On December 9, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) both issued final rules adding export restrictions on Cambodia.

BIS amended the Export Administration Regulations (EAR) to implement more restrictive export controls for Cambodia to ensure that items subject to the EAR are not available to Cambodia’s military and military intelligence services without prior review by the U.S. Government, and also added Cambodia to the list of countries subject to a more stringent review policy for license applications involving national security-controlled items.

Specifically, BIS made four changes to the EAR restricting exports to Cambodia as follows:

(1) updating the controls applicable to Cambodia related to National Security-controlled items;

(2) making Cambodia subject to the Military End User (MEU) list;

(3) making Cambodia subject to the Military Intelligence End Use List (MIEU) list; and

(4) adding Cambodia to Country Group D:5.

DDTC amended § 126.1(d)(2) of the International Traffic in Arms Regulations (ITAR) to add Cambodia to the list of proscribed countries. This change institutes a policy of denial to licenses and approvals for exports of defense articles or defense services to Cambodia, see additional information at § 126.1(o).

These country policy amendments were made in response to serious concerns about the deepening influence of China’s military presence in Cambodia and a concern that this presence presents a threat to regional security. Additionally, the changes were made in response to credible evidence of growing corruption and human rights abuses by the Government of Cambodia.

The Federal Register notices are available here and here.