IMF Says Cambodia's Vetting of Casino Owners Is Deficient Ahead of 2027 Renewals

The International Monetary Fund's 2026 review of Cambodia finds that the casino regulator checks little more than applicants' criminal record certificates and that beneficial owners face no fit and proper test at all. With most casino licences due for renewal around 2027, it wants the gambling law amended first.

• The International Monetary Fund says both Cambodia's legal framework for keeping criminals from owning or controlling casinos and the actual vetting of applicants are "similarly deficient and should be rectified swiftly", in its 2026 Article IV staff report published on 28 September
• The Law on the Management of Commercial Gambling sets integrity requirements only for shareholders with 10% or more and senior managers, and the Commercial Gambling Management Commission of Cambodia (CGMC) in practice goes no further than reviewing criminal record certificates supplied by applicants, the IMF says
• It recommends amending the law so that beneficial owners and directors face a robust fit and proper test and the CGMC satisfies itself that an applicant's funds are lawful before licensing, and says the renewal of most licences around 2027 is "a good opportunity" to apply the upgraded rules
• The IMF ties the casino findings to scam proceeds, citing United Nations estimates that Mekong scam centres earn just under $40 billion a year, laundered typically through casinos, shell companies and other channels
• The report arrives as Cambodia's online gambling shutdown takes effect and the CGMC drafts a suitability test for casino licence renewals whose criteria it has not published

The IMF Puts Casinos Alongside Banks in Cambodia's Financial Integrity Problem

The IMF's Executive Board concluded its 2026 Article IV consultation with Cambodia on 22 September, without a meeting, and published the staff report, IMF Country Report No. 26/254, with a press release on 28 September. It projects growth slowing to 3.0% this year from 5.3% in 2025, and treats financial integrity as a macroeconomic risk in its own right, in a section where casinos sit alongside banks.

In the staff appraisal, the IMF says that "the absence of fit-and-proper requirements for beneficial owners or need for establishing a legitimate source of funds in the licensing of banks, payment institutions, and casinos is a significant vulnerability that should be addressed by the NBC and the Commercial Gambling Management Commission of Cambodia as a top priority". The NBC is the National Bank of Cambodia. The Executive Board's summary goes further on banks, saying the authorities "need to urgently identify and address potential links between criminal activity and banks and close significant gaps in the licensing frameworks".

The detail is in an annex on fraud, human trafficking and money laundering, prepared by the Fund's legal department. Its paragraph on casinos is short. "Both the legal framework for preventing criminals from owning or controlling casinos and actual vetting is similarly deficient and should be rectified swiftly," it says. The Law on the Management of Commercial Gambling (LMCG) asks only major shareholders, those with 10% or more of the shares, and senior managers to be of good reputation, character, honesty and integrity. In practice, the IMF says, the CGMC's assessment does not go beyond reviewing the criminal record certificates applicants submit. It found the same practice at the central bank, where such certificates "may not reflect whether the person is subject to any ongoing proceedings or investigations".

What the Fund Wants Changed

The annex recommends that the LMCG be amended so that beneficial owners and directors, as well as managers, are subject to a robust fit and proper test, and that the CGMC satisfies itself of the lawful origin of the funds before it issues a licence. The law requires every casino licence to be renewed every five years, and "most existing licenses are expected to be renewed around 2027, offering a good opportunity to review the licensees against upgraded requirements", the IMF says.

It also calls for regulators to share what they know. Every licensing authority should seek information from other regulators where an applicant's other businesses fall under their supervision, and licensing and supervision teams should exchange information so that fitness and propriety are checked on an ongoing basis. In bank licensing, it names casino operations as a high-risk line of business that should trigger further due diligence.

On supervision, the Ministry of Justice considers banks, payment institutions and casinos the sectors most exposed to the proceeds of fraud and human trafficking, yet the Cambodian Financial Intelligence Unit (CAFIU), the anti-money laundering supervisor, still sets priorities from the 2018 national risk assessment, is still developing entity-level risk models for casinos, and does not capture group affiliation, which the IMF calls "a significant gap".

Scam Money, Sanctions and Bank Failures Are the Backdrop

The IMF links all of this to the scam economy. It cites a United Nations Office on Drugs and Crime estimate that industrial-scale scam centres in the Mekong region generate just under $40 billion a year in profits, typically laundered through casinos, shell companies, virtual asset service providers, underground banking, payment processors and real estate. It recalls the October 2025 US and UK sanctions on the Prince Group, which is alleged to include a Cambodian-licensed bank, a group owning a licensed payment institution, and casinos, and a further US action in April 2026 against a Cambodian senator and two licensed banks. Prince Bank and Panda Commercial Bank went into liquidation in early 2026, and three more small banks followed in August, according to the report. Prince Group remains the focus of foreign action.

The authorities, the report says, acknowledge the scale of the problem. They cite raids on scam compounds, deportations, frozen accounts, the Law on Combating Online Scams adopted in April 2026 and an anti-scam strategy now being drafted. Whether the new law will also help pursue money laundering and recover assets, as the authorities expect, "remains to be seen", the IMF says.

The IMF Has Written the Renewal Test the CGMC Has Not Published

Cambodia's regulator began drafting a casino integrity and quality evaluation framework for licence renewals in early September, and Prime Minister Hun Manet has since said the country's more than 100 casinos are too many and ordered a licence review to reduce them. Neither has said what the test will contain. The IMF now has: beneficial ownership, directors, and the lawful source of funds. Those are the questions that matter when the concern is criminal control, and the 2027 renewal wave is the moment to ask them of every licensee at once. A renewal framework that weeds out shophouse casinos but does not ask who ultimately owns a casino and where its capital came from would cut the number of licences without addressing the vulnerability the IMF describes.

Shutting Down Online Gambling Treats the Channel, Not the Owners

The ban on online gambling from casino premises, which Hun Manet has said is permanent, closes one route by which licensed properties served scam and illegal operations. The IMF's report does not mention it. Its concern sits one level up: if the law cannot see past a 10% shareholder and the regulator relies on certificates provided by applicants, the same owners can run whatever the licence still permits. Enforcement since 2025 has revoked or suspended dozens of licences, but those actions came after scam links were found, not at the licensing stage. The Fund's point is that vetting should catch these owners before the police do.

The Cost Is Measured in Banks and Tourists, Not Just Reputation

The IMF puts the financial integrity problem in its macroeconomic forecast because it has had macroeconomic effects: bank liquidations, a small deposit run, enhanced due diligence by foreign correspondent banks and falling tourist arrivals. For a casino sector that depends on foreign visitors and on access to banking, that is the practical case for the reform. Licensees that can demonstrate clean ownership and lawful funds stand to benefit from a credible test; those that cannot are the reason it is needed.

Cambodia has spent a year closing casinos after the fact. The IMF is asking it to start checking owners before the licences are issued.