In an unusual joint notice regarding a country that is not generally subject to US sanctions, on November 10, 2021, the US State Department, Treasury Department, and Commerce Department issued a
The Advisory flags potentially significant reputational, economic and legal risks of doing business in Cambodia, and calls for “appropriate” due diligence to mitigate these risks. The Advisory does not itself impose sanctions or other trade restrictions on Cambodia, although it was issued in parallel with the imposition of sanctions on two senior Cambodian military officials under the Global Magnitsky program for their “involvement in significant corruption.” Nonetheless, the Advisory directs US companies to proceed with enhanced caution when doing business with individuals and entities in Cambodia and outlines a series of potential penalties, including sanctions that companies need to consider with respect to their activities in Cambodia. The Advisory specifically identifies the financial, real estate, casino, infrastructure, manufacturing, and timber sectors as areas of risk exposure for US companies.
This Alert notes the Advisory’s broad coverage, highlights the risk categories it identifies, and discusses implications important to affected businesses and activity involving Cambodia.
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