Big picture first: Cambodia now officially recognises crypto‑asset business, but the National Bank of Cambodia (NBC) draws a bright red line between “Group 1” tokens (stablecoins & tokenised real‑world assets) and “Group 2” crypto such as Bitcoin. Commercial banks may not trade or hold Group 2 for their own account, yet NBC has opened a brand‑new licence class—Crypto‑Asset Service Provider (CASP)—through Prakas No. B7‑024‑735 (26 Dec 2024).
So, a pure “Bitcoin bank” in the traditional sense (deposit‑taking with BTC on balance sheet) is still off‑limits. But a fully‑licensed, Bitcoin‑focused CASP that partners with a Cambodian bank for fiat rails is attainable—and that’s where the opportunity lies. Let’s map the route!
1. Choose the Winning Structure
| Route | What you can legally do with Bitcoin | Paid‑up capital (indicative*) | Supervisors | Pros | Cons |
| A. Commercial Bank | Hold or trade BTC? ❌ (Group 2 ban), but may offer custodial/transfer services once separate guidelines are out. | US $ 75 m | NBC | Full banking franchise | No BTC balance‑sheet exposure |
| B. Payment‑Service Institution (PSI) | Process BTC→fiat when partnered with a CASP; no proprietary BTC. | ≈ US $ 5 m | NBC | Faster licence than a bank; taps Bakong rails | Cannot call itself a “bank” |
| **C. Crypto‑Asset Service Provider (CASP) | Exchange, transfer, custody of BTC for clients (no lending, no rehypothecation). | TBA – draft hints at ≥ US $ 10‑15 m | NBC (primary) + SERC (if tokens = securities) | Purpose‑built “Bitcoin bank” function | Licence handbook expected H2 2025 |
| D. Regulatory Sandbox Pilot | Test limited BTC services with real users under NBC/SERC oversight. | Flexible | NBC + SERC | Lower entry bar, proof of concept | 12‑month cap; must exit to full licence |
*NBC has not yet published minimum capital for CASPs; figures above reflect market consultations and draft notes.
2. Reality‑Check on the Rules (2025 edition)
| Topic | NBC position | What it means for you |
| Group 2 assets (Bitcoin, ETH, etc.) | Banks cannot issue, hold, or transact on own account. CASPs may handle them for clients under strict segregation. | Make your entity a CASP (or PSI partnering with a CASP). |
| Marketing | CASPs may market services, not individual coins. | Focus on education & platform features, not “Buy BTC now!” ads. |
| Lending / staking | Prohibited for CASPs. | Keep client BTC 1‑to‑1 in segregated wallets. |
| Telecom blocking | Unlicensed crypto websites/exchanges are blocked. | Secure the licence before you launch your .kh app or site. |
| AML / Travel Rule | Same as banks: risk‑based KYC, STRs to CAFIU, FATF Travel‑Rule data sharing. | Budget for a solid RegTech stack from Day 1. |
| Bakong integration | Strongly encouraged for retail on/off‑ramp. | Being a Bakong participant gives instant reach to 10 M wallets. |
3. Your 9‑Step Launch Road‑map 🛤️
| Month | Milestone | Key actions | Success tips |
| 0‑1 | Concept & Feasibility | Decide on CASP vs PSI + CASP; refine the customer promise (e.g., “Cambodia’s safest Bitcoin vault”). | Show NBC you’re solving a real need (e.g., SME remittances, diaspora savings). |
| 1‑2 | Name Reservation & Incorporation | Form a Public Limited Company (Plc.)—100 % foreign ownership is fine; min. statutory capital only ~US$1 k but commit full paid‑up later. | Draft shareholders’ agreement that permits future tokenisation of equity. |
| 2‑4 | Sandbox Entry (optional) | Submit pilot plan to NBC FinTech Office; typical approval within 60 days. | Limit to 2 000 beta users; emphasise consumer protection. |
| 3‑6 | Licence Application | Full dossier: AML/KYC policy, cold‑storage architecture, SOC‑2/ISO 27001 roadmap, board CVs (fit & proper). | Hire a Cambodian independent director with banking/IT security chops. |
| 6‑8 | Capital Injection & Tech Build | Wire paid‑up capital into an escrow a/c at a partner bank; deploy multi‑sig wallets with HSM; integrate Chainalysis/Scorechain. | Keep hot‑wallet float ≤ 2 % of client assets. |
| 8 | NBC On‑site Due Diligence | Demonstrate segregation of client vs treasury wallets; walk through incident‑response playbook. | Run a mock hack drill beforehand! |
| 9 | Final Licence Issued | Pay licence fee (expected KHR 200 M ≈ US$50 k). | Celebrate – quietly; NBC dislikes hype at this stage. |
| 9‑10 | Public Beta & Bakong Go‑Live | Offer Riel & USD rails via Bakong; limit daily BTC purchase to US$5 k until systems proven. | Launch bilingual in‑app tutorials on tax & self‑custody. |
| 12 | Full Commercial Launch | Roll out merchant API, OTC desk for > US$50 k orders, and a proof‑of‑reserve dashboard. | Quarterly auditor‑signed PoR wins trust fast. |
Total time: 10‑12 months if sandbox route skipped; 12‑15 months with sandbox.
4. Budget Snapshot 💰
5. Five Golden Success Hacks 🌟
Final Word—Dare Greatly, but Play by the Rules! 🎉
Cambodia’s 2025 framework doesn’t let you warehouse Bitcoin on a bank balance sheet—but it does let visionary entrepreneurs like you stand up a fully compliant Bitcoin service institution that can custody, transfer, and exchange BTC for a fast‑growing, tech‑savvy population. Nail the governance, wow the regulator with security & transparency, and you’ll pioneer Cambodia’s next financial frontier—all while keeping the spirit of Satoshi alive.
Onward to building the Kingdom’s first Bitcoin powerhouse—let’s bank the unbanked, one sat at a time! 🚀🇰🇭