The National Bank of Cambodia has published a first set of digital asset rules that apply to banks and payment service providers. Banks can have exposure to tokenized assets and qualifying stablecoins, but no first party exposure to cryptocurrencies. Multiple Cambodian news outlets have stated that a ban on cryptocurrencies persists. Our interpretation of the rules is more permissive – that banks can provide cryptocurrency services to clients.
Cambodia’s central bank rules distinguished between banks acting for their own purposes, versus on behalf of a client – as a crypto asset service provider (CASP). In both cases, they require central bank approval. For direct bank exposures, the institutions are restricted to tokenization and stablecoins. However, the clause relating to client services does not mention the same limitation.
There is an additional clause explicitly banning bank engagement with cryptocurrencies, but that is prefaced as relating to “their own crypto-assets”. Hence, the consistency between the two clauses reinforces our conclusion that approved banks may be allowed to provide cryptocurrency services to clients, including custody, on and off ramping, and trading.
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