daily life, criminal activities have also evolved. Online scams conducted through social media, the banking system, and digital platforms pose serious risks to individuals, businesses, and national security. This law establishes a structured legal framework to address these risks.

Purpose and scope

The law aims to strengthen criminal measures against technology-enabled scams, safeguard the public, and promote both national and international cooperation. Its scope is broad. It applies not only to offenses committed in Cambodia but also to those involving Cambodian nationals abroad, as well as those committed against Cambodian victims, and crimes connected to Cambodia’s financial system. This ensures that offenders cannot evade liability by operating across borders.

The law describes various types of online scam offenses and their penalties, as described below.

Technology-enabled scams

The law defines technology-enabled scams as fraudulent acts carried out through technological systems to obtain funds, property, services, or legal obligations.

Offenders are subject to 2 to 5 years of imprisonment and fines ranging from KHR200 million to KHR500 million. Where the offense involves an organized group or multiple victims, penalties increase to 5 to 10 years of imprisonment and fines ranging from KHR500 million to KHR1 billion.

Organizing or leading scam centers

Anyone who organizes or leads a premises established as a technology-enabled scam center, whereby multiple persons operate individually or in groups or networks for the purpose of committing technology-enabled scams, is subject to 5 to 10 years of imprisonment and a fine ranging from KHR500 million to KHR1 billion.

The same penalties apply to anyone who organizes or leads multiple premises interconnected as a network for such purposes, even without a centralized structure.

Where the offense is committed with aggravating circumstances, including violence, unlawful detention, or any form of exploitation, the offender will be subject to 10 to 20 years of imprisonment and a fine of from KHR1 billion to KHR2 billion.

Where the offense results in the death of one or more persons, the offender will be subject to a sentence of 15 years to life imprisonment

Recruiting or training for scam activities

Anyone who recruits or trains others to participate in technology-enabled scams will be subject to 2 to 5 years of imprisonment and a fine ranging from KHR200 million to KHR500 million.

Where the offense involves aggravating circumstances such as violence, torture, cruelty, involving abduction, unlawful detention or restraint, causing death, or where the offender knowingly recruits victims of trafficking, the penalty increases to 5 to 10 years of imprisonment and a fine of from KHR500 million to KHR1 billion.

Misuse of personal identification documents

The unlawful collection or use of identity cards, passports, or other personal information documents for the purpose of facilitating online scams is punishable by 1 to 3 years of imprisonment and a fine ranging from KHR100 million to KHR300 million.

Where committed by an organized group, the penalty increases to 3 to 5 years of imprisonment and a fine of from KHR300 million to KHR500 million.

Money laundering related to online scams

Where a person cannot prove the lawful origin of assets linked to online scams, such conduct is treated as money laundering. Penalties apply in accordance with anti-money laundering laws, in addition to sanctions under this framework.

Additional penalties and liability

In addition to imprisonment and fines, the court may impose additional measures, including confiscation of assets, seizure of property used in the commission of offenses, and closure of bank accounts or online platforms involved in scams.

Legal entities may also be held criminally liable. Such entities will be subject to fines ranging from KHR1 billion to KHR30 billion or an amount equivalent to the value of the proceeds of the offense, along with additional sanctions.

The strong punitive measures, including significant financial penalties, ensures serious consequences for offenders, removing the financial incentives behind online scams to make enforcement more effective.

On March 9, 2026, Cambodia’s Ministry of Interior and Ministry of Public Works and Transport issued Inter-Ministerial Circular No. 010 to clarify the documents that Cambodian citizens can use to verify their identity when requesting public services in the public works and transport sector. The circular aims to address the practical challenges citizens encounter when trying to access services at the local administrative level and to facilitate faster and more efficient access to public services through the Single Window Service Units.

Cambodian citizens requesting services in the public works and transport sector must attach one of the following identification documents when submitting an application:

• A copy of their Cambodian national ID card certified by a competent authority
• A copy of their Cambodian national ID card signed and thumbprinted by the applicant in the presence of the service officer, together with their original national ID card for verification
• An original letter attesting to their personal identity or a letter confirming the accuracy of their personal identity data, both issued by the General Department of Identification

In addition to the identification documents listed above, applicants must continue to comply with other conditions and documentation requirements applicable to each specific public service, in accordance with the relevant laws and regulations in force.