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The gap comes as Phnom Penh prepares to host its major anti-scam conference on 23-24 September, part of the wider government campaign against online scam networks.

Initially framed as “Together Towards Disrupting the Chain and Ending Online Scams” by AKP in August, the conference now carries the theme “Acting Together towards Breaking the Chain and Eradication of Online Scams” on its official website. 

Prime Minister Hun Manet has publicly characterised the crackdown as an effort to “clean our house” and restore Cambodia’s reputation internationally.

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“In my experience, where compliance concerns can be satisfactorily addressed without suspending an operator’s licence, the Commission may allow the operator to implement remedial measures or an action plan while continuing to trade,” says Richard Williams, partner at Keystone Law, speaking before the news of the collapse of the businesses.

“The fact that suspension has been considered necessary in this case therefore indicates that the Commission presently considers the issues sufficiently significant to justify preventing the operators from continuing to offer gambling while its reviews are ongoing.”

For any consumer-facing businesses, a suspension is likely existential and such appears to have been the case here. But wider implications have to be considered before the two sites are binned forever.

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The ASA reviewed a clip posted to TikTok in July promoting Midnite, a Gibraltar-based online casino app. The clip displayed a young-looking man using the app, accompanied by the voiceover: “Another massive World Cup upset. Bet £10 on the big match and get £30 in free bets. Level up your World Cup with Midnite, get on it.”

According to the ASA’s Code for gambling advertising, anyone who “was, or seemed to be, under 25 years of age” must not be depicted gambling or playing a significant role in advertisements. 

The regulator concluded that the central figure’s youthful facial features, casual styling and excited demeanour gave the impression he was in his late teens or early twenties.