MLV LAW GROUP

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Securities Regulation, FinTech Sandbox & Digital Assets (SERC)TRANSACTIONAL

Key licensing requirements for a DASP include:

• Incorporation as a company in Cambodia and completion of commercial and tax registration.

• Successful testing of the IT system, business model, products or services in the SERC securities-sector regulatory sandbox.

• Minimum capital of KHR 40,000,000,000 (approximately USD 10 million) for the principal trading-platform and related activities, or KHR 4,000,000,000 (approximately USD 1 million) for certain advisory or limited activities (exact thresholds as specified in the Prakas).

• Robust corporate governance, fit-and-proper assessment of controllers, directors and key officers, and appointment of a licensed Digital Asset Agent where required.

• Comprehensive AML/CFT programmer, including customer due diligence, Travel Rule compliance, and MLRO function.

• Operational resilience, cybersecurity, custody and client-asset segregation arrangements.

Initial license validity is two years; renewal is for three years and must be applied for at least 60 days before expiry. We provide end-to-end support from sandbox entry through full license application, governance and AML framework design, and post-license compliance.