Will Your Country Find Out You Acquired a Cambodian Passport?

Cambodia's emerging data protection framework adds another layer of complexity. The country announced a comprehensive Draft Law on Personal Data Protection on July 23, 2025, featuring GDPR-inspired provisions with a two-year implementation timeline. This development could significantly affect how citizenship information is collected, processed, and shared, though the law currently excludes public authorities from its scope.

The program's legal structure under Articles 10-12 of the 1996 Law on Nationality provides for discretionary citizenship grants requiring Royal Decree approval. This contrasts sharply with Caribbean programs that operate under standardized regulatory frameworks with published statistics and transparent procedures. Cambodia has not released citizenship grant statistics since 2022, making it impossible to assess program volume or success rates.

Information sharing mechanisms and Cambodia's unique position

Cambodia occupies a distinctive position in the global network of tax and financial information sharing that fundamentally affects disclosure risks for citizenship by investment participants. Understanding these mechanisms requires examining both what Cambodia participates in and, crucially, what it does not.

The Common Reporting Standard represents the primary vehicle for automatic exchange of financial information globally, but Cambodia is notably absent from this framework. Unlike over 120 participating jurisdictions that automatically share financial account information, Cambodia has not joined the CRS, creating significant gaps in information sharing with major economies. This non-participation means Cambodian financial institutions are not required to identify and report tax residents of other countries, substantially reducing the likelihood of citizenship disclosure through financial channels.

This contrasts sharply with Caribbean CBI jurisdictions, which fully participate in CRS and automatically share detailed financial information with tax authorities worldwide. Cambodia's isolation from this system represents one of its few competitive advantages in the citizenship by investment space.

However, Cambodia maintains a comprehensive FATCA agreement with the United States, creating specific disclosure risks for U.S. persons. The Model 1A Intergovernmental Agreement signed September 14, 2015, requires Cambodian financial institutions to identify and report U.S. citizens and residents. This includes explicit citizenship reporting requirements, with financial institutions required to search for "identification of the Account Holder as a U.S. citizen or resident" and report names, addresses, U.S. tax identification numbers, and account information.

The FATCA framework extends beyond simple account reporting to encompass comprehensive due diligence procedures. Cambodian banks must examine various "U.S. indicia" including place of birth, residence addresses, telephone numbers, and standing instructions to transfer funds to U.S. accounts. For U.S. citizens considering Cambodian citizenship, this creates unavoidable disclosure risks through the banking system.

Cambodia's bilateral tax treaty network remains extremely limited, reducing treaty-based information sharing obligations. Research confirms no active bilateral tax treaties with major economies including the United States, United Kingdom, Canada, Australia, or major European nations. This absence of formal treaty relationships significantly limits the legal frameworks available for information sharing, though it also means potential citizens receive no treaty benefits such as reduced withholding taxes or double taxation relief.

The country's participation in multilateral information-sharing frameworks is similarly limited. While Cambodia belongs to the Global Forum on Transparency and Exchange of Information for Tax Purposes, it has not signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, which facilitates automatic information exchange among 149 participating countries.

Country-specific disclosure obligations and dual citizenship policies

The disclosure risks associated with Cambodian citizenship vary dramatically based on your current nationality, with most major democratic countries imposing no requirements to report dual citizenship acquisition while others maintain strict disclosure obligations or prohibit dual citizenship entirely.

United States citizens face no legal requirement to report dual citizenship acquisition to government authorities. U.S. law fully permits dual nationality without requiring citizens to choose between citizenships or notify the State Department of foreign citizenship acquisition. Recent legislative proposals such as H.R. 7484 Dual Citizenship Disclosure Act would require Congressional candidates to disclose dual citizenship, but these bills have not been enacted and would not affect private citizens.

However, U.S. tax obligations create indirect disclosure pathways. All U.S. citizens must report worldwide income to the IRS regardless of where they reside or what other citizenships they hold. Foreign Bank Account Reports (FBARs) are required when foreign account balances exceed $10,000, while FATCA reporting applies to foreign assets above $200,000-$300,000 depending on filing status. These requirements, combined with Cambodia's FATCA agreement, create comprehensive disclosure pathways for U.S. citizens.

United Kingdom policy explicitly permits dual citizenship without disclosure requirements. The Home Office states clearly that British citizens "do not need to apply for dual citizenship" and face no notification obligations when acquiring foreign nationality. UK dual citizens cannot receive diplomatic protection from the British government when in their other country of citizenship, but this limitation carries no reporting requirements or penalties.

Canada follows a similar approach, recognizing dual citizenship without disclosure obligations. Immigration, Refugees and Citizenship Canada confirms that "you don't apply for dual citizenship, and there is no related certificate." Canadian dual citizens must use valid Canadian passports when entering Canada by air since 2016, but no reporting requirements exist for foreign citizenship acquisition.

Australia has permitted dual citizenship since April 2002 without requiring disclosure to authorities. Citizens who lost Australian citizenship before 2002 due to acquiring foreign citizenship do not automatically regain it, but current law imposes no reporting obligations for dual nationality acquisition. Australian citizens must use Australian passports when entering or leaving the country, but this represents a practical requirement rather than a disclosure obligation.

Germany implemented major dual citizenship reforms in June 2024, eliminating most restrictions while maintaining no disclosure requirements. The country now allows dual citizenship for all foreign nationals, reducing naturalization residency requirements from eight to five years while permitting retention of previous citizenship. No specific reporting obligations exist for dual citizenship status.

Several countries maintain strict prohibitions or disclosure requirements that create higher disclosure risks. Singapore strictly prohibits dual citizenship, requiring citizens to renounce foreign citizenship or face automatic loss of Singapore nationality. Switzerland requires Swiss nationals living abroad to notify their registered Swiss representation when acquiring another citizenship. The United Arab Emirates generally prohibits dual citizenship outside specific investor programs, while Hong Kong follows Chinese nationality law that does not recognize dual citizenship.

Tax reporting obligations and financial disclosure pathways

Beyond direct citizenship reporting requirements, tax obligations create significant indirect pathways for disclosure that vary by jurisdiction and financial activity level. Understanding these obligations requires examining both residence-based and citizenship-based taxation systems and their interaction with international reporting standards.

The United States operates the world's most comprehensive citizenship-based taxation system, creating unavoidable disclosure risks for U.S. citizens regardless of residence. All U.S. citizens must file annual tax returns reporting worldwide income, with no exceptions for dual nationals or foreign residents. This obligation extends to reporting foreign financial accounts, investments, and business interests through multiple disclosure mechanisms.

The Foreign Bank Account Report (FBAR) requires disclosure of foreign accounts when the aggregate balance exceeds $10,000 at any point during the year. Given Cambodia's investment thresholds exceeding $245,000, most CBI participants would trigger FBAR obligations that create detailed financial records linking them to Cambodia. The report requires specific identification of account locations, financial institutions, and maximum balances, creating a clear record of Cambodian financial activity.

FATCA reporting obligations add another disclosure layer for U.S. citizens with significant foreign assets. Reporting thresholds range from $200,000 to $300,000 depending on filing status and residence, capturing most CBI participants' financial positions. These reports require detailed disclosure of foreign investments, business interests, and financial accounts, creating comprehensive records of international financial activities.

Most other major countries operate residence-based taxation systems that reduce disclosure risks for citizens living abroad. Canada, the United Kingdom, Australia, and most European nations tax based on residence rather than citizenship, meaning citizens who establish residence elsewhere often face limited reporting obligations to their home country tax authorities.

However, residence-based systems can create disclosure obligations when citizens maintain financial ties to their home countries. UK tax residents must report worldwide income and gains, potentially including Cambodian investments or account information. Canadian tax residents face similar worldwide reporting obligations, though specific disclosure thresholds and requirements vary by asset type and income level.

The Common Reporting Standard creates the most significant systematic disclosure risk for citizens of CRS-participating countries who maintain financial accounts in Cambodia. However, Cambodia's non-participation in CRS eliminates this major disclosure pathway. CRS participating countries automatically exchange detailed financial account information, including names, addresses, tax identification numbers, account balances, and investment income for their tax residents' foreign accounts.

Cambodia's absence from CRS means this information sharing does not occur, creating a significant privacy advantage compared to Caribbean CBI jurisdictions that fully participate in automatic exchange mechanisms. Citizens of CRS countries who acquire Cambodian citizenship and establish financial relationships there would not have this information automatically shared with their home country tax authorities.

Anti-money laundering and know-your-customer requirements create additional disclosure pathways through private sector compliance. Financial institutions worldwide must verify customer identities and assess money laundering risks based on citizenship, residence, and transaction patterns. Large investment transactions required for CBI programs typically trigger enhanced due diligence procedures that include detailed background checks and source of funds verification.

These compliance procedures often involve sharing information with correspondent banks, regulatory authorities, and law enforcement agencies. While not automatic disclosure to home country governments, AML compliance creates institutional records and potential disclosure pathways that extend beyond formal government information-sharing agreements.

Privacy and confidentiality protections in practice

Cambodia's approach to privacy protection for citizenship by investment participants reflects the country's broader challenges with institutional capacity and regulatory development. Current protections operate through limited legal frameworks while facing significant pressures from international compliance requirements and diplomatic pressure.

Cambodia's existing privacy legal framework provides basic constitutional protections supplemented by sector-specific regulations. Article 40 of the Constitution guarantees privacy of residence and communications, while the Civil Code Articles 10-13 establish personality rights including privacy protections. Sub-Decree No. 252 (2021) specifically addresses personal identification data within the Ministry of Interior, though its scope remains limited to government identification records.

The draft Law on Personal Data Protection announced July 23, 2025, represents a significant expansion of privacy rights with GDPR-inspired provisions. The law establishes comprehensive data protection principles, subject rights, and controller obligations while providing for administrative penalties up to 600 million riels for entities violating data protection requirements. However, the law currently excludes public authorities from its scope, potentially limiting its application to government processing of citizenship information.

Practical privacy protections for CBI participants remain limited due to institutional weaknesses and lack of transparency. Unlike Caribbean jurisdictions that maintain detailed privacy policies and data protection procedures for their CBI programs, Cambodia provides no specific confidentiality measures for citizenship applications. The discretionary nature of the approval process, combined with requirements for political connections, creates significant confidentiality concerns given the lack of standardized procedures and oversight mechanisms.

The absence of published program statistics or transparency reports since 2022 creates uncertainty about information handling practices. While this lack of transparency might suggest greater privacy protection, it more likely reflects institutional capacity limitations rather than deliberate confidentiality measures. The program's reliance on informal networks and political connections raises concerns about information security and potential unauthorized disclosure.

Cambodia's position outside major international information-sharing frameworks provides significant confidentiality advantages compared to other CBI jurisdictions. The country's non-participation in CRS eliminates the primary pathway for automatic financial information sharing with over 120 countries. Limited bilateral tax treaty relationships reduce formal information exchange obligations, while minimal multilateral convention participation limits cooperative information sharing requirements.

However, this isolation from international frameworks also creates vulnerabilities. Cambodia's failure to meet international transparency standards has attracted criticism from the FATF-OECD, U.S. Treasury, and European regulatory authorities. The June 2025 U.S. State Department memorandum specifically criticizes deficiencies in "data sharing" and threatens travel restrictions if improvements are not implemented by August 13, 2025.

Financial sector privacy protections operate primarily through standard banking confidentiality practices rather than specific CBI-related measures. Cambodian banks maintain customer confidentiality as part of standard business practices, though this protection faces limitations from AML compliance requirements and international reporting obligations. The FATCA agreement with the United States creates specific disclosure obligations that override standard banking confidentiality for U.S. persons.

Enhanced due diligence requirements under anti-money laundering regulations may require disclosure of citizenship information to correspondent banks, regulatory authorities, and potentially law enforcement agencies. These requirements create institutional records and potential disclosure pathways that extend beyond formal government information-sharing agreements.

Comparative analysis with other citizenship programs

Examining Cambodia's disclosure and privacy practices within the broader citizenship by investment landscape reveals significant differences in approach, institutional capacity, and international integration that affect confidentiality protections for participants.

Caribbean citizenship by investment programs operate under increasingly sophisticated privacy and disclosure frameworks designed to balance client confidentiality with international compliance requirements. The five active Caribbean programs (Antigua & Barbuda, Dominica, Grenada, St. Kitts & Nevis, and St. Lucia) have implemented standardized minimum investments of $200,000 and enhanced due diligence procedures following extensive coordination with U.S. Treasury officials.

These programs maintain strong constitutional privacy protections while implementing enhanced security measures behind the scenes. All five jurisdictions moved away from public disclosure of citizenship grant recipients, maintaining client confidentiality while sharing security-relevant information through the Joint Regional Communications Centre database. This approach demonstrates how established programs balance privacy protection with international cooperation requirements.

The Caribbean programs' participation in CRS creates automatic financial information sharing with over 120 countries, representing a significant disclosure pathway that Cambodia avoids through non-participation. However, the Caribbean jurisdictions' sophisticated regulatory frameworks, independent oversight mechanisms, and transparent reporting systems provide greater institutional protection against unauthorized disclosure or program manipulation.

Malta's former program represented the gold standard for balancing transparency with privacy protection before its termination in April 2025. The program featured independent parliamentary oversight, published annual regulatory reports, and a four-tier due diligence process that achieved a 33% rejection rate. While the European Court of Justice ultimately found the program incompatible with EU law for commercializing Union citizenship, Malta's approach demonstrated how rigorous oversight and transparency could coexist with client confidentiality.

Malta's requirement for genuine connection to the jurisdiction through residency and integration represented a fundamentally different approach from Cambodia's minimal connection requirements. The program's emphasis on due diligence quality over processing speed created institutional protections against money laundering and security risks while maintaining privacy for approved applicants.

Asian citizenship by investment programs demonstrate varying approaches to privacy and disclosure, with most maintaining greater confidentiality than transparency. Turkey's program increased minimum investments to $400,000 while implementing enhanced physical presence requirements including mandatory in-country fingerprinting and biometric submission. The program maintains standard confidentiality without public registries or detailed transparency reporting.

Jordan implemented fundamental reforms in July 2025, eliminating passive investment options and requiring active business engagement with job creation requirements. All pathways now require investments of $750,000 to $2.1 million with annual quotas of 500 applications. While Jordan publishes program statistics and revenue data, participant names remain confidential with standard privacy protections.

Programs facing international sanctions demonstrate the consequences of inadequate privacy and security measures. Vanuatu's permanent removal from the EU Schengen visa-exempt list in December 2024 resulted from security concerns including inadequate due diligence that allowed "hostile state spies and criminals" access to visa-free travel. The UK's 2023 revocation of visa-free access reflected similar security and due diligence concerns.

These sanctions highlight how programs balancing speed and revenue generation over security and due diligence standards ultimately face international restrictions that affect all participants. Vanuatu's decline from 50% to 21.8% of government revenue dependence on CBI programs demonstrates the financial consequences of international isolation.

Cambodia's approach falls into the lower tier of international standards based on available evidence. The program demonstrates less transparency than Malta's former gold standard, minimal international cooperation compared to Caribbean information-sharing initiatives, limited due diligence relative to reformed programs like Jordan's active-investment model, and weak regulatory oversight compared to emerging Caribbean regional regulators.

The program's competitive advantages primarily stem from Cambodia's isolation from international information-sharing frameworks rather than sophisticated privacy protection design. While this isolation provides confidentiality benefits, it also attracts international criticism and regulatory pressure that could ultimately threaten program viability or participant mobility.

Practical risk assessment and strategic considerations

Evaluating the practical likelihood of home country discovery requires examining specific disclosure pathways, enforcement realities, and risk mitigation strategies based on individual circumstances and intended use of Cambodian citizenship.

The highest disclosure risks exist for U.S. citizens due to comprehensive reporting obligations and Cambodia's FATCA compliance. U.S. citizenship-based taxation creates unavoidable worldwide income reporting requirements, while FBAR obligations capture foreign accounts exceeding $10,000 aggregate balances. Given Cambodia's investment thresholds exceeding $245,000, most participants would trigger multiple reporting requirements that create detailed records of Cambodian financial activity.

Cambodia's FATCA agreement requires financial institutions to identify and report U.S. citizenship status, creating additional disclosure pathways through the banking system. These combined obligations mean U.S. citizens cannot practically avoid disclosure of significant financial activities in Cambodia, though direct citizenship reporting requirements do not exist.

Citizens of other major democracies face substantially lower disclosure risks due to residence-based taxation and limited information-sharing mechanisms. UK, Canadian, Australian, and most European citizens typically face no direct reporting requirements for dual citizenship acquisition. Their countries' participation in CRS could create disclosure risks, but Cambodia's non-participation eliminates this major pathway.

However, maintaining significant financial ties to home countries while residing abroad can trigger residence-based reporting obligations that might capture Cambodian investments or activities. Citizens maintaining tax residence in their home countries while acquiring Cambodian citizenship should evaluate specific reporting thresholds and requirements based on their total financial positions.

Banking and financial activities create the highest practical disclosure risks regardless of formal government information-sharing agreements. AML compliance requirements mandate customer identification, source of funds verification, and ongoing monitoring that creates institutional records of citizenship and financial activities. Large investment transactions trigger enhanced due diligence that often involves sharing information with correspondent banks, regulatory authorities, and potentially law enforcement agencies.

These private sector compliance activities operate independently of government information-sharing agreements and create records that could be accessible through various legal processes. Citizens seeking maximum confidentiality should consider how their intended use of Cambodian banking and financial services might create disclosure risks through compliance activities.

Travel patterns and passport usage create additional disclosure considerations that vary by intended citizenship use. Frequent travel using multiple passports can create records that immigration authorities might correlate over time. Citizens planning to use Cambodian passports for specific travel purposes should evaluate whether these activities might create patterns that alert home country authorities to dual citizenship status.

The U.S. State Department's June 2025 memorandum threatening travel restrictions on Cambodian citizens creates additional risks for program participants. If implemented, such restrictions could affect all Cambodian passport holders and potentially trigger enhanced scrutiny of individuals with connections to Cambodia.

Risk mitigation strategies focus on minimizing unnecessary disclosure rather than complete concealment, given the legal nature of dual citizenship in most jurisdictions. Citizens should evaluate their specific legal obligations for tax reporting, financial disclosure, and travel document usage rather than assuming complete confidentiality is possible or necessary.

Professional legal and tax advice becomes essential for understanding jurisdiction-specific obligations and developing compliant strategies that minimize unnecessary disclosure. Citizens should engage qualified advisors familiar with both their home country requirements and Cambodia's developing regulatory environment.

The timing of citizenship acquisition relative to changing international pressures requires careful consideration. The August 2025 U.S. deadline for addressing program deficiencies could affect future travel privileges or disclosure requirements, making current regulatory timing a strategic factor in decision-making.

Current regulatory environment and recent developments

The regulatory landscape surrounding Cambodia's citizenship by investment program has evolved significantly throughout 2025, with international pressure, domestic policy changes, and regional developments creating a complex environment that affects disclosure risks and program viability.

The U.S. State Department's June 2025 travel ban memorandum represents the most significant immediate threat to program participants and Cambodia's international standing. The memorandum includes Cambodia among 36 countries facing potential visa restrictions, establishing an August 13, 2025 deadline to address deficiencies in "document security, data sharing, and visa overstays." This explicitly targets citizenship by investment programs offering "citizenship by monetary investment without residency requirement."

The memorandum's emphasis on "data sharing" deficiencies suggests U.S. authorities expect enhanced information sharing capabilities that could affect participant privacy. If Cambodia fails to meet these requirements, resulting travel restrictions could affect all Cambodian passport holders regardless of their acquisition method, creating practical consequences that extend beyond disclosure risks to include restricted mobility.

EU regulatory developments continue pressuring citizenship by investment programs globally through enhanced visa suspension mechanisms and strengthened anti-money laundering requirements. New visa suspension rules expected by fall 2025 feature lower thresholds for triggering suspensions, extended 12-month initial suspension periods with 24-month extensions, and explicit targeting of CBI programs without genuine residency links.

The European Court of Justice's April 2025 ruling terminating Malta's program established precedent condemning "commercialization of Union citizenship" and requiring "genuine links" between citizens and countries. While this ruling specifically addressed EU citizenship, it reflects broader international skepticism toward investment-based citizenship that could influence other jurisdictions' policies.

Cambodia's announcement of comprehensive data protection legislation on July 23, 2025, introduces significant regulatory uncertainty for citizenship program privacy protections. The draft Law on Personal Data Protection features GDPR-inspired provisions including data subject rights, controller obligations, breach notification requirements, and administrative penalties up to 600 million riels for entities.

However, the law's current exclusion of public authorities from its scope limits direct application to government processing of citizenship information. The two-year implementation timeline creates additional uncertainty about how these provisions might affect existing citizenship grants or ongoing applications.

Regional ASEAN developments affect Cambodia's position within Southeast Asian integration frameworks that could influence information sharing requirements. The ASEAN Economic Community's emphasis on enhanced cooperation and integration could create pressures for greater transparency and information sharing among member states, potentially affecting Cambodia's current isolation from international frameworks.

Cambodia's economic over-dependence on Chinese investment, representing 90% of foreign direct investment, creates additional geopolitical pressures that could affect international cooperation and information sharing requirements. The U.S. memorandum's broader concerns about Cambodia's alignment with Chinese interests suggest citizenship program scrutiny occurs within larger strategic considerations.

Institutional capacity challenges continue undermining program implementation and creating uncertainties about procedures and protections. Multiple sources confirm that successful citizenship applications have become "extremely difficult" due to local government inaction and lack of institutional infrastructure. The program's reliance on political connections rather than standardized procedures creates risks for both applicants and the program's continued viability.

The absence of dedicated CBI units, official application processes, or public-facing program information contrasts sharply with established jurisdictions that provide transparent procedures and institutional protections. This institutional weakness creates vulnerabilities to international pressure and potential program modifications that could affect existing participants.

Anti-money laundering and counter-terrorism financing pressures continue affecting all CBI programs globally, with Cambodia's limited compliance frameworks attracting particular scrutiny. FATF-OECD recommendations emphasize enhanced due diligence, source of funds verification, and international cooperation requirements that Cambodia has not fully implemented.

The country's ranking of 158th on Transparency International's Corruption Index and single-party political system governance structure contribute to international concerns about program integrity and oversight. These factors influence whether other countries maintain information-sharing relationships and cooperation agreements that could affect participant privacy.

Key takeaways and strategic implications

The question of whether your home country will discover Cambodian citizenship acquisition depends primarily on your current nationality, intended use of the citizenship, and the specific disclosure pathways that apply to your circumstances. The analysis reveals several key conclusions that should inform strategic decision-making.

Cambodia's non-participation in major international information-sharing frameworks provides genuine privacy advantages that distinguish it from most other citizenship by investment jurisdictions. The country's absence from the Common Reporting Standard eliminates automatic financial information sharing with over 120 countries, while limited bilateral tax treaties reduce formal information exchange obligations. This isolation creates real confidentiality benefits for citizens of most major democracies who acquire Cambodian citizenship.

However, these privacy advantages exist primarily due to Cambodia's institutional limitations and international isolation rather than sophisticated privacy protection design. The same factors that create confidentiality benefits also attract international criticism and regulatory pressure that threatens program viability and participant mobility.

U.S. citizens face substantially higher disclosure risks due to citizenship-based taxation and Cambodia's FATCA compliance requirements. Comprehensive worldwide income reporting obligations, Foreign Bank Account Report requirements, and automatic financial information sharing through FATCA create multiple pathways for disclosure that U.S. citizens cannot avoid. While no direct citizenship reporting obligation exists, the practical effect of these combined requirements makes significant Cambodian financial activities visible to U.S. authorities.

Citizens of other major democracies generally face minimal formal disclosure requirements, with most countries imposing no obligations to report dual citizenship acquisition. However, residence-based taxation systems can create indirect disclosure risks for citizens maintaining financial ties to their home countries while engaging in significant investment activities abroad.

The program faces immediate and substantial international pressure that could fundamentally alter disclosure risks and program viability. The U.S. State Department's August 2025 deadline for addressing deficiencies in "data sharing" suggests potential requirements for enhanced information sharing that could eliminate current privacy advantages. Travel restrictions affecting all Cambodian passport holders represent practical consequences that extend beyond disclosure risks to include restricted international mobility.

EU regulatory developments, including strengthened visa suspension mechanisms and the precedent established by Malta's program termination, indicate broader international movement toward restricting citizenship by investment programs that lack genuine residency requirements or sophisticated oversight mechanisms.

Practical disclosure risks operate primarily through private sector compliance activities rather than formal government information-sharing agreements. Anti-money laundering requirements, enhanced due diligence procedures, and correspondent banking relationships create institutional records and potential disclosure pathways that extend beyond formal treaty obligations. Citizens planning significant financial activities in Cambodia should evaluate these private sector risks as carefully as government-to-government information sharing.

The program's institutional weaknesses create both opportunities and vulnerabilities for confidentiality protection. Limited transparency and lack of standardized procedures might provide short-term privacy benefits through reduced institutional record-keeping and oversight. However, these same weaknesses make the program vulnerable to international pressure, potential manipulation, and sudden policy changes that could affect existing participants.

For potential applicants, the analysis suggests that Cambodia's citizenship by investment program offers genuine privacy advantages for non-U.S. citizens compared to most alternatives, but these benefits come with significant risks including international pressure, limited global mobility, and uncertain program viability. The decision requires careful evaluation of individual circumstances, risk tolerance, and intended citizenship usage against the backdrop of rapidly evolving international regulatory pressure and institutional limitations that may fundamentally alter the program's character and benefits.

The window for acquiring Cambodian citizenship under current conditions appears to be closing, with the August 2025 U.S. deadline representing a critical inflection point that could trigger substantial changes to disclosure requirements, international recognition, or program continuation. Potential participants should engage qualified legal counsel familiar with both their home country obligations and Cambodia's evolving regulatory environment while carefully considering whether the program's current benefits justify its substantial risks and limitations.