VLP Legal Press #31: Law on Combating Technology-Enabled Scams
Online scams are a growing crisis in our region.
A study carried out in 2025 by Global Anti-Scam Alliance found that 63% of Southeast Asians experienced a scam in the past 12 months, with total estimated loss of US$23.6 billion from Southeast Asians.
ASEAN established a dedicated Working Group on Anti-Online Scams in 2024 to improve regional coordination in combating scams.
In Cambodia, the Government has moved quickly by passing the Law on Combating Technology-Enabled Scams (the “Law”) in April 2026 to deal with those behind these crimes.
While the law is enacted to combat scam operations, it extends to those acting as a platform for scam activities.
For company and property owners, here is what you need to know in four simple questions.
Q1: What exactly is a "technology-enabled scam" under the law?
A technology-enabled scam is:
any fraudulent scheme,
carried out through technological systems (like phone calls, SMS, or apps),
with the intent to trick someone into giving up money, valuables, property, services or signing any document to create obligations/release.
Common versions include bank/authority impersonation, romance scams, fake promotion calls and blackmail.
Q2: Am I only liable if I am the one tricking victims?
The short answer is - no. You may also fall within the ambit of the Law if you’re involved in any of the following activities, whether personally or through your company:
Individual & Organised Group Scamming: Individually or as an organised group carrying out a scam through technological system.
Organizing Scam Centers: Running a scam operation or network, or the operation involves human trafficking, torture, forced labor, or results in the death of any person.
Recruitment & Training: Hiring or training others to conduct scams, especially when involving violence, abduction, or the exploitation of trafficking victims.
Collecting Data for Scamming Purpose: maliciously collecting personal documents like IDs and passports to set up the necessary bank and social media accounts as means to carrying the scam.
The Law expressly mentions that co-perpetrators, instigators and accomplices to the offences are punishable as principal perpetrators. Therefore, the liability does not only fall on the principal offender but to others who are assisting, abetting and involved.
The Law exempts those who participated in the offence relating to organising a scam centre or training others for scam-related offences from penalty if before being charged, they report the offence to competent authorities and leads to identification or other participants/proceeds. Therefore, staying informed and reporting suspicious activity is the best way to protect you or your business.
Q3: What are the penalties for businesses/individuals found involved?
Commits a technology-enabled scam (individually):
(Individual) Imprisonment of 2 to 5 years and a fine of US$50,000 to US$125,000
(Organised group; against multiple victims) Imprisonment of 5 to 10 years and a fine of US$125,000 to US$250,000
Commits the offence of organising a technology-enabled scam centre including those that interconnect as a network in any configuration:
Imprisonment of 5 to 10 years and a fine of US$125,000 to US$250,000
Commits the offence of organising a technology-enabled scam centre (if it involves violence, torture, cruelty, abduction, detention, unlawful restraint, human smuggling, trafficking, labor exploitation, forced criminality and other exploitation):
Imprisonment of 10 to 20 years and a fine of US$250,000 to US$500,000
Commits the offence of organising a technology-enabled scam centre (if it involves death of 1 or more persons):
Imprisonment of 15 to 30 years or life imprisonment
Recruits or trains others to participate in technology enabled scams:
Imprisonment of 2 to 5 years and a fine of US$50,000 to US$125,000
Recruits or trains others to participate in technology enabled scams (if it involves violence, torture, cruelty, abduction, detention, unlawful restraint, death, knowing recruit is a victim of human smuggling/trafficking):
Imprisonment of 5 to 10 years and a fine of US$125,000 to US$250,000
Maliciously collects identity cards, passports, other personal information documents of others to use or forge for bank accounts, online accounts, websites, electronic accounts or social media accounts as instruments for technology-enabled scams:
(Individual) Imprisonment of 1 to 3 years and a fine of US$25,000 to US$75,000
(Organised group) Imprisonment of 3 to 5 years and a fine of US$75,000 to US$125,000
If the above is committed by a legal entity:
A fine of US$250,000 to US$7,500,000 or equivalent to the value of funds/property that are proceeds of the offence
The above penalties are specifically detailed in the Law on Combating Technology-Enabled Scams. However, the Law also mentions that:
Assets suspect to relate to or are proceeds of technology-enabled scams and cannot be justified by the owner, shall be punishable according to money laundering laws.
Court may order confiscation of immovable property used as technology-enabled scam premise as state property.
Court may impose one or more additional penalties under Criminal Code for offences specified under the Law on Combating Technology-Enabled Scams.
Court may order closure of bank accounts, online accounts, websites, electronic accounts, or social media accounts used as instruments for technology-enabled scams.
Court may order a seizure or freezing of accounts/property within 48 hours from receipt of request or additional 24 hours if the matter is complex.
Q4: Can I be responsible for what happens on my property/platform if I didn't know?
The original intention of the law is that it will not impact innocent people, but one has to be careful not to participate in any of the activities mentioned in the law, intentionally or knowingly.
As the law also covers those who may act as a platform for scam operations, simply being unaware of the offence may not be enough. Individuals should be ready to cooperate and show that they have not knowingly or intentionally been involved in any conduct caught by the law.
As shared in our VLP Legal Press #28, related regulation such as Sub-Decree No. 03, require owners and managers of residential and business locations to maintain safety systems, keep CCTV footage for 90 days, and report suspicious activities to the police.
⚠️ Be Vigilant ⚠️
The law is designed to stop scams at the source, which means the authorities are looking at everyone in the chain. Who should be especially careful?
Landlords and Property Managers: Ensure you know who is renting your space and what they are doing there.
Company Owners: Monitor your digital platforms and networks to ensure they aren't being used by others to facilitate fraud.
Tech Service Providers: Be careful of clients who may be setting up "networks" for fraudulent purposes. Conduct proper know-your-customer checks.
This is for general reference only and does not constitute legal advice. For further guidance and legal advice on the non-competition clause in your contracts, contact us at:📧 connect@vlplaw.co