Anti-Money Laundering & Counter-Terrorism Financing Policy

At VLP Law Office, we are committed to delivering legal services with the highest standards of integrity, transparency, and accountability. As part of our ethical obligations and legal compliance under the laws of Cambodia, we have implemented robust Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) measures.

By signing our fee proposal or engaging us for our service, you have acknowledged and agreed with this policy. We may update this policy from time to time without prior notice. Please check the last updated date to see if there have been any changes.

 

1. What This Policy Covers

This policy is intended to help our clients understand our legal responsibilities and to ensure that our firm is not used, whether knowingly or unknowingly, as a vehicle for money laundering or the financing of terrorism.

 2. What Are Our Legal Obligations

We are obligated to comply with Cambodia’s Law on Anti-Money Laundering and Combating the Financing of Terrorism (2020) and its relevant subsidiary legislation (collectively referred to as “the Law”).

Lawyers fall within the definition of "reporting entities" when they prepare for or carry out transactions on behalf of client in the following areas, and are therefore required to comply strictly with the Law:

  • Buying and selling immovable property, building and land.

  • Managing client’s money, securities or other assets.

  • Establishing, operating or management of entities or arrangements.

  • Buying and selling of business entities.

  • Trust or company providing services when they carry out transactions for client concerning the following activities:

  1. Acting as a formation agent of legal entity.

  2. Acting as, or arranging for another person to act as, a director or secretary of a company, a partner in a partnership, or a similar position in another legal entity.

  3. Providing a registered office, business address, correspondence, or administrative address for a company or entity.

  4. Acting as, or arranging for another person to act as, a trustee of an express trust.

  5. Acting as, or arranging for another person to act as, a nominee shareholder for another person.

The Law require us to:

  • Know your client (KYC) and carry out customer due diligence (CDD) to assess the risks of money laundering and terrorism financing.

  • Identify and verify (and retain for a minimum of five years) the identities of our clients, their beneficial owners (if applicable), and the relevant transactions.

  • Understand the purpose and intended nature of the business relationship or transaction.

  • Identify and report suspicious transactions to the competent authorities.

  • Establish internal controls and conduct regular staff training.

 

3. What This Means for Our Clients

As part of our onboarding and ongoing relationship management, we may, at any time request the following:

  • Verification of identity (e.g., passport, national ID card, or company registration documents).

  • Information about the source of funds or wealth, particularly in complex, high-value, or cross-border matters.

  • Details on the nature and purpose of the engagement or transaction.

  • Updated documentation if there are material changes in your profile or transaction.

We appreciate your cooperation and understanding. These steps are not only legal obligations but essential measures to uphold the integrity of our profession.

 

4. What Are Our Confidentiality and Reporting Obligations

While we respect and uphold client confidentiality, we are legally required to report certain information to relevant authorities without notifying the client involved if we suspect that a transaction involves criminal conduct, money laundering, or terrorism financing.

 

5. What Are Red Flags and High-Risk Indicators

We are vigilant in identifying and assessing risks that may arise from:

  • Refusal to provide information relating to the relevant parties or transactions.

  • Unexplained or sudden wealth.

  • Requests to use third-party intermediaries or offshore structures without clear legal or business rationale.

  • Complex or unusually large transactions lacking an apparent economic or lawful purpose.

  • Clients from jurisdictions identified as having a high risk of money laundering or terrorist financing.

 

6. Our Commitment

We are committed to working with clients who share our values of transparency and compliance. Our AML and CTF frameworks are part of our broader commitment to ethical legal practice and to supporting the rule of law in Cambodia, and beyond.

 

Updated on 14 May 2025