AMRO Flags Cambodia Scam Losses Above $45 Million and Casino Money Laundering Risks

Cambodia's losses expose a wider regional problem

Cambodia recorded more than $45 million in officially reported domestic online scam losses in 2025, according to an ASEAN+3 Macroeconomic Research Office analysis dated October 12, 2026. The figure draws on Ministry of Interior data published in February 2026, while the analysis also highlights weaknesses in regional oversight of casinos operating in special economic zones and businesses handling virtual assets.

AMRO's digital scam analysis, titled Managing Digital Scam Risks in ASEAN+3: Regulatory Frameworks and Policy Responses, calls for earlier detection, rapid account freezes, better recovery mechanisms and stronger cooperation between countries. Its authors are Benyaporn Chantana, Ivan Lim and Prashant Pande.

The Cambodian loss figure measures money lost through domestic online scams. AMRO's broader concern stretches across a much larger network: criminals deceive victims through phones and digital platforms, receive payments through financial institutions, then move the proceeds through accounts, gambling businesses or cryptocurrency services across several countries.

Households face the most immediate damage. Money intended for savings, education or business expenses can disappear within minutes, while recovery becomes harder with each transfer. AMRO says evidence of effects on the financial system as a whole remains limited, but persistent fraud can weaken confidence in digital financial services.

The warning brings together two connected challenges for Cambodia and its neighbours: stopping people from losing money and preventing criminal networks from using financial and commercial infrastructure to hide the proceeds.

Why approving a payment can leave victims exposed

Authorised payment fraud happens when someone is deceived into approving a transfer. A criminal might pose as an investment adviser or another trusted contact, persuading the victim to send money through an otherwise legitimate payment service.

AMRO explains that the deception often begins on telecommunications networks or social platforms, before a bank becomes involved. Financial regulators oversee payments and financial institutions, while other authorities supervise many of the channels where criminals first approach their victims.

Banks therefore encounter only part of the operation. A payment may carry the customer's approval even though a criminal engineered the decision behind it. Reimbursement arrangements are generally clearer for unauthorised transactions, while losses from authorised payments largely remain with customers, according to AMRO.

The institution says some regional arrangements are beginning to extend responsibility to other participants. Its recommended response covers prevention, detection, containment, recovery and the allocation of losses, meaning decisions about who bears the financial cost when safeguards fail.

Regional figures show a gap in recovery

Across selected economies, about 55 per cent of adults experienced at least one scam attempt during 2024–2025, AMRO says. Exposure reached 63 per cent in the selected ASEAN economies, compared with 40 per cent in the selected Plus-3 economies, a difference of 23 percentage points.

Among those exposed, 22 per cent in the ASEAN group reported losing money, compared with 8 per cent in the Plus-3 group where data were available. The Plus-3 economies are China, Japan and South Korea. These figures describe selected survey populations rather than a separate measurement for Cambodia.

Recovery was also weaker in the ASEAN group. Although 72 per cent of victims who lost money reported the scam to their payment provider, only 20 per cent recovered any funds. In the selected Plus-3 economies, 87 per cent reported the incident and 46 per cent recovered money or had the payment blocked before it reached the scammer.

AMRO also found that more than half of victims in the selected ASEAN economies recovered nothing, compared with 41 per cent in the Plus-3 group. Its survey estimates put individual scam losses at between 0.2 and 3.4 per cent of gross domestic product in 2024, including losses that victims never reported to authorities.

Those results explain the focus on speed. Criminals use mule accounts, accounts controlled by people who knowingly or unknowingly receive and pass on stolen money, to split and move payments. Once funds are dispersed or cross a border, authorities have less time and fewer straightforward routes to recover them.

Why casinos and economic zones draw scrutiny

AMRO identifies uneven supervision of businesses exposed to money laundering, including casinos operating in special economic zones, or SEZs, and virtual asset service providers. Money laundering means moving or disguising criminal proceeds so that they appear to come from lawful activity.

SEZs are designated areas intended to attract investment and jobs through arrangements such as tax incentives and simpler trade procedures. Casinos and junkets, businesses that arrange gambling trips and related services, can handle large sums and provide financial services that criminal networks seek to exploit.

The Global Initiative Against Transnational Organized Crime's Compound Crime report identifies MDS Thmorda SEZ in Cambodia, the Golden Triangle SEZ in Laos and Clark Freeport SEZ in the Philippines among locations that have attracted concern. Its research involved 14 researchers and civil society partners during the first six months of 2024.

The report identifies confirmed scam operations in a limited number of legally designated SEZs and describes other compounds in areas calling themselves SEZs or operating under different economic arrangements. It also documents scams in hotels, villas, apartment complexes and casino premises. Effective oversight must therefore follow the operators and their money across different types of property.

Citing UNODC, the Global Initiative says approximately 340 licensed and unlicensed casinos operated across Southeast Asian SEZs in 2021. UNODC's recommendations include monitoring financial flows and investments in these areas, alongside stronger supervision of junkets and digital financial businesses.

Phnom Penh's role in the digital money network

The United Nations Office on Drugs and Crime's Inflection Point report describes Huione Guarantee, also known as Haowang, as a major online marketplace headquartered in Phnom Penh. It says the predominantly Chinese language platform had more than 970,000 users at the time of writing and thousands of connected vendors.

UNODC cites expert estimates that cryptocurrency wallets used by Huione Guarantee and its vendors received at least $24 billion over four years. The Global Initiative gives a broader reported transaction range of $70 billion to $89 billion since 2021 for Huione Pay and marketplace vendors, covering a different set of businesses and transaction activity.

Blockchain researchers cited in the Global Initiative report traced some transactions to scam operations, armed groups and the Lazarus hacking group affiliated with North Korea. Huione denied reports linking it to illicit activity, according to that report.

UNODC says Huione expanded into a cryptocurrency exchange, a trading application, online gambling, a blockchain network and a stablecoin backed by the US dollar. A stablecoin is a digital token designed to maintain a steady value against an asset such as a national currency.

The National Bank of Cambodia confirmed in March 2025 that it had withdrawn Huione's payment service institution licence for failure to comply with regulations and recommendations, according to UNODC. The Global Initiative also describes subsequent action in May 2025, when the US Financial Crimes Enforcement Network proposed cutting Huione Group off from the US financial system and Telegram banned thousands of associated accounts and usernames.

How gambling can function as underground banking

UNODC officials have described an underground banking system concentrated in Cambodia, Laos, Myanmar, Thailand and Vietnam. Online gambling and digital payment tools allow networks to move value through arrangements that are difficult for authorities to follow.

Benedikt Hofmann, UNODC deputy representative for Southeast Asia and the Pacific, described how gambling's shift online changed the scale of the problem:

"Casinos have long played a role in money laundering in Southeast Asia, but the surge of online gambling has accelerated this in ways that weren't expected," Hofmann said.

One technique is offsetting. A customer deposits money with an operator in one country and receives an equivalent amount through another account in a different country. The operator settles the obligation through its network, allowing value to move without a simple transfer connecting the two customers across borders.

Another practice is buying a ready made package of software and services to run an online gambling site. This allows operators with little technical knowledge to establish gambling platforms that can also conceal financial activity.

Amanda Gore, a forensic accountant who heads the Centre for Global Advancement, has warned that accepting one payment method and paying out through another complicates identity checks. An account funded with a bank card might pay out in cryptocurrency, making it harder to verify who ultimately received the money.

The cases span several jurisdictions. A Macau court convicted gambling operator Alvin Chau over an illegal gambling empire that handled more than $105 billion in bets since 2013. Related prosecutions in mainland China included at least $160 million in illegal international payments. Thai authorities also alleged that Cambodian casino operator Kuo Che-min may have laundered more than half a billion dollars before Thailand extradited him to Taiwan.

The human cost moves across borders too

Scam compounds also involve trafficking and forced criminal activity. The Global Initiative cites a 2023 estimate from the Office of the UN High Commissioner for Human Rights of at least 120,000 people in Cambodia's scam compounds and at least 100,000 in Myanmar.

Workers can be moved or sold between compounds as operations relocate. The report describes routes through Thailand linking the Golden Triangle SEZ, Cambodia and Myanmar. A raid or closure in one place can therefore send both criminal operations and exploited workers elsewhere.

UNODC estimates that fraud enabled by digital technology caused between $18 billion and $37 billion in losses across East and Southeast Asia in 2023, with most attributed to scams committed by organised crime groups in Southeast Asia. Its report describes enforcement actions targeting online operations in Cambodia, the Philippines, Laos, Myanmar and Thailand.

Several developments show how the financial and human dimensions have accumulated:

• 2018: US authorities sanctioned Golden Triangle SEZ founder Zhao Wei and associates, alleging involvement in a transnational criminal organisation.
• 2022–2023: Zhao and several associates obtained Cambodian citizenship, according to UNODC.
• 2023: UN human rights estimates placed at least 120,000 people in Cambodia's scam compounds.
• March 2025: Cambodia's central bank confirmed withdrawing Huione's payment service institution licence.
• October 12, 2026: AMRO's analytical note called for stronger controls throughout the scam chain.

For governments, the practical challenge is to pursue organisers, financial intermediaries and assets while also identifying people forced to commit fraud. The same operation can involve victims losing savings abroad and workers facing exploitation inside a compound.

Where financial safeguards fall short

AMRO's assessment draws on Financial Action Task Force evaluations of measures against money laundering and terrorist financing. Those evaluations distinguish between having the required rules and making those rules work in practice.

Across several ASEAN+3 economies, gaps include checking customer identities, supervising businesses outside traditional banking, controlling risks from new technologies and cooperating with foreign authorities. The businesses concerned include casinos and providers that exchange, transfer or otherwise handle virtual assets.

AMRO says licensing and registration arrangements generally exist but are inconsistently enforced. Supervisors may lack staff, knowledge of criminal financing risks or the capacity to concentrate inspections on the activities most likely to be abused. Penalties strong enough to discourage misconduct and money laundering prosecutions are also rare.

No ASEAN+3 economy received a substantial effectiveness rating in the assessments AMRO cites for legal persons, such as companies, or for money laundering investigation and prosecution. Those weaknesses make it harder to identify who controls businesses, connect transactions to criminal networks and bring cases to court.

AMRO's conclusion is practical: stronger supervision must be accompanied by investigations, enforcement and usable mechanisms to trace, freeze and recover criminal proceeds.

What coordinated action would change

AMRO recommends standing contacts between countries, clearer procedures for handing cases between authorities and national centres that serve as designated points of contact. Cooperation should include financial intelligence units, telecommunications regulators and other agencies alongside police.

Governments would also need a clear legal basis for responding to foreign requests to trace, freeze, confiscate and return assets. Mutual legal assistance allows authorities in one country to seek evidence or other investigative support from another. Extradition arrangements address the transfer of suspects between jurisdictions.

AMRO says these procedures should extend to virtual assets and build on existing regional bodies, with clear responsibilities rather than parallel institutions. It also recommends improving supervisory capacity where resources are weakest. The analysis gives no deadline for governments to adopt its recommendations.

For victims, the most useful change would be a shorter interval between reporting a scam and stopping the money. For Cambodia and its neighbours, the larger task is to make relocation less useful to criminal networks by closing gaps in supervision and enforcement together.

Hofmann, the UNODC regional deputy representative, explained why isolated national campaigns struggle:

"That's why comprehensive regional responses are so important — individual countries' efforts just bring the issue back through the back door," Hofmann said.

Key Points

• Cambodia reported more than $45 million in domestic online scam losses for 2025, according to Ministry of Interior figures cited by AMRO.
• AMRO identifies regional supervision gaps involving casinos in special economic zones and virtual asset service providers.
• Only 20 per cent of victims in selected ASEAN economies recovered any money, despite 72 per cent reporting the scam to their payment provider.
• UNODC and the Global Initiative describe connected networks involving gambling, cryptocurrency services, money laundering and trafficking.
• AMRO calls for earlier detection, rapid freezes, stronger enforcement and coordinated international investigations and asset recovery.