Cambodia: IMF calls for tighter controls before issuing casino licences

The IMF says Cambodia’s current legal framework is not strong enough to stop criminals from owning or controlling casinos, and it wants the vetting process tightened fast. For high-risk operators and their payment providers, the point is simple: if the licensing gate is weak, the compliance burden does not disappear — it moves downstream.

1. The conclusion appears in the IMF’s press release and staff report for the 2026 Article IV Consultation, both based on a recent national assessment. The Fund said Cambodia’s casino regulation has several structural gaps, starting with who is actually screened before a licence is granted.
2. Under Cambodia’s Law on Commercial Gambling Management (LMCG), the “good reputation, honesty and integrity” test applies only to two groups: major shareholders holding 10% or more of the shares, and senior managers of the applicant. The IMF said that leaves out other people who can still exercise real control over the business.
3. The Fund also criticised the Commercial Gambling Management Commission of Cambodia (CGMC), the regulator overseeing the sector. According to the report, the commission only checks the criminal record certificates submitted by applicants; it does not carry out a deeper assessment.
4. The IMF wants the LMCG amended so that beneficial owners, directors and managers all face proper fit-and-proper testing. It also said the CGMC should verify the lawful source of funds before issuing a licence.
5. Timing matters here: the IMF said most existing licences will be renewed around 2027, which would give Cambodia a chance to re-screen licence holders under updated requirements.

The casino review sits inside a broader look at other high-risk sectors, including banks and payment institutions. The IMF said regulators across those industries should share information, including between licensing and supervisory teams, so they can map ownership links, spot issues earlier, and keep operators fit on an ongoing basis. It also said authorities should examine links to related companies and individuals, with a deeper review where the business is high-risk or connected to a politically exposed person.

The criticism does not stop at casinos. The IMF said Cambodia’s current requirements for banks and payment service providers are also insufficient, because they do not guarantee that new entrants are free of criminal links.