Cambodia Investment Review
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has updated its sanctions list to include new entities and individuals operating in Cambodia and Myanmar, citing their involvement in large-scale cyber scams and forced labor, according to its latest September 2025 press release.
The action expands restrictions on U.S. persons and financial institutions, who are now prohibited from conducting transactions with the designated parties. Any property or interests in property under U.S. jurisdiction belonging to those named is frozen, and global institutions face compliance risks if they continue dealings.
According to U.S. estimates, Americans lost more than $10 billion to Southeast Asia–based scams in 2024, driven by fraudulent online investment schemes often linked to casino and real estate compounds in Cambodia. These operations, Treasury said, rely on trafficked labor and are increasingly structured to specifically target American victims.
For U.S. investors in Cambodia, the updated sanctions mean heightened due diligence requirements when engaging with local partners, particularly in real estate, hospitality, and financial services. The reputational and legal risks of inadvertently engaging with a sanctioned entity or its affiliates have significantly increased. Violations of OFAC regulations carry strict liability, with civil and criminal penalties possible even in the absence of intent.
The full list of newly added individuals and entities is available here.
