4H Materials

Gambling Market Assesment Note: Cambodia

1. Gambling market size and addressable market

Due to the official ban on online gambling, the true scope of the potential market remains unclear. According to government budget stipulations, the casino sector annually contributes roughly $43.55 million to the nation's coffers, which includes licensing fees and tax revenue.

Cambodia's current population is around 17 million, with approximately 60% falling within the 18 to 65 age range.

Licensed gambling establishments are restricted from offering games of chance to local Cambodians and primarily serve foreign nationals, with Chinese tourists making up most of the player base. Local players tend to play online on the website of irregulated online operators.

2. Available verticals

Online gambling has been closed for new operators since 2019 as part of a broader ban on online gambling in Cambodia. Existing operators will be able to offer online gambling until the expiration of their licenses.

Land-based gambling (casinos and betting shops) is permitted in gambling zones only. While casinos are the focus of the legislation, betting shops remain in a legally grey area with limited regulation.

In particular, casinos may organise:

· Card and dice games,
· Roulette,
· Slot machines,

but may not offer betting.

Betting shops may offer fixed-odds betting and pari-mutuel betting.

Lotteries are legal and operated as a state monopoly; operations on the lottery market are not available for investors.

3. Gambling zones in Cambodia

Land-based gambling establishments may be in permitted zones only. Permitted zones allow organizing casino games and betting, which are only permitted within the premises of a casino.

In practice, these zones are concentrated near state borders to facilitate access for foreign players.

4. Available gambling licenses

In practical terms, there are two license types available:

· Casino license located outside integrated resorts,
· Casino license for the integrated resort casino.

5. Key gambling license requirements

Corporate requirements:

Company operator shall:

· Be established in Cambodia,
· Have local legal and tax representation,
· Ensure a clear governing structure,
· Have minimum assets in the amount of ≈USD 100,000,000 for casinos outside integrated resorts and ≈ USD 200,000,000 for casinos in integrated resorts.

License fees and terms:

· For casinos outside integrated resorts – approx. ≈USD 100,000; validity term is up to 20 years,
· For casinos in integrated resorts – approx. ≈USD 200,000; validity term is up to 5 years.

Operational requirements:

Company operator shall ensure:

· Enough financial and human resources,
· Pre-approval and register offered games and rules for visitors,
· The hardware and software used for the operation were bought from a licensed supplier and manufactured less than 10 years ago.

6. Regulator and application process

The Commercial Gambling Committee of Cambodia (“CGC“) is key regulator for the industry.

The application procedure involves three key steps:

· The applicant provides documents and relevant confirmations (related to premises, assets etc) to CGC,
· CGC studies, search, and decide on the application; when needed, additional information requests are sent
· Within 60 days CGC issues its decision.

7. Taxation

Cambodia uses GGR rax for taxation of gambling operations. The current tax rate is 7%.

8. Enforcement measures and sanction for operators

CGC may issue written warning, suspend license or withdraw the license entirely.

In several cases, illegal online gambling operators and players were found guilty of breaching the gambling ban. However, the gambling ban is not strictly enforced yet.

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