• National Bank of Cambodia (NBC) – Prakas on Transactions Related to Crypto assets (effective late 2024) classifies crypto assets into Group 1 (tokenized traditional assets and adequately backed stablecoins) and Group 2 (unbacked crypto-currencies). Commercial banks and payment institutions may offer Group 1 services with prior NBC approval; Group 2 remains heavily restricted. Crypto-asset service providers offering exchange, transfer or custody services require NBC licensing for the payment-related perimeter.

• SERC – investment-side digital-asset activities are governed by Prakas 093 as described above; sandbox participation is the gateway to a full DASP license.

We advise clients across the spectrum of Web3 and digital-asset activities: token issuance and distribution (subject to securities characterization), exchange and OTC desk structuring, custody and wallet solutions, decentralized-finance (DeFi) interfaces that touch Cambodian users or assets, NFT platforms where they engage securities or consumer-protection rules, and the structuring of real-world-asset (RWA) tokenization projects. Our work includes regulatory perimeter analysis, dual NBC/SERC licensing strategy, AML/CFT programmer design calibrated to FATF standards, white-paper and disclosure review, smart-contract legal overlays, and ongoing compliance monitoring as the rules continue to develop. Given the rapid evolution of both the technology and the regulatory framework, we emphasize cautious, documented structuring and early engagement with the competent regulators.