Insights

Virtual Assets after the 23 September 2026 Joint Statement — who needs a licence before serving Cambodia

On 23 September 2026, the Securities and Exchange Regulator of Cambodia (SERC) and the National Bank of Cambodia (NBC) issued a milestone Joint Statement defining the regulatory perimeter for Virtual Assets and Virtual Asset Service Providers (VASPs). It clarifies who falls within Cambodia's oversight framework, but is not itself an operating licence. Commercial banks require prior NBC authorisation before offering virtual asset services, while all other entities and platforms require a prior SERC licence. The framework applies to services operated from Cambodia or offered to persons and entities inside Cambodia, regardless of where a foreign platform is incorporated. Licensed operators become mandatory Reporting Entities to the Cambodia Financial Intelligence Unit (CAFIU). Virtual Assets remain non-legal tender without state guarantees. Pure network infrastructure providers without customer-facing activities remain outside the framework.