DASP Approval-Readiness
The end-to-end regulatory approval-readiness programme for SERC's Prakas 093 digital-asset licensing regime — in force since 30 December 2025.
The firm prepares the application, builds the AML/CFT programme, assembles the governance roster, and supports the client from sandbox readiness through to the full application. The licensed DASP operator (you) submits and operates; reserved legal opinion routes to a Bar lawyer. We never custody, never file, never operate.
Why now
Prakas 093 entered into force on 30 December 2025. Cambodia's digital-asset operators — crypto exchanges, OTC desks, custody providers, payment-on-rails firms with token components — now need DASP licensing from SERC to operate legally.
The requirements are prudential rather than technical. The AML/CFT and governance build — FATF Travel Rule, MLRO function, sandbox readiness, fit-and-proper assessments — is the substantial work; the technology is the smaller half.
Honesty discipline: there is no published grace window. We will not manufacture urgency by claiming one. The regulation is in force; the readiness work takes 4–8 months to do properly. The cost of starting late is missing the early-mover window.
Read the instruments rather than our summary of them: Prakas 093 sets the licensing regime, and SERC Notification 083/25 is what makes sandbox graduation a precondition of applying at all. Both pages state what the instrument does not cover, and link to the sources they were checked against.
Four products, one ladder
Land-and-expand from diagnostic to ongoing compliance. Pricing indicative; validated by quote at engagement scoping.
DASP-DX · Diagnostic
Readiness diagnostic that doubles as our paid integrity STOP-gate qualifier (see below). Maps your current state against the SERC requirements; flags eligibility blockers; produces a costed remediation plan.
Indicative range: US$8k–25k · 2–3 weeks
DASP-BUILD · Flagship
The full programme: AML/CFT framework, governance documentation, MLRO function design, FATF Travel Rule integration spec, sandbox-readiness package, and full SERC application pack. The licensed DASP operator submits.
Indicative range: US$45k–75k (wallet) · US$90k–160k+ (full exchange/custody) · 4–8 months
DASP-RUN · Managed compliance
Post-approval retainer. Quarterly compliance reviews, transaction-monitoring tuning, CAFIU reporting cadence support, regulatory-update advisory, and pre-audit readiness. Your named MLRO stays client-side; we run the function around them.
Indicative range: US$2k–8k/month retainer
DASP-TRAIN · Capability transfer
Operational training for your AML/CFT, compliance, and front-office teams. CDD walkthroughs, Travel Rule operational playbooks, scenario-based training for transaction monitoring escalations.
Indicative range: US$5k–15k per cohort
The 5-test integrity STOP-gate
Before we accept any DASP engagement, every prospect clears a five-test integrity screen. The DX diagnostic is the qualifier. If a test fails, we decline — no exceptions. The five tests:
- 1. UBO transparency. Beneficial-ownership traceable to a named individual with verifiable identity; no anonymous chains, no opaque holding structures.
- 2. Sanctions clearance. Principals, entity, and connected parties clear OFAC, UK, EU, UN, and Cambodian designations at engagement and re-screened quarterly.
- 3. Source-of-funds defensibility. Capital provenance can be substantiated to a documented origin. Funds traceable to a designated party, to an entity subject to a special measure, or to proceeds of technology-enabled fraud do not clear this test.
- 4. Counterparty hygiene. Current and proposed trading relationships pass a basic-due-diligence screen; no obvious facilitation of designated entities.
- 5. Operational separation. No operational ties (shared infrastructure, common officers, intermingled funds) to entities in the designated set.
We document the screen and its result. If we decline, we tell you which test failed and why. The DX fee is non-refundable on STOP-gate failure — it's the work done.
What we do — and explicit bright lines
In scope
- AML/CFT framework + policy + procedures
- Risk assessment + risk appetite statement
- Governance structure + board pack + MLRO function design
- CDD/EDD workflows + onboarding decision matrices
- Transaction monitoring rule library + tuning
- FATF Travel Rule integration spec + counterparty handling
- Sandbox application pack + readiness reviews
- Full SERC application support (drafting, not filing)
- Fit-and-proper documentation packages
- Post-approval RUN retainer + audit-readiness
Bright lines — out of scope
- Named MLRO stays client-side — must be a board-appointed, senior-management, CAFIU-notified individual of the licensed entity (not outsourceable to us)
- Custody, filing, operating the rail stays with the licensed DASP — we never hold assets, never file submissions on your behalf, never operate
- Reserved legal opinion routes to a Bar lawyer we coordinate — never CamFinTech-stamped
- External audit routes to an audit firm — never CamFinTech-stamped
- Sanctions-screening platform operation — we design the policy, you operate the tool
Honesty notes — corrections we've made
- 15% SERC guarantee deposit: single-sourced to a DFDL alert; failed our cross-source check. We will not quote a deposit figure until counsel confirms. Treat secondary-source numbers with caution.
- No grace / no application window: several commentaries refer to a "grace period." We checked — it doesn't appear in the gazetted instrument. We will not manufacture urgency by quoting one.
- Sandbox sequencing, application fee schedule, fit-and-proper test specifics, and the Cambodian Travel Rule instrument: all currently graded [V] — to be verified with counsel during DX. We won't pretend they're settled.
- Pricing is indicative. All figures on this page are planning estimates. Final pricing is engagement-specific and validated by quote during DX.
Ready to start the DX diagnostic?
The diagnostic is a 2–3 week paid engagement that doubles as the integrity STOP-gate qualifier. Tell us about your DASP plans — we'll reply within 24 hours in Phnom Penh business hours.