On 3 July 2025, the Commercial Gambling Management Commission of Cambodia (“CGMC“) issued Instruction No. 008/25 on the Implementation of Licence for Special Employees in Casino Establishments (“Instruction“). This Instruction aims to ensure compliance of casino operations and effective management of casino employees in accordance with applicable laws and regulations.
To achieve the above objectives, casino owners and/or casino operators shall comply with the following obligations:
- Instruct Special Employees to wear their licence at all times during work hours;
- Prohibit any employees other than Special Employees duly licensed/recognised by CGMC from undertaking the duties reserved for Special Employees, and ensure that such Special Employees do not engage in any work beyond the scope of each licence;
- Ensure that Special Employees and other casino employees are not, concurrently or otherwise, civil servants, officials of CGMC, qualified shareholders, Special Employees of other commercial gaming operators, of owners of integrated resort, of owners of casinos, of casino managers or of other related parties whether directly or indirectly;
- Promptly inform CGMC of any disputes that occurs with Special Employees;
- Ensure that games are operated by licensed Special Employees;
- Submit an up-to-date list of all casino employees, including their positions and duties, to the General Secretariat of CGMC quarterly by the 10th day of the following month, and annually by 15 January of the following year;
- Provide written notice to the General Secretariat of CGMC no later than seven working days after the dismissal or termination of any Special Employees;
- Submit to the General Secretariat of CGMC an annual up-to-date list of Special Employees that are currently working, have resigned or have been dismissed by 15 January of the following year;
- Pay the annual Special Employee licence fee no later than the 15 January of the following year; and
- Submit application for the renewal of Special Employee licence at least three months prior to the expiration date.
Failure to comply with the foregoing obligations shall be considered as a violation of the Law on Management of Commercial Gambling and shall be subject to administrative sanctions and/or fines in accordance with the applicable laws and regulations.
If you have any queries on the above, please feel free to contact our team members who will be happy to assist.
Disclaimer
Rajah & Tann Asia is a network of member firms with local legal practices in Cambodia, Indonesia, Lao PDR, Malaysia, Myanmar, the Philippines, Singapore, Thailand and Vietnam. Our Asian network also includes our regional office in China as well as regional desks focused on Brunei, Japan and South Asia. Member firms are independently constituted and regulated in accordance with relevant local requirements.
The contents of this publication are owned by Rajah & Tann Asia together with each of its member firms and are subject to all relevant protection (including but not limited to copyright protection) under the laws of each of the countries where the member firm operates and, through international treaties, other countries. No part of this publication may be reproduced, licensed, sold, published, transmitted, modified, adapted, publicly displayed, broadcast (including storage in any medium by electronic means whether or not transiently for any purpose save as permitted herein) without the prior written permission of Rajah & Tann Asia or its respective member firms.
Please note also that whilst the information in this publication is correct to the best of our knowledge and belief at the time of writing, it is only intended to provide a general guide to the subject matter and should not be treated as legal advice or a substitute for specific professional advice for any particular course of action as such information may not suit your specific business and operational requirements. You should seek legal advice for your specific situation. In addition, the information in this publication does not create any relationship, whether legally binding or otherwise. Rajah & Tann Asia and its member firms do not accept, and fully disclaim, responsibility for any loss or damage which may result from accessing or relying on the information in this publication.
