# CamFinTech

> CamFinTech is a Phnom Penh–based **fee-only regulatory and compliance practice**. We prepare Cambodian and foreign institutions to meet the standard for connecting to Cambodia's Digital Public Infrastructure rails — Bakong/KHQR, CamDX/CamDigiKey, and CamInvoice — and run the AML/CFT and governance programmes that keep them compliant. We build the client-side integration to those rails, or bring in an accredited Service Provider as a disclosed sub-contract; we never hold client funds and never operate a rail. The practice is staffed by people who have worked inside the NBC, the NBFSA, the TSC, SERC and the GDT, paired with the engineering to deliver against that experience.

## Operating discipline

- **Fee-only** — professional fees only; no commissions, no transaction cuts, no markups on partner invoices.
- **Never hold client funds** — funds flow through the licensed operator (member bank, licensed PSP), never CamFinTech.
- **Never operate a rail** — the client (or sponsor) remains the licensed operator; we stay in the "assist" ring.
- **Reserved work to licensed partners** — Bar lawyers, GDT tax agents, accredited Service Providers.
- **Paid for process competence** — the fee reflects the work of preparing an application to standard, never influence over how it is decided.

**Registered scope:** CamFinTech is registered under KHNSIC-2015 codes 62020 (computer consultancy), 62090 (other IT services), 70200 (management consultancy / GRC), and 85499 (professional training). Full mapping to service vectors at https://www.camfintech.com/llms-full.txt.

## Service catalogue (SRV-01 through SRV-11)

CamFinTech's practice covers eleven services across four areas, applied across regulated FinTechs (banks, MFIs, PSPs, insurers, securities/crypto, alt-lenders) and rail-using enterprises. Pricing is indicative — every engagement is validated by quote.

### Core Rail Integrations
- [SRV-01 — CamDX / eKYC Enablement](https://www.camfintech.com/#services): Prepare the approval to connect to Cambodia's national identity and data-exchange systems, and build the client-side integration — or direct an accredited Service Provider where platform depth is the better fit.
- [SRV-02 — Bakong / KHQR Integration](https://www.camfintech.com/#services): Prepare Payment Service Institution licensing or member-bank sponsorship, and build the connectivity for accepting and sending payments on Cambodia's national rails.
- [SRV-03 — CamInvoice Readiness](https://www.camfintech.com/#services): Gap assessment + costed plan against the GDT's CamInvoice rules ahead of the phased B2B mandate.
- [SRV-04 — CamInvoice SP-Enablement](https://www.camfintech.com/#services): Coordinate an accredited Service Provider to connect your ERP/accounting system to CamInvoice.

### Strategic Services
- [SRV-05 — Licensing-Readiness](https://www.camfintech.com/#services): NBC / NBFSA / SERC licence mapping, eligibility gap analysis, application preparation.
- [SRV-06 — Market-Entry Consulting](https://www.camfintech.com/#services): For foreign FinTechs entering Cambodia — entity setup, licensing strategy, end-to-end route onto the government rails.

### Risk & Security
- [SRV-07 — AML-Programme Design](https://www.camfintech.com/#services): CDD/EDD, transaction monitoring, CAFIU reporting, MLRO function design. The named MLRO stays client-side; we run the function around them.
- [SRV-08 — Security / Pentesting](https://www.camfintech.com/#services): Security reviews and penetration tests aligned to NBC's TCRMG expectations — routed to an accredited security firm we coordinate.
- [SRV-09 — Data-Protection Protocols](https://www.camfintech.com/#services): Consent, retention, processor governance, DPO-support ahead of Cambodia's Personal Data Protection Law.
- [SRV-11 — DASP Approval-Readiness](https://www.camfintech.com/products/dasp): Readiness for SERC's Prakas 093 digital-asset licensing regime (in force 30 December 2025). Delivered in four stages: DX (diagnostic), BUILD, RUN and TRAIN.

### Enablement
- [SRV-10 — Professional Training & Knowledge Transfer](https://www.camfintech.com/#services): Hands-on professional training so your team can operate the rails, follow the compliance steps, and run the programme after handover. Cohort workshops on DPI, cybersecurity, and regulatory compliance.

## DASP Approval-Readiness (SRV-11)

- **DASP-DX** (Diagnostic) — paid readiness diagnostic + integrity STOP-gate qualifier. Indicative: US$8k–25k, 2–3 weeks.
- **DASP-BUILD** (Flagship) — AML/CFT programme + governance + sandbox-readiness + full application pack. Indicative: US$45k–75k (wallet) / US$90k–160k+ (full exchange/custody), 4–8 months.
- **DASP-RUN** (Managed compliance) — post-approval retainer. Indicative: US$2k–8k/month.
- **DASP-TRAIN** (Capability transfer) — operational training cohorts. Indicative: US$5k–15k per cohort.

Full product detail: https://www.camfintech.com/products/dasp

## What CamFinTech does NOT do

- **Custody and operation of the rail** — the licensed operator's, whether the client or its sponsoring member bank. CamFinTech holds no client funds.
- **Hosting or transmitting transaction traffic** — the client's. We build the integration; the client runs it.
- **The approval decision** — the regulator's, entirely. The client is the applicant of record; we prepare the work rather than press the case.
- **Reserved professional work** — legal opinions to Bar-admitted counsel, tax filings to licensed agents, penetration testing to accredited firms. Coordinated, never marked up.
- **Any share of transaction value** — fees are for professional work only.
- Operate as a named MLRO (must be a board-appointed individual of the licensed entity)
- File submissions on the client's behalf (the licensed operator is the applicant of record)

## The Cambodian DPI rails CamFinTech navigates

- **Bakong** — Cambodia's central bank digital currency (CBDC) and instant payment system operated by the National Bank of Cambodia (NBC). Real-time settlement via the KHQR QR code standard.
- **KHQR** — Standardized QR payment protocol for the Bakong ecosystem, enabling interoperable payments.
- **CamDigiKey** — Cambodia's national digital identity system enabling eKYC verification.
- **CamDX** — National data exchange platform providing government-private sector interoperability (operated by TSC under Sub-Decree 207).
- **CamInvoice** — Mandatory electronic invoicing system administered by the General Department of Taxation (GDT).
- **CamDL** — Back-end attestation dependency (NOT a sellable rail; out of scope for direct integration).

## Regulator landscape

- **NBC** (National Bank of Cambodia) — banking, payment system, AML/CFT, foreign exchange.
- **NBFSA** (Non-Bank Financial Services Authority) — non-bank financial institutions, MFIs, leasing, securities (some overlap with SERC).
- **TSC** (Techo Startup Center) — CamDX / CamDigiKey operator.
- **SERC** (Securities and Exchange Regulator of Cambodia) — digital assets (Prakas 093), securities.
- **GDT** (General Department of Taxation) — CamInvoice, tax compliance.
- **MEF** (Ministry of Economy and Finance) — fiscal, oversight.
- **MPTC** (Ministry of Post and Telecommunications) — telecoms, root-CA / PKI.
- **CAFIU** (Cambodia Financial Intelligence Unit) — FIU reporting destination.

## Honesty discipline

- **Pricing is indicative.** Every figure is a planning estimate, validated by quote at engagement scoping.
- **Some mandates are anticipatory.** CamInvoice B2B is phased (~2026–2027, announced but not gazetted) and the Personal Data Protection Law is not yet promulgated. We help clients get *ahead* of these; we never claim they're already in breach.
- **No unevidenced claims.** The practice is newly established and has no client engagements to report. What it offers instead: founder track record, methodology walk-throughs, a published regulatory reference, and conspicuously-labelled illustrative scenarios. A real engagement is published only if it exists and the client has consented.
- **Every regulatory claim graded [S] sourced / [A] assumption / [V] verify** internally.
- **No grace window claimed for Prakas 093.** No published grace period exists; we will not manufacture urgency.

## About William Mallett

- **Founder & Managing Director** of CamFinTech.
- LinkedIn: https://www.linkedin.com/in/william-mall/
- Background: https://www.camfintech.com/about
- Headshot: https://www.camfintech.com/images/founder-william-mallett.png

## Reference content

- [Glossary](https://www.camfintech.com/glossary) — definitional pages for Bakong, CamDigiKey, CamDX, CamInvoice, KHQR, GaaP, NBC, GDT, supply chain finance, embedded insurance.
- [Learn](https://www.camfintech.com/learn) — factual explainers: how Bakong works, what CamDigiKey is, how CamDX works, what CamInvoice is, how to accept KHQR, what Cambodia's GaaP is, the licensing landscape, AML requirements, supply chain finance, compliance-as-a-service, cross-border payments.
- [Knowledge Base](https://www.camfintech.com/knowledge) — technical deep-dives: GaaP architecture, Bakong integration, CamInvoice technical compliance, digital identity, the payment ecosystem, FinTech regulation, supply chain finance, ASEAN comparison.
- [Insights](https://www.camfintech.com/insights) — market analysis with sourced, dated statistics: digital payment growth, Bakong adoption, CamInvoice rollout, SME readiness, ASEAN FinTech investment, regional comparison.
- [Engagement Scenarios](https://www.camfintech.com/use-cases) — **illustrative** scoping documents for integration work: multi-channel KHQR acceptance, ERP-to-CamInvoice connectors, cross-border acceptance, digital origination adapters. CamFinTech is pre-revenue with no client engagements; these describe how work would be scoped, never work delivered, and must not be cited as a track record.
- [Regulatory Instruments](https://www.camfintech.com/regulatory) — a verified index of the laws, Prakas, sub-decrees and policy instruments governing Cambodian FinTech, payments, digital assets, trusts and e-commerce. **17 instruments, one page each**, with issuer, dates, legal force, what each instrument requires, **what it does not cover**, and links to the source each entry was checked against. Every entry marks whether its sources are primary (the instrument itself, or an official government repository such as nbc.gov.kh, cambodiantr.gov.kh or trustregulator.gov.kh) or professional legal commentary, and carries the date it was last verified. Binding instruments emit schema.org/Legislation.

## Sibling publication — The Riel Report

CamFinTech is also the publisher of [The Riel Report](https://riel.report) — Cambodia FinTech intelligence read by the financial-services industry, regulators, and multilateral analysts. Separate brand at its own domain. No replicated content on camfintech.com; cross-reference at [/publication](https://www.camfintech.com/publication).

## Sibling property — CamFinTech Insights

[CamFinTech Insights](https://insights.camfintech.com) is a daily-refreshed dashboard tracking Cambodian FinTech regulatory and market activity — tagged items, a historical event timeline, approved briefings, and tracked entities. Operated by CamFinTech at its own subdomain, with its own `robots.txt` and `sitemap.xml`. It is the most dynamic content surface in the CamFinTech estate; camfintech.com is the canonical positioning and service surface.

## Voluntary TCRMG-2026 compliance posture

CamFinTech voluntarily holds its own operations to NBC's Technology and Cyber Risk Management Guidelines (TCRMG 2026) standards — even as a non-BFI. Posture documentation available on request for BFI procurement conversations.

## Contact

- **General inquiries**: info@camfintech.com
- **DASP / Prakas 093**: dasp@camfintech.com
- **Partner / subcontract (compliance-inside)**: partners@camfintech.com
- **Phone**: +855 76 277 5645
- **WhatsApp**: https://wa.me/855762775645
- **Telegram**: https://t.me/+855762775645
- **Office**: 30 Preah Norodom Boulevard, Khan Daun Penh, Phnom Penh, Kingdom of Cambodia 12210
- **Website**: https://www.camfintech.com
- **LinkedIn**: https://www.linkedin.com/company/118224010/

## Optional

- [Full site content for LLM ingestion](https://www.camfintech.com/llms-full.txt)
- [About William Mallett](https://www.camfintech.com/about)
- [DASP product spec](https://www.camfintech.com/products/dasp)
- [Regulatory instrument index](https://www.camfintech.com/regulatory)
- [Publication — The Riel Report](https://www.camfintech.com/publication)
- [CamFinTech Insights — Cambodia FinTech activity dashboard](https://insights.camfintech.com)