Cambodia – CM P

2025, Cross-border, Update

New BRP Country Manual Products

Cambodia

BRP SA - Cambodia CM P
BRP SA – Cambodia CM P

BRP has updated

its Country Manual Products

for Cambodia

SOURCE OF CHANGESANSWERS
Law/Regulation  No
New Position of the Authorities  No
Evolution of Expert’s interpretation  Yes

Definitions & Concepts, Regulatory Overview and Behaviour Template

The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date.

Material changes

In alignment with the Country Manual Private Banking (CM PB), the provision of macroeconomic information/reports, investment research and financial analysis documents/reports and generic/personalised recommendation lists is now only permitted on an occasional basis onshore in Cambodia (at target).

With regard to execution only services, in line with the CM PB, it is highlighted that any provision of such services by foreign (unlicensed) service providers onshore in Cambodia (at target) triggers local licensing requirements. It is therefore only permitted to accept unsolicited client orders on an occasional basis and if they are passed to the service provider’s country of establishment for execution. Accordingly, the Country Manual Products Behaviour Template (CM P BT) now provides the answer “Grey zone/YES)”.

Please note that activities in Cambodia should only be performed on an occasional basis in order to avoid a lasting presence (permanent establishment). The CM P BT therefore provides the answer “Grey zone/YES” in the relevant onshore scenarios.

In order to better reflect the existing regulatory framework, the active distribution of foreign (unregistered) Securities and Funds (both registered and not registered) on a cross-border basis is now only possible if conducted on a one-to-one basis in/into Cambodia (in order to act outside the scope of “commercial activities”).

Non-material changes

Some comments and content have been slightly reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately. 

For more information, please contact us: info@brpsa.com

Geneva, January 10th, 2025