Cambodia Property Scam Checklist: 12 Documents to Pull

Quick answer: Cambodia has no per-buyer escrow, but it does have a licensing regime with a real deposit behind it. Under Prakas No. 047 a developer lodges 2% of construction cost, or 5% of land investment cost, with the regulator. Ask for the licence, and most scams end at that question.

Every page that ranks for Cambodian property scams is a list of stories. A man paid a deposit and the seller vanished. A family bought a house that had already been sold. The stories are true and they are useless, because none of them names a document you can demand before you pay.

This page is the document list. It starts from what Cambodian law actually requires a developer to hold, and works outward to the six patterns that recur when those requirements are absent.

Two structural facts explain almost every loss a foreign buyer reports in Cambodia. The first is that there is no statutory per-buyer escrow and no deposit-protection scheme, so money paid to a developer is simply money paid to a company. The second is that systematic land registration is only now concluding, with roughly 500,000 parcels still unregistered in 2026, which means a meaningful share of the country’s land sits outside the national cadastre where a title search would find it. Our analysis treats these two facts as the substrate rather than as the scams themselves. The patterns below are what grows on that substrate, and the checklist that follows is built to test for both conditions before any money moves. Neither fact is hidden, and neither is unusual for a market at this stage of registration.

What is actually unprotected when you wire a deposit?

Nothing at the individual buyer level. Cambodia has no statutory escrow requirement and no deposit-protection scheme, so an off-plan instalment is an unsecured payment to a company. The protection that does exist is a project-level guarantee lodged with the regulator, at 2% of construction cost or 5% of land investment cost.

Protection	Exists in Cambodia?	What it actually covers
Per-buyer escrow account	No	Nothing
Deposit-protection scheme	No	Nothing
Developer guarantee deposit	Yes, under Prakas No. 047	2% of construction cost, project level
Land development guarantee	Yes	5% of land investment cost
Bank guarantee letter alternative	Yes	Substitutes for the cash deposit
Recovery route on failure	Civil litigation	Whatever the courts award

The distinction between project-level and buyer-level protection is the one most foreign buyers miss, and it changes the sizing decision rather than the buying decision. A 2% guarantee on a $40 million construction cost is $800,000, which is real money and a genuine barrier to entry for a fictitious developer. It is also less than the aggregate deposits on a mid-sized tower, so it does not make any individual buyer whole. Our underwriting treats the guarantee as evidence that a developer passed a regulatory test, and never as insurance, and the checklist below is built to gather evidence rather than to find cover that does not exist. A buyer who understands the difference sizes an off-plan position at what they can afford to litigate over, which is a very different number from what they can afford to pay.

• The guarantee proves the developer was licensed, not that you are covered.
• Off-plan instalments are unsecured payments to a company.
• Off-plan mechanics sit in the off-plan guide.
• Payment schedules are covered in the payment schedule guide.
• Delay and default risk is treated in the developer default guide.

Which documents prove a developer is licensed?

The licensing rule in force is Prakas No. 047 of 26 September 2023, issued by the Non-Bank Financial Services Authority, which replaced Prakas No. 089 SHV of 20 January 2020 and moved administration to the Real Estate Business and Pawnshop Regulator. Four documents establish whether a project is lawful.

Document	What it proves	Who issues it
Development business licence or permit	The project is registered and permitted	Real Estate Business and Pawnshop Regulator
Construction permit	Building work is authorised	Municipal or provincial authority
Guarantee deposit receipt or bank letter	The 2% or 5% guarantee is lodged	Regulator or a licensed Cambodian bank
Hard title or strata title over the site	The developer controls the land	Ministry of Land Management
Company registration extract	The counterparty exists as claimed	Ministry of Commerce
Tax registration certificate	The company is in the tax system	General Department of Taxation

Insider tip: ask which licence category the project falls into before asking to see the licence itself. More than 30 units or villas, or a lot above 10,000 square metres, requires the national licence. A project of 3 to 30 units, or a smaller lot, needs only a prior permit from the Capital-Provincial Department of Economy and Finance. A salesperson who cannot immediately say which threshold their own project sits above has almost certainly never seen the paperwork, and that single question sorts a professional developer from a promoter faster than any document request. Our methodology puts it first in the sequence for exactly that reason.

• Ask the licence category before asking for the licence.
• A promoter who cannot name the threshold has not seen the file.
• Developer red flags are catalogued in the due diligence red flags guide.
• The full process sits in the step-by-step due diligence guide.
• Named cases are covered in the unfinished projects warning.

What are the six patterns that recur?

Six patterns account for most reported foreign-buyer losses in the Cambodian market, and each one maps to a specific document that would have exposed it before any money moved. The largest single category is the double title, which persists because roughly 500,000 land parcels are still unregistered as systematic registration concludes in 2026.

Pattern	How it works	Document that exposes it
Double title	Sold once on soft title, once on hard title	National cadastral title search
Deposit disappearance	Fake owner takes a deposit and leaves	Title in the seller’s registered name
Forged or duplicated title	Fabricated or multiply issued document	Cadastral office verification
Unlicensed development	No licence, no 2% guarantee, no permit	Licence and construction permit
Stalled project resale	Unfinished tower sold as active, against a 8.9% banking NPL ratio	Site inspection and permit currency
Guaranteed return offer	Yield of 8% to 12% promised by a party who cannot fund it	Audited accounts of the guarantor

Every one of the six is a documentary failure rather than a judgement failure, which is the encouraging part of an otherwise unpleasant list. A buyer who obtains a national title search, a licence, a construction permit and a company extract has closed five of the six patterns before negotiating price. The sixth, the guaranteed return, closes when the buyer asks who is funding the guarantee and reads that party’s accounts. Our analysis has never seen a reported loss in this market that survived all six checks, and the checklist below is arranged in the order that eliminates the most exposure for the least effort. The cost of running all six is roughly $1,000 to $3,000 in legal fees, or about 0.7% to 1.5% of value, against a 4% transfer tax that a buyer pays without hesitation and a deposit that is commonly 10% to 30% of the price.

• All six patterns fail against documents, not against instinct.
• A national title search alone closes the largest category.
• Rent guarantee offers are dissected in the rent guarantee warning.
• Group-level scrutiny is covered in the Prince Group warning.
• The wider safety question sits in the buying safety guide.

How do you verify a title before you pay anything?

Title verification for foreign buyers is a search at the cadastral office against the national register, and not an inspection of whatever paper the seller hands across the table. Hard, LMAP and strata transfers take about 12 weeks, soft title transfers under 90 working days, and a soft title loses to a hard title in any contest between the two.

Verification step	What you are checking	Where
National cadastral search	The title exists and matches the seller	Ministry of Land Management office
Title class confirmation	Hard, soft, LMAP or strata	Cadastral record
Encumbrance check	Mortgages, caveats, disputes	Cadastral record
Boundary and area check	Parcel size in sqm matches what is sold	Cadastral plan
Foreign quota confirmation	Remaining share of the 70% total private-unit area	Building administration, in writing
Seller identity match	The name on the title is the person signing	Original identity documents

Transfer timing is a useful cross-check that costs nothing to apply. A hard, LMAP or strata title transfer takes about twelve weeks in practice, and a soft title transfer under 90 working days. A seller pressing for completion far inside those windows is either promising something they cannot deliver or is not transferring what they claim to be transferring. Our underwriting treats an unexplained compression of the transfer timetable as a red flag on the same level as a missing licence, because both indicate that the paperwork trail will not bear inspection at the pace the buyer is being pushed toward. A seller offering completion in 3 weeks on a title that takes 12 is describing something other than a registered transfer.

• A national search costs a fraction of the 4% transfer tax and settles ownership.
• Search the national register; do not inspect the seller’s copy.
• A hard title beats a soft title in any contest between them.
• Timelines are set out in the transfer timeline guide.
• Title classes are explained in the soft versus hard title guide.
• Registration mechanics sit in the strata registration guide.

What does a safe payment structure look like?

A safe structure pays a named project account, in stages tied to verified construction milestones, against a contract reviewed by an independent lawyer. Legal fees of $1,000 to $3,000, or roughly 0.7% to 1.5% of value, are the cheapest risk reduction available in this market.

Payment control	Safe version	Unsafe version
Recipient account	Named project account of the licensed developer	Agent’s personal or company account
Reservation fee	Small, refundable, documented	Large, non-refundable, verbal terms
Stage payments	Tied to verified construction milestones	Tied to dates alone
Contract review	Independent lawyer instructed by you	Seller’s introduced lawyer
Currency and route	Bank transfer with full audit trail	Cash or third-party transfer
Proof of receipt	Company receipt on letterhead	Handwritten note

Wiring money to the wrong account is the single most avoidable loss in this market, and it is the reason the deposit disappearance pattern still works after decades of warnings. The correction is procedural rather than analytical: the account name on the transfer instruction must match the licensed developer named on the permit, and if it does not, no explanation is sufficient. Our underwriting applies the same test to a reservation fee as to a stage payment, because a buyer scenario we see repeatedly is a modest reservation paid casually to an agent, which then anchors the buyer into a project they have not yet verified.

• The account name must match the licensed developer on the permit.
• Apply the same test to a reservation fee as to a stage payment.
• Fund sourcing requirements sit in the proof of funds guide.
• Wire mechanics are covered in the bank transfer guide.
• Contract review is treated in the SPA review guide.

What do you do when it has already gone wrong?

The response for foreign buyers is documentary and it is urgent. Preserve every payment record and communication, obtain an independent national title search, and instruct a Cambodian lawyer within the first week. Recovery of an off-plan deposit of 10% to 30% generally requires civil litigation, because no deposit-protection scheme stands behind the payment at all.

Step	Purpose	Timing
Preserve records	Build the evidential file	Immediately
Independent title search	Establish who actually owns it	First week
Instruct Cambodian counsel	Assess the cause of action, at $1,000 to $3,000	First week
Check the licence status	Establish whether the 2% or 5% guarantee exists	First week
Formal demand to the developer	Create a documented default	Before litigation
Civil claim	The only real recovery route	On advice

Speed matters more than strategy in the early stage, and the reason is documentary rather than legal. Evidence in these cases is often held by the counterparty: receipts on their letterhead, contracts in their possession, marketing material on a website that can be edited overnight. A buyer who archives everything in the first week has a case; a buyer who waits three months while an agent promises resolution frequently does not. Our analysis of the reported cases suggests the practical outcome is decided long before a court sees the file, and the deciding factor is whether the buyer collected documents while the counterparty was still communicating. Set against a 12-week transfer timetable and a civil process measured in years, the first seven days carry more weight than any subsequent decision the buyer makes.

• Archive everything in the first week, before positions harden.
• A formal demand creates the documented default a claim needs.
• Lawyer selection is discussed in the lawyer guide.
• Authority to act for you sits in the power of attorney guide.
• Defect claims are covered in the warranty claims guide.

Advantages and disadvantages of the Cambodian system

The regime is more documented than its reputation suggests, and less protective of the individual buyer than a European purchaser will expect.

Advantage	Disadvantage
Licensing regime with a real guarantee deposit	Guarantee is project level, not buyer level
2% and 5% deposits are lodged with a regulator	No per-buyer escrow exists at all
National cadastre records hard title reliably	About 500,000 parcels remain unregistered
Transfer timelines are predictable at twelve weeks	Pressure to compress them is common
Legal fees of $1,000 to $3,000 are low	Enforcement runs through civil litigation
Thresholds are clear at 30 units and 10,000 sqm	Buyers are rarely told which category applies

Cambodia is not an unregulated market, and describing it that way does foreign buyers a disservice by implying that care is impossible rather than merely necessary. A developer running a 200-unit tower has a licence, a construction permit, a lodged guarantee and a registered company, all of which can be produced on request. What Cambodia lacks is the automatic consumer protection a buyer in Britain or Australia takes for granted, and the gap between those two facts is exactly the space where the twelve documents below do their work.

Buyer scenarios and red flags

The twelve documents, in the order that removes the most risk first.

Scenario	What they want	What we would recommend
Off-plan buyer, 30% deposit due	Reassurance before wiring	Licence, permit, guarantee receipt, title, then wire
Resale buyer from a private seller	Clean transfer	National title search and identity match first
Buyer offered a guaranteed 12% return	To believe it	Audited accounts of the guarantor, or walk

The failure pattern is verification performed after commitment. A buyer pays a reservation fee, then begins due diligence, and discovers that every subsequent question is now a negotiation about getting money back rather than a decision about whether to proceed. The sequence is the whole defence. Our underwriting will not review a project after a deposit has moved without saying plainly that the leverage has already gone, and the twelve documents listed here are ordered so that a buyer can stop at any point without having paid anything.

• Development business licence or permit issued under Prakas No. 047.
• The licence category, confirmed against the 30-unit and 10,000 sqm thresholds.
• Construction permit, current and matching the site.
• Guarantee deposit receipt or bank guarantee letter for the 2% or 5%.
• Hard or strata title over the development site, in the developer’s name.
• Company registration extract from the Ministry of Commerce.
• Tax registration certificate for the developing entity.
• National cadastral title search on the specific unit or parcel.
• Encumbrance check for mortgages, caveats and disputes.
• Written confirmation of the remaining foreign quota by floor stack.
• Named project bank account details matching the licensed developer.
• Independent legal review of the SPA before any payment.

Where the money physically sits between your deposit and your title is a separate question from whether the developer is licensed, and it has its own set of answers: Cambodia deposit protection, escrow and bank guarantees sets out the three levers that exist, including the security guarantee a licensed developer has already lodged with the regulator.

Frequently Asked Questions

Is my off-plan deposit protected? +

Not at buyer level. Cambodia has no statutory escrow or deposit-protection scheme. A project-level guarantee exists under Prakas No. 047: 2% of construction cost or 5% of land investment cost lodged with the regulator.

How do I check a developer is licensed? +

Ask for the development business licence under Prakas No. 047 of 26 September 2023, plus the construction permit. Licensing sits with the Real Estate Business and Pawnshop Regulator under the NBFSA.

What is the double title scam? +

The same property sold twice, once on soft title and once on hard title. The hard title wins. It persists because roughly 500,000 parcels remain unregistered as of 2026.

Which licence does a project need? +

More than 30 units or villas, or a lot above 10,000 square metres, needs a national licence. Three to 30 units needs a prior permit from the Capital-Provincial Department of Economy and Finance. A seller who cannot say which is a red flag.

Can I pay a deposit to an agent? +

No. Pay only into the named project account of the licensed developer. The deposit disappearance pattern relies entirely on a buyer paying a person rather than a project.

Do I need a lawyer? +

For anything above a small ticket, yes. Fees run $1,000 to $3,000, roughly 0.7% to 1.5% of value, and the lawyer must be independent rather than introduced by the seller.

What if it has already gone wrong? +

Preserve every record, obtain an independent national title search and instruct Cambodian counsel in the first week. Recovery generally runs through civil litigation.