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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.

Initially framed as “Together Towards Disrupting the Chain and Ending Online Scams” by AKP in August, the conference now carries the theme “Acting Together towards Breaking the Chain and Eradication of Online Scams” on its official website. 

Prime Minister Hun Manet has publicly characterised the crackdown as an effort to “clean our house” and restore Cambodia’s reputation internationally.

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He emphasised the new system would make burdens less demanding than before, but the new ‘exit plan’ requirement and sharper duty‑of‑care definitions do bring some added complexity.

The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.

All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.