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There is a second complication. The relentless flow of Commission statements may eventually make enforcement less damaging rather than more.

“The regulatory failures are unhelpful but perhaps the sheer number and regularity of them has made them less remarkable, such that they become ‘wallpaper’,” Waugh says.

He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.

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However, the sustained enforcement drive has already taken a toll on the wider Cambodian economy. In May, the government lowered its 2026 GDP growth forecast as construction, real estate and consumer spending absorb the short-term impact of the crackdown.

Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements. 

The gap comes as Phnom Penh prepares to host its major anti-scam conference on 23-24 September, part of the wider government campaign against online scam networks.

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When asked about the Chargers—one of several teams, alongside the Dallas Cowboys and Denver Broncos, seeking to bounce back from a Week 1 upset to avoid an 0-2 start—Kubiak brushed off the narrative during his brief news conference.

That same single-game focus applies to the Raiders, with reporters pressing Kubiak on potential overconfidence following a 27-13 home win over the Miami Dolphins.

“Hopefully [the players] are mature enough to know that one of 17 is nothing,” Kubiak said.