July 13, 2025|Published by Surtin Dung
Washington has not forbidden every U.S. firm from doing business with Cambodia. Instead, several agencies have imposed overlapping measures that raise the compliance bar for U.S. persons and anyone who uses U.S. technology, dollars, or banking channels:
Tool | Agency | What it does | Key takeaway |
Business Advisory (Nov 10 2021) | State + Treasury + Commerce | Flags five “high-risk” sectors (finance, real-estate, casinos, timber, infrastructure). | U.S. firms must apply enhanced due-diligence before entering Cambodian deals. OFAC |
Export Administration Regulations (EAR) | Commerce/BIS | Added Cambodia to Country Group D:5 → any dual-use or high-tech item needs a licence, presumption of denial. Federal RegisterFederal Register | |
ITAR Arms Embargo | State/DDTC | Since 9 Dec 2021 the policy is to deny licences for defense articles & services. Federal Register | |
OFAC Sanctions | Treasury/OFAC | Designates individuals & companies tied to forced-labour scam hubs; U.S. persons are barred from dealing with them. U.S. Department of the Treasury | |
PATRIOT Act §311 Action | Treasury/FinCEN | Proposed rule (1 May 2025) to cut Huione Group off from USD correspondent banking for laundering ≈ $4 bn cyber-fraud proceeds. FinCEN.gov |
Nov 10 2021 – Inter-agency Cambodia Business Advisory warns of corruption and trafficking risk zones. OFAC
Dec 9 2021 – BIS places Cambodia in EAR Group D:5 and State adds it to ITAR §126.1 “proscribed countries.” Federal RegisterFederal Register
Dec 6 2024 – OFAC designates Senator Ly Yong Phat, L.Y.P. Group and three resort-casinos for trafficking-linked forced labour at O-Smach. U.S. Department of the Treasury
May 1 2025 – FinCEN finds Huione Group to be “primary money-laundering concern,” proposes cutting its U.S. dollar access. FinCEN.gov
(Ongoing 2025) – Congress weighs additional trade measures as reports continue about Chinese military presence at Ream Naval Base. The Washington Post
Legal exposure – Contracting with an OFAC-listed person can trigger civil fines up to US $1 m per violation and criminal penalties.
Technology exports – U.S. sensor chips, advanced software, strong encryption, drones, etc., all require BIS licences that are usually refused.
Banking friction – Payments routed through Cambodian banks face heightened AML checks; transfers involving Huione Pay or L.Y.P. Group may be blocked outright.
Logistics risk – Cargo originating from high-risk zones (Ream, Sihanoukville, Dara Sakor SEZ) is more likely to be detained by U.S. Customs.
Automated sanctions screening – Run every Cambodian counter-party through OFAC/BIS/UN lists before onboarding.
Map the supply chain – Avoid routing goods through entities located on or near military-controlled sites such as Ream Base.
Watch the money – Decline payments that come from Huione Pay or any bank flagged in the FinCEN finding.
Export licences – If you sell telecoms gear, aerospace parts, or strong-crypto software, consult a U.S. trade lawyer about EAR exemptions or licence applications.
Record-keeping – Keep screening logs, invoices, and shipping papers for at least five years to defend against audits.
Stay current – Subscribe to OFAC Recent Actions and BIS Updates; Dakoli will relay major changes via our newsletter.
Built-in compliance micro-services – Our TypeScript backend calls sanctions & export-control APIs every 24 hours and tags sellers Low / Medium / High Risk.
Transparent dashboards – Buyers see an at-a-glance risk score and last-screened date for each Cambodian supplier.
Bilingual legal support – Dakoli’s VN-EN compliance team can draft BIS licence packets or self-certification letters of origin on request.
The U.S. “Cambodia restrictions” are not an iron wall, but they do demand stricter due-diligence than most ASEAN trade. With the right screening tools and documentation, you can still source Cambodia’s garments, furniture, or components without stumbling into U.S. sanctions trouble — and Dakoli is ready to guide you every step of the way.
This article is for general information only and is not legal advice. For case-specific guidance, consult qualified counsel or the relevant U.S. government agency.
