Cambodia Investment Review
Cambodia’s financial sector is advancing its adoption of artificial intelligence (AI) technologies, focusing on their potential to enhance operational efficiency, reduce fraud, and improve customer services. However, as business implementation accelerates, the absence of a clear regulatory framework continues to present both risks and limitations. Stakeholders are now calling for a structured, forward-looking approach to ensure the safe and strategic deployment of AI systems across the sector.
The topic was the focus of a recent luncheon hosted by the American Chamber of Commerce in Cambodia (AmCham) on June 3, 2025. Attended by senior representatives from the government, financial institutions, and academia, the event explored how Cambodia can balance innovation with accountability as it integrates emerging technologies into its banking infrastructure.
Speakers at the Event:
- Kong Phallack, Secretary of State, Ministry of Post and Telecommunications
- Torsten Kleine Büning, Chief Risk Officer, ABA Bank and Treasurer of AmCham Cambodia
- Oudam Rony, Director of Technology Risk and Innovation Supervision, National Bank of Cambodia
AI Integration in Banking: Business Priorities
In Cambodia’s banking sector, AI is increasingly being deployed to automate credit assessments, detect fraud, monitor cybersecurity threats, and support customer-facing tools such as chatbots and self-service kiosks. These applications are seen as essential to scaling digital banking services and managing operational risk, especially as the sector becomes more complex and competitive.
Yet while the potential benefits are clear, banks also face strategic challenges in implementation. Regulatory ambiguity, internal capacity gaps, and concerns over data protection continue to slow the pace of adoption. Institutions often build and test AI models quickly, but formal approvals and compliance procedures can add significant delays, creating friction between innovation and oversight.
This tension underscores the need for a more agile yet reliable framework—one that promotes responsible experimentation while safeguarding customer data, system integrity, and ethical standards.
Regulatory Gaps and Upcoming Frameworks
Cambodia’s existing financial technology guidelines, most notably the National Bank of Cambodia’s 2019 technology circular, do not explicitly cover AI. As a result, banks are currently deploying AI solutions in a regulatory grey zone, with limited clarity on how such innovations should be monitored or governed.
Recognising this, the central bank is preparing a revised guideline on technologies and cyber risk management. The updated document is expected to introduce AI-specific oversight mechanisms, which will function as both a compliance checklist and supervisory tool. These measures aim to bring AI into alignment with broader risk management practices already in place for other digital infrastructure.
Among the key considerations will be ensuring that banks apply strong data governance principles, particularly when training AI models on customer data. If data is stored or processed internationally, institutions must take care to ensure personal information is not improperly exposed or used without consent.
Aligning Policy, Innovation, and Implementation
Beyond technical oversight, the Ministry of Post and Telecommunications has called for a multi-stakeholder approach to policy development. The goal is to build a legal foundation that both encourages AI adoption and anticipates the societal impacts of automation, bias, and privacy concerns. Rather than merely react to AI developments, the government is aiming to proactively define the rules of engagement for one of the most transformative technologies of the decade.
For business leaders, the current moment presents both a challenge and an opportunity. The successful implementation of AI in Cambodia’s financial sector will depend on the ability to align internal investment strategies with evolving policy structures. Institutions that can anticipate compliance needs while embedding AI into their core services will likely gain a competitive advantage in an increasingly digitised financial marketplace.
As the country takes these next steps, collaboration between regulators, technologists, and business leaders will be essential—not only to define what responsible AI use looks like, but to ensure that its deployment contributes meaningfully to long-term financial stability and inclusion.
