In one energizing sweep: Cambodia lets 100 % foreign‑owned banks in, demands a US $75 million paid‑in capital for a full commercial bank, and runs a clear, two‑stage licensing path (approval‑in‑principle ➜ final license) that can be completed in 9‑15 months if your paperwork sings. You incorporate locally, park the capital, prove your team is “fit & proper,” pay about US $39 k in NBC fees, register with tax and labor authorities, build robust AML/CFT and governance systems, then open the doors—just in time to ride Phnom Penh’s digital‑payment boom and an upcoming deposit‑insurance scheme. Strap in; here’s the play‑by‑play.

1. Choose your banking “vehicle” & ownership structure

Model	Typical purpose	Key regulatory facts
Commercial bank (PLC)	Full retail & wholesale banking	Min. capital US $75 m; no branch‑count rule; may be 100 % foreign‑owned
Specialized bank	Niche lending (e.g., mortgage, SME)	Min. capital US $15 m; cannot take demand deposits
Branch of foreign bank	Serve corporate clients, funnel group funding	Parent must hold investment‑grade rating; capital US $50 m if rated, otherwise US $75 m
Representative office	Market research only – no lending or deposit taking	No prudential capital; cannot generate income

Good news for an American founder: Cambodia’s investment law places no equity cap on foreigners in banking, so you can own the entire entity or team up with local investors purely for market knowledge. 

2. Capital, prudential & fee checklist

1. Paid‑in capital – wire US $75 m to a Cambodian account in your bank’s name and place it in an NBC‑designated blocked account until the license is granted.  
2. One‑time NBC fees – inquiry (US $250) + admin (US $1,250) + license (US $37,500). Ministry of Commerce (MoC), Tax and Labor registrations add another ≈ US $1,000.  
3. Ongoing ratios – Tier‑1 CAR ≥ 15 %; liquidity & reserve ratios posted quarterly; NBC on‑site exams yearly. (Ratios contained in NBC Annual Supervision Reports.)  
4. Deposit insurance coming – NBC & MEF are designing a scheme in 2024‑25; plan systems to calculate premiums early.  

3. Licensing timeline – from idea to grand opening

Stage	Regulator	What happens	Indicative time
Name reservation	MoC (CamDX portal)	Hold your future brand	1‑3 days
Approval‑in‑principle (AIP)	NBC	Submit business plan, capital proof, board CVs, AML/CFT & risk policies	~ 3 months
Company incorporation	MoC	Upload AoI, shareholder IDs; receive certificate	1 week
Tax & Labor registration	GDT, MLVT	E‑filing, staff quota, work permits	1 week each
Final banking license	NBC	Pay license fee, show premises readiness	2‑6 weeks after docs accepted

Realistic total: 9‑15 months if your project is well‑prepared; longer if NBC needs clarifications.

4. Governance, compliance & risk armor

Fit & Proper People

• Board ≥ 5 directors, at least 1 independent.
• CEO & key officers need banking CVs, clean criminal record, and NBC approval.  

AML/CFT 2020 law duties

• Enhanced customer due diligence for PEPs & high‑risk transactions.
• Mandatory STR/SAR filing to CAFIU.
• Fines up to KHR 1 billion (~ US $244 k) plus license revocation for breaches.  

Technology & cyber

• Join the NBC “FAST” and “Bakong” payment rails for real‑time riel & USD transfers. (NBC mandates core‑system connectivity in its Prakas on Payments.)  

5. Taxation & incentives

Item	Standard rate	Notes
Corporate income tax	20 %	0 % – 9 years holiday possible via QIP status at the Council for the Development of Cambodia (CDC).
VAT on banking	Exempt on interest; 10 % on certain fees (clarified by GDT).	—
Withholding on profit repatriation	14 % (dividends) unless treaty applies (U.S. treaty pending).	—

CDC can grant duty‑free import of IT equipment and a CIT holiday if you commit to rural outreach or fintech innovation. 

6. Winning‑edge strategies for an American founder

1. Leverage the digital boom – cashless payments grew from USD 85 bn (2019) to USD 274 bn (2022); a mobile‑first model slashes branch costs.  
2. Position on ESG & inclusion – align with the National Financial Inclusion Strategy 2025.  
3. Recruit bicultural leadership – NBC limits expat staff to 10 % unless waived; invest early in Khmer talent pipelines.  
4. Stay ahead of deposit‑insurance premiums – design MIS now to tag insured vs. uninsured balances.  
5. Engage early with NBC “Innovation Office” – sandbox pathways exist for e‑KYC and cloud core‑bank pilots.

7. High‑voltage action plan

1. Vision sprint (30 days): craft a 3‑year business plan, partner with a Cambodian law firm, and lock preliminary capital commitments.
2. Regulatory runway (Days 31‑180): file NBC AIP, parallel MoC name reservation, draft AML/CFT & risk manuals.
3. Build & recruit (Months 7‑12): hire core executive team, select core banking platform, secure head office lease.
4. Final push (Months 13‑15): NBC onsite inspection, fee payment, license in hand—throw the ribbon‑cutting party!

8. Pep talk to power you forward 🚀

Cambodia’s banking field is wide open, tech‑charged, and welcomes bold foreign founders. With clear rules, dollarized deposits, and a fast‑growing middle class, you’re stepping into a market hungry for innovative, customer‑centric banking. Nail the compliance, champion financial inclusion, and you can build the next breakout bank of Southeast Asia—fueled by American ingenuity and Khmer dynamism. Let’s make it happen! 🎉