Cambodia: The New Licensing Regime Explicitly Excludes the Asset a BATM Actually Trades

No crypto ATM operates anywhere in Cambodia today, and a new December 2024 banking regulation splits crypto into two groups — banks may handle tokenised securities and stablecoins, but Bitcoin and Ethereum specifically are barred from bank balance sheets entirely.

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There is no confirmed crypto ATM operating anywhere in Cambodia today, and independent travel-currency guides state this directly: "no, there are no Bitcoin ATMs in Cambodia," a position CoinATMRadar's own country page corroborates.^1,2 Cambodia's regulatory history explains why cleanly: a 2018 joint statement from the National Bank of Cambodia (NBC), the Securities and Exchange Regulator of Cambodia (SERC), and national police declared that propagating, buying, selling, trading, or settling cryptocurrencies without a licence was illegal, and no such licence was actually issued for years afterward — a ban in practice even though not in name.^3,4 That changed on 26 December 2024, when the NBC issued Prakas B7-024-735, a regulation permitting commercial banks and payment institutions to offer limited crypto-asset services — but with a distinction that matters enormously for this specific business: the regulation splits crypto into Group 1 (tokenised securities and fully-backed stablecoins, which banks may handle with NBC approval) and Group 2 (everything else, explicitly including Bitcoin and Ethereum), and banks are barred from holding Group 2 assets on their own balance sheets.^5,6 Since a cash-to-crypto ATM overwhelmingly trades Bitcoin, this is not a peripheral technicality. Sources do diverge on exactly how far the Group 2 restriction reaches, and the distinction matters: regional law firm Rajah & Tann reads the Prakas as barring banks from carrying out any services or activities directly or indirectly related to Group 2 assets, while other commentary suggests banks may, with NBC approval, provide client-facing services (exchange on-ramping, custody, remittance conversion) even for assets they cannot hold themselves. Whether a Cambodian bank could lawfully service a Bitcoin ATM operator's account is therefore an open question rather than a settled no, and it should be put to a Cambodian lawyer directly.^6,7 As in most markets on our legislation map, General Bytes as a hardware and software vendor is not itself performing a licensable activity; it is the in-country operator of the machines who bears whatever regulatory status applies. For GENERAL BYTES, Cambodia is not simply an early-stage or ambiguous market — it is a market whose current licensed banking framework structurally excludes the asset a BATM is built to trade.

Last updated: August 2026

Regulatory Framework and Its Evolution

Cambodia's starting point was unusually blunt: the 2018 joint statement did not merely warn about risk, it declared unlicensed crypto activity of any kind illegal, explicitly naming several local token schemes as examples of what to avoid, and stating any violator "shall be penalized in accordance with applicable laws."^4,8 No licence was actually made available under this regime for years, meaning the practical effect was a comprehensive prohibition regardless of the technical legal framing.⁹ A narrow exception opened in January 2024 when SERC approved Royal Group Exchange (RGX), backed by a major Cambodian conglomerate, to operate under its FinTech Regulatory Sandbox — the country's first and, for some time, only licensed digital-asset exchange.¹⁰

The NBC's Prakas B7-024-735 (effective early 2025) represents the first systematic banking-sector framework, but it arrived alongside, not instead of, continued restriction: in November 2024, just before the Prakas was issued, Cambodia's Telecommunications Regulator blocked access to 16 offshore exchanges, including Binance, Coinbase, and OKX, cutting off roughly 200,000 Cambodian Binance users in one action.^11,12 SERC has continued building out a more comprehensive regime since: its Financial Services Authority Council approved a draft proclamation on digital asset businesses in December 2025, spanning nine chapters and 63 clauses covering licensing, renewal, and obligations for digital-asset service providers generally — a genuinely comprehensive VASP-style framework, still pending final adoption.

Getting Licensed: Two Platforms Total, and Bitcoin Is Excluded From the Main One

As of 2025-2026, only two channels are consistently reported as authorised to convert crypto to Cambodian riel or US dollars, though sources name them differently: Royal Group Exchange (RGX) under the SERC sandbox appears in every account, while the second is described variously as Bakong-based channels (Cambodia's state-backed digital payment system) or as Cambodian Network Exchange (CNX). The exact identity of the second licensee should be verified with the NBC rather than assumed.^13,7 Commercial banks may offer Group 1 services (tokenised securities, fully-backed stablecoins) only with prior NBC approval, subject to strict limits (Group 1a exposure capped at 5% of Common Equity Tier 1 capital, Group 1b at 3%), and are required to file quarterly exposure reports.⁵ Group 2 — Bitcoin, Ethereum, and all other unbacked cryptocurrencies — cannot be held on a bank's own balance sheet, and Cambodian banks including major players like ABA and Canadia Bank are reported to auto-flag and freeze transactions linked to crypto exchanges generally, which suggests the practical posture is stricter than the letter of the rule requires.^6,14

The pending SERC digital-asset-business proclamation may eventually create a broader licensing path outside the banking-specific Prakas, but as of this writing it remains in draft form with no confirmed effective date. As with the rest of our legislation map, any authorisation that does eventually apply would sit with the in-country operator of the machines, not with General Bytes as hardware and software vendor.

AML and KYC

Cambodia's restrictive posture is directly tied to serious, high-profile money-laundering and fraud concerns rather than abstract caution. The US Treasury's Office of Foreign Assets Control sanctioned Cambodian entities including the Prince Group and businessman Ly Yong Phat in late 2024 over forced-labour and online scam-centre operations that used crypto to launder proceeds, and in January 2026, Prince Group founder Chen Zhi was arrested and extradited to China on cryptocurrency fraud and human-trafficking charges, with the NBC subsequently ordering the liquidation of the affiliated Prince Bank.^15,16 This context — Cambodia's international reputation directly threatened by crypto-linked organised crime — explains why the NBC has prioritised tight control over rapid market opening, and why any operator here should expect AML scrutiny to be genuinely severe rather than procedural.

Banking

Banking is the central obstacle in Cambodia specifically because of the Group 1/Group 2 split: no Cambodian bank may hold Bitcoin on its own balance sheet, and whether a bank may lawfully service a Bitcoin-focused business as a client is exactly the point on which sources disagree (see above). Either way, an operator cannot assume ordinary banking will be available.⁶ Cambodian banks are also reported to proactively freeze accounts merely suspected of crypto-exchange association, independent of formal Group 1/Group 2 status, reflecting a risk-averse posture across the sector generally.

The Next 24 Months: Watch the SERC Proclamation, Not the NBC Banking Rules

The NBC's banking-specific framework is unlikely to open meaningfully to Bitcoin given how deliberately Group 2 assets were excluded, and the Prince Group scandal occurring within the same window makes near-term loosening even less likely.^15,16 The more relevant development to track is SERC's broader digital-asset-business proclamation, approved in draft in December 2025 with nine chapters and 63 clauses — if finalised, this could create a licensing path for digital-asset service providers outside the banking system entirely, which is the more plausible route (if any) toward a legally operable Cambodian crypto ATM.¹³

For GENERAL BYTES, the honest recommendation for Cambodia right now is to treat it as effectively closed for the core BATM product, not merely underdeveloped. Three things point the same way: the only systematic legal framework that exists places Bitcoin in the restricted tier where banks cannot hold it on their own books, no crypto ATM has ever operated in the country despite years of regional interest, and the live AML and fraud crisis makes near-term loosening unlikely. The one genuinely open question is how far the Group 2 restriction reaches for client-facing bank services, which a Cambodian lawyer could settle cheaply. The SERC digital-asset proclamation is worth monitoring as the more plausible path forward, but there is nothing to act on in Cambodia today.

Sources and references

1. Confirmation of no Bitcoin ATMs in Cambodia — atmfeesaver.com
2. CoinATMRadar reporting no known Bitcoin ATM in Cambodia — coinatmradar.com
3. 2018 joint NBC/SERC/police statement declaring unlicensed crypto activity illegal — nbc.gov.kh
4. No licence historically issued despite the stated licensing pathway — acc.com
5. Prakas B7-024-735 (26 Dec 2024), Group 1a/1b capital exposure limits, quarterly reporting — dfdl.com
6. Rajah & Tann Asia legal analysis: banks barred from services related to Group 2 cryptoassets — rajahtannasia.com
7. Only RGX and Bakong-based channels authorised for crypto-fiat conversion — tokencustom.com
8. 2018 statement explicitly naming prohibited token schemes — freemanlaw.com
9. Historical absence of any issued licence under the 2018 framework — acc.com
10. Royal Group Exchange as first SERC sandbox-licensed exchange, January 2024 — erickimphotography.com
11. TRC blocking 16 offshore exchanges, November 2024 — glavx.org
12. ~200,000 Cambodian Binance users affected by the block — glavx.org
13. SERC draft digital-asset-business proclamation approved December 2025 (9 chapters, 63 clauses) — coingeek.com
14. Cambodian banks (ABA, Canadia) auto-flagging/freezing crypto-linked transactions — tokencustom.com
15. US Treasury OFAC sanctions on Prince Group/Ly Yong Phat, late 2024 — hashultra.com
16. Chen Zhi arrest/extradition and Prince Bank liquidation, January 2026 — en.wikipedia.org

Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. Cambodia's current banking regulation explicitly excludes Bitcoin and other unbacked cryptocurrencies from the licensed banking system; always consult specialised local legal counsel and confirm the current NBC and SERC position before considering market entry.