Cambodia Business Advisory on High-Risk Investments and Interactions

Date issued: Nov. 11 2021

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TURBOFAC Commentary (113 words)

Notes:

1) As is common with most "advisories," this advisory not clarify the scope and operation of any OFAC-administered sanctions provisions. Instead, it serves to alert the regulated community to Cambodia-related sanctions risks and diligence expectations related thereto. In the case of this particular advisory, the limited OFAC-related portion simply recounts, in stock language, the basics of the Global Magnitsky sanctions program pursuant to which several Cambodians, including Cambodian government-related persons, are sanctioned. See https://home.treasury.gov/news/press-releases/jy0475 (designating Cambodian government officials on the day the advisory was issued) and https://home.treasury.gov/news/press-releases/sm849 (a significant wave of Cambodia-related Global Magnitsky designations from 2019).