HOSTILE TAKEOVER JULY 2016 1

JULY 2016

CONTENTS
03 EXECUTIVE SUMMARY & KEY RECOMMENDATIONS
06 INTRODUCTION: CAMBODIA IS OPEN FOR BUSINESS
07 CAMBODIA CORPORATES AND THE POWER OF DATA
08 THE HUN FAMILY TREE
10
12
13
16

THE HUN FAMILY’S BUSINESS EMPIRE
THE HUN FAMILY’S DOMINANCE OF THE ENERGY SECTORA LOOK INSIDE HUN MANA’S INVESTMENT PORTFOLIOINFOGRAPHIC SHOWING FULL LIST OF COMPANIES

18 THE HUN FAMILY’S LINKS TO INTERNATIONAL BRANDS
19 THE RISKS FOR FOREIGN INVESTORS
20 A SINGLE HUN FAMILY RESPONSE TO GLOBAL WITNESS ALLEGATIONS
21
21
22
25

THE HUN FAMILY’S DISREGARD FOR THE LAWCASHING IN ON STATE RESOURCES
THE COST TO PEOPLE AND ENVIRONMENTTAKING ADVANTAGE OF PERSONAL IMPUNITY

26
26
27
28
28

THE HUN HEGEMONY – REINFORCING CONTROLPUBLIC OFFICE AND STATE SECURITY FORCESMARRIAGES TO CREATE ALLIANCESCHARITY ENDS AT HOMEMEDIA – OFFLINE AND ONLINE

30 CONCLUSION
31 RECOMMENDATIONS
33
33
38
38
41

ANNEXESANNEX 1 – OUR FINDINGS IN FULL
ANNEX 2 – METHODOLOGYANNEX 3 – THE LEGAL FRAMEWORK
ANNEX 4 – BREAKDOWN OF KEY FINDINGSHOSTILE TAKEOVER JULY 2016 3

EXECUTIVE SUMMARY1
I think that within two years
my assets will decrease, there
won’t be a gain. And besides
my salary I don’t have anyother income. But I think mychildren will support me, they
won’t let me starve. 2– Hun Sen, April 2011

Cambodian prime minister Hun Sen held his asset declaration
form up to the flashing cameras as he addressed a room full ofjournalists. It was April 2011 and for the first time ever, Hun Sen
was publicly declaring his assets to Cambodia’s newly installed
anti-corruption unit.3 Cambodia’s fledgling anti-corruption
law included an obligation on more than 25,000 Cambodian
officials to declare their assets every two years. Those who
failed to do so faced a maximum fine of US$500 and up to ayear spent in prison.4
This anti-corruption drive was long overdue. For many years
the country has languished at the bottom of Transparency
International’s Corruption Perceptions Index. Most recently, in
2015, it ranked 150th out of 168 countries - the lowest score in
Southeast Asia.5
But the figures on Hun Sen’s inaugural declaration werepuzzling. The prime minister’s salary, which he claimed as hissole source of income, was US$1,150 per month, amounting to
US$13,800 a year.6 Puzzling because the Hun family is renowned
as one of the richest, if not the richest, and most powerfulfamilies in Cambodia, with a combined wealth estimated byexperts to total between US$500 million and US$1 billion.7
Hostile Takeover helps solve that mystery. It is the firstever exposé to reveal how, behind the scenes of Hun Sen’s
dictatorial rein, his family is amassing vast personal fortunes,
tracing the contours of a huge network of secret deal-making,corruption and cronyism which is helping secure the prime
minister’s political fortress.
Hun Sen is the world’s sixth longest-serving premier having
been in power for 30 years, years that have been characterisedby electoral fraud and the brutal suppression of political
opposition, including through murder, torture and arbitrary
imprisonment.8 This report provides the evidence base to prove
what most Cambodians suspect – that Hun Sen has abused his

Cambodian journalists have been ordered to use Hun Sen’s full title intheir coverage, “Lord Prime Minister and Supreme Military Commander”.

position as prime minister to allow his relatives control of, or
major stakes in, most of Cambodia’s key industries.
Our investigators spent months mining data on company
ownership in Cambodia – information that the government has
recently restricted access to - that shows who owns or controls
private companies registered there. We then mapped thatdata onto the Hun family tree, to find that the prime minister’s
immediate family have registered business holdings that link
it to companies with a total listed share capital of more than
US$200 million, including links to international brands suchas Apple, Nokia, Visa, Unilever, Procter & Gamble and Honda.9
Their business holdings span many of Cambodia’s mostprofitable sectors, including those known to be riddled withcorruption such as mining, gambling and real estate.
This is undoubtedly just a fraction of the true value ofthe family’s holdings – the government data we mined
is limited in scope, and the Hun family is said to obscuretheir links to companies by listing the names of friends andassociates as nominee owners, or hiding their identity behindshell companies.

[In 2015, Hun Sen] used his control of
Cambodia’s security forces, courts, andcivil service to force the opposition leader
into exile, beat up opposition politicians, jailcritics, pass draconian laws, and increase theruling party’s stranglehold on the country’s
institutions. 10 – Human Rights Watch, January 2016

1 References for the points made in this section can be found in the main body of the report unless otherwise indicated.

4

The impact of the Hun family’s thumbprint on Cambodia’s
economy is more than just wealth and privilege. It is resulting
in hegemonic control that has formed a stranglehold over the
democratic space and corrupted the country’s legal system
which remains firmly under the control of Hun Sen. As a result,companies linked to the Hun family appear not to have beentroubled by anti-corruption laws preventing preferential
allocation of lucrative public contracts and concession licences.
These are not victimless crimes – some of their companies’
operations have driven devastating impacts for Cambodian
citizens and the environment, including land grabs that havecaused mass displacements and destitution among Cambodia’s
rural poor. Unrelated to their companies, individuals within thefamily have also allegedly committed serious criminal offenses
without facing prosecution. Over the years, family members
have been implicated in a US$1 billion heroin-smuggling
operation, shoot-outs and a fatal hit-and-run.
The prime minister’s relatives have also been instrumental
in helping secure his control through means other thantheir domination of the private sector. They hold key posts
across the state apparatus, including in politics, the military,
police, media, and charities – sectors that prop up Hun Sen’sCambodian People’s Party through propaganda, political
donations or brute force. Hun Manet, for example, the prime
minister’s eldest son and heir apparent, holds four notable
positions – he is deputy commander of the prime minister’s
bodyguard unit, deputy chairman of the Royal Cambodian
Armed Forces Joint Staff, deputy commander of the army
and commander of Cambodia’s counter-terrorism special
forces. Manet’s middle brother Manith is a Lieutenant Generalin the military and director of the Defence Ministry’s military
intelligence unit. Hun Sen’s two youngest children, Many andMaly, are each married to the offspring of one of the country’snine deputy prime ministers – just two examples of a plethoraof intermarriages between the prime minister’s immediatefamily and those of powerful elites. Hun Mana, Hun Sen’s eldest
daughter and the most prominent business tycoon in thefamily, is one of only two media moguls in Cambodia to own
outlets which broadcast across radio, TV and newspapers.
The results of the stranglehold that the Hun family and otherelites have over almost every aspect of society are plain to see
in today’s Cambodia. Despite overall economic growth, six
million Cambodians, 40% of the population, still live below
or close to the poverty line.11 Inequality is growing with thelifestyle gap between rich urban elites and the 80 percent of
Cambodian citizens still living in rural areas becoming evermore stark.12

Oligarchs are linked to ministers, police
chiefs to party power-brokers. Money
circulates within a nexus of political andeconomic connections in which allies are
not just friends – but family too. 13– Sebastian Strangio, Hun Sen’s Cambodia, 2014

This power base is also dependent on influxes of capitalfrom abroad. Our investigations revealed a plethora of links
between companies owned or controlled by the Hun family
and big international brands. These relationships not only raise
ethical questions for the brands, they also pose significant risk.
Companies and investors entering into any kind of businessarrangement with political elites or their family members, inan opaque business environment such as Cambodia’s, risk
breaking national and international anti-corruption laws, facing
financial penalties, and ultimately tarnishing their reputations.
Whether these links are via formal partnerships, franchising,supply chains, distribution deals or even loose client
relationships, international companies should not be doing
business with individuals or companies with a history ofcorruption allegations and human rights abuses. Those that doso have either failed to carry out the appropriate checks andbalances or are aware of the connections but have chosen
not to care.

KEY FINDINGS• Hun Sen’s immediate family14 has registered interests in

114 private domestic companies with listed capital ofmore than US$200 million. This figure excludes 16 of the
114 companies (14%) where data on company capital was
unavailable.15 A complete list of holdings can be found in
Annex 1 on page 33.

• 103 of these companies (90%) count the family member

as chairperson, director or as having a shareholding of morethan 25%, meaning that they exercise total or substantial
control.16 For a breakdown of this figure go to Annexes 1
and 4.

• O f the 44 companies for which we were able to obtainshareholder information, all shareholdings held byfamily members grant them significant ownership, with aminimum stake of 5%.17 For a breakdown of this figure go
to Annex 1.

• 3 0 companies (26%) with links to the family are listed as a‘Single Member Private Limited Company’ meaning thatthe entire share capital issued is held or owned by one
single person. Hun family members are listed as company
directors or chairs in all 30 of these cases, therefore it ishighly likely that a member of the family is the sole ownerof the majority, if not all, of these companies. 18 For abreakdown of this figure see Annex 4.

• C ompanies associated to the Hun family span the majority

of Cambodia’s most lucrative business sectors, including
trade, finance, energy and tourism. They also operate withina number of sectors notorious for corruption including
gambling, construction, agriculture and mining. For a full
sectorial breakdown see Figure 1 page 11.

• Companies linked to members of the Hun family havebusiness connections to major global brands including
Visa, Unilever, Procter & Gamble, Honda, Heineken andelectronics giants Apple, Canon and Nokia. For moredetails, see page 18.

HOSTILE TAKEOVER JULY 2016 5This is likely just the tip of the iceberg. Our investigation
relied almost exclusively on official government data from
Cambodia’s Ministry of Commerce company registry. This lists
company chairs but does not systematically provide complete
lists of directors or shareholders. More importantly, the findings
only reveal those business holdings that have been officiallydeclared. Family members, including Hun Sen, have long beenthought to conceal their interests in private companies by using
proxies, in other words getting non-family members to registerbusiness holdings in their name while the Hun family remains
the ultimate beneficiary.
In January 2016 Global Witness wrote to 25 members of the
Hun family, including the prime minister himself, asking fortheir response to the allegations made against them in thisreport. At the time of publishing, only one response had been
received from one of Hun Sen’s son-in-laws, Sok Puthyvuth,
which is featured on page 20. Global Witness also wrote to
the majority of the Cambodian companies and organisations
mentioned and received six responses which have been
included throughout the report.

Hun Sen and Bun Rany pose with four of their children and their spouses and Former
Thai Prime Minister Thaksin Shinawatra in 2009. © AP/Press Association Images

KEY RECOMMENDATIONS
For the full list of recommendations go to page 31.
Companies and investors should:• Conduct stringent due diligence to ascertain who is

involved in the investment. Where there is the involvementof business or political elites (including all Politically
Exposed Persons) with a history of corruption allegations,or their family members, do not proceed with theinvestment. Where this relates to an existing investment,
then exit the business relationship as soon as possible.
If evidence of involvement in corruption is uncovered
through the due diligence process then companies andinvestors should self-report the findings to all relevant
authorities that have legal jurisdiction.

International governments providing Cambodia
with financial aid and other types of assistance:• Ensure that all donor money to Cambodia is managed

transparently, does not end up in the pockets of elites, andis spent in a way which benefits the citizens of Cambodia.

• Warn home country investors about the high-risk of

becoming embroiled in corruption when investingin Cambodia. Advise them to conduct stringent due
diligence to ensure that they are not entering commercial
relationships with business or political elites with ahistory of corruption allegations or their family members.
Advise them that certain sectors, such as natural resource
extraction, are particularly high-risk and therefore should
be avoided.

• Publicly oppose the ongoing closing down of democratic
space including the clampdown on government critics
and the introduction of repressive legislation.

The Royal Government of Cambodia should:• Conduct thorough, independent and transparent

investigations into the allegations made in this report andprosecute those individuals and companies found to be
breaking Cambodian law. In particular, conduct a thoroughand transparent investigation into Prime Minister Hun Sen,and the members of his family named in this report, for thecrimes of illicit enrichment and the granting and receivingof unfair advantages over the allocation of state resources.

• Reform the Anti-Corruption Law so that it is fit for

purpose. In particular, add requirements for all public
officials and their family members to make publicdeclarations concerning their personal assets including
business holdings.

• Bring an end to the recent wave of repressive
actions including;		- Stopping the current surge in persecution of
government critics- Ensuring that repressive laws currently in the pipeline
do not pass in their current form and that similarly
repressive laws that have passed recently are repealed.
Members of the Hun family, including Prime Minister
Hun Sen, should;• Make full public declarations of their assets including

all existing connections to domestic and international
companies, whether those connections are formal
or informal.

6

CAMBODIA IS
OPEN FOR BUSINESS
It can be tempting to describe Cambodia’s fate under prime
minister Hun Sen as a descent into chaos. But despite all theviolence and abuse, this is not anarchy. It is the systematic
capture of an entire state and its resources by a profoundly
corrupt regime, which has clamped down on free speech andtrampled over those who stand in its way, often literally. Hostile
Takeover lays bare the economic dimensions of the Hun Sen
operation, and shows its stranglehold on almost every sectorof Cambodia’s political economy.
Formerly a commander in the Khmer Rouge, Hun Sen rose to
the premiership in 1985.19 Cambodians voted him out in the
UN-administered elections in 1993, but Hun Sen famously
refused to step down.20 Since then, each and every election in
Cambodia has been marred by violence or the promise of it.21
In 1997, in the run up to the general election, 16 people diedand more than 150 were wounded in a grenade attack involving
the prime minister’s bodyguard unit at a rally led by opposition
leader Sam Rainsy. Later that year, in the wake of the bloody
July coup in which Hun Sen ousted his co-prime minister, morethan 100 people – mainly royalist opposition party members were summarily executed. To date, none of these crimes havebeen properly investigated or prosecuted.22
Cambodia has long posed a dilemma to the international
community. The US, for example, happily imports its cheap
garments and invests in its economy - which markets itself on
its lax approach to regulation - and it is also the country’s third
biggest aid donor.23 But Hun Sen’s bleak human rights record
has sat uncomfortably on Washington’s diplomatic conscience,and had always disqualified the premier from an official
invitation to the US.

I think it’s quite remarkable that the UnitedStates is in fact Cambodia’s largest export
market, even though we have half the world
between our countries. And we will continue
to explore ways to deepen our trade andinvestment relationship, including by helping
to tackle corruption and exploring ways tostrengthen Cambodia’s legal institutions. 24– US Secretary of State John Kerry speaking to reporters
in Phnom Penh in January 2016
The second half of that approach appears to have beenforgotten. In early 2016, US President Barack Obama requested
Hun Sen’s presence at the US-ASEAN summit in California,
where talks focused on bolstering Washington’s trade links
with the Southeast Asian nations in attendance.25 Shortly
before, US Secretary of State John Kerry paid a preparatory
visit to the prime minister in Phnom Penh.26 Among several
requests that Hun Sen tabled were that the US increase imports
from Cambodia by eliminating quotas and import tariffs, that
US businesses increase investment in Cambodia, and that
Washington write-off some of Cambodia’s historic debts.27
It appears Hun Sen’s bold approach may pay off. Washington
is looking to shore up US influence in Southeast Asia as acounterbalance to Chinese dominance in the region, andCambodia - an old ally of China’s and a major destination for
Chinese investment - will be one of the most important markets
for those efforts.28 As a result, Hun Sen is not being treatedas a tyrant who should be held to account for the systematic
exploitation of Cambodia’s people and environment, but asa strategically important business partner whose corrupt
personal interests can align with US foreign policy.
This report shows that this approach is deeply flawed. It
undermines all attempts by the US and other governments topush Hun Sen’s regime to end their corrupt practices and masshuman rights violations. With aid still flowing in and investment
deals on the table, there is simply no motivation for the Hunfamily to stop their plunder. Hearing this message loud andclear, they continue to expand their private sector holdings,
enabling them to accumulate the wealth required to maintaintheir 30 year rule.29
The US and other governments that are key donors and trading
partners with Cambodia should be using their leverage toensure governance reforms that will halt the asset-stripping.
They should also be making companies that invest in Cambodia
aware of the significant legal, financial and reputational risks of
doing business in such a corrupt environment.

The US and Cambodian military come together for two
weeks every year to take part in joint training exercises.

Cambodians protest against the NGO law outside the Senate
in July 2015. Despite widespread domestic and international
opposition the law was passed a month later.

CAMBODIA CORPORATESAND THE POWER OF DATA
The Hun family has well-known links to some industries
and companies in Cambodia, but never before has anyone
attempted to map out the extent of their control of thecountry’s business sector. Using data taken from theCambodian Ministry of Commerce’s corporate registry, Global
Witness investigators were able to establish how the Hunfamily owns or part-controls companies with a total sharecapital of more than US$200 million.30 This is likely just the
tip of the iceberg given the layers of fake nominees, shellcompanies or non-disclosure supposedly used by Cambodia’s
political elite to obscure their commercial interests. 31 Amongthe companies that the Hun family control or part-own areseveral that have been accused of egregious social andenvironmental crimes, for example Khun Sea Import Export
which has been involved in land grabbing and forced evictions
and the Garuda Group which, according to local media, hasviolently suppressed garment workers’ protests.32
The Ministry of Commerce data that informed theinvestigation was once in the public domain, but in April
2015 the government restricted access to it.33 Before thisdate, it had been possible to conduct anonymous searcheson the ministry’s online corporate registry. This had enabledinvestigators and activists to access company ownership
information without being identified by the government, which
lessened the likelihood of them facing reprisals once they
published or acted upon their findings. However, users must
now register to obtain a log-in, enabling the government tomonitor who’s using their database and what they’re searchingfor.34 At a time when the prime minister is recruiting teamsof civil servants to trawl the internet for comments deemed
critical of government policy - a project which has resulted
in arrests, imprisonment and lawsuits - most people areunwilling to take the risk.35

The government’s intervention to impede access to company
ownership information is part of a far broader assault ontransparency and accountability in Cambodia. A recentlypassed NGO law allows the government to shut down or ban
any organisation that speaks out against its policies.36 The
2015 Law on Telecommunications grants the government
virtually unchecked spying powers and criminalises any
electronic communication that “may affect public order or
national insecurity.”37 Online control is further reinforced by thegovernment’s “Cyber War Team” which was created in October
2014 to “protect the government’s stance and prestige”.38
This suffocation of democratic freedoms is making it
increasingly hard for Cambodians to monitor and speakout about the corruption at the heart of their political andeconomic systems. This in turn rewards criminals with
impunity, matches power with privilege, and further widens
the gap between rich and poor.39 Many critics and political
opponents of Hun Sen have had to seek exile overseas.40
In an effort to offset this, Global Witness has transformed data
scraped from the Ministry of Commerce’s site into an online,
fully-searchable database hosted on our website. Launchedin tandem with this publication, our Cambodia Corporates
site allows journalists, investigators and NGOs to analyse who
owns, controls or has major stakes in companies in Cambodia
without fear of censorship, prosecution or worse.41
We hope that the database will also be used by companies andinvestors that are considering or already engaged in businesswith Cambodia. It should be used as a key starting point fordue diligence processes – enabling investors to gauge the levelof risk by seeing who they are getting into bed with. Without
this resource, they will struggle to determine who profits fromtheir investment, leaving them exposed to significant legal
and financial risk. More importantly, using the database will
help them to identify whether their investment is helping
fuel corruption, human rights abuses, social injustice orenvironmental crime and what damage it could do either
to ordinary people in Cambodia or their own reputation.

8

HOSTILE TAKEOVER JULY 2016 9

10THE HUN FAMILY’S
BUSINESS EMPIRE
Since Hun Sen assumed office as co-prime minister in 1993 hehas populated strategic posts in the government, the police,
military, parliament, courts and charitable sector with relatives
and friends to ensure full control of state apparatus.42 Over theyears these structures of patronage have extended into theprivate sector, with chairmanships, directorships and majority shareholdings ending up in the hands of family members
or cronies.43 This has created a closed circle of immense andever-growing wealth, bound together by strategic inter-marriages.44 However, this is not just about the accumulation of
personal wealth or specific links between Hun family members
and particular companies – the Hun family’s domination of
Cambodia’s public and private sectors has resulted in Hun Sen
have near-total control over the country.
The prime minister’s hold over the economy is due in part tothe fact that his family’s business holdings span such a wide
range of economic sectors - 20 in total.45
By far the largest number of companies controlled by the family
are trading companies, which make up around 15% of the total
with 17 companies.46 This is a sector that is rife with corruption.
In 2013 Cambodia’s imports and exports were valued at morethan US$18 billion.47 That same year, the anti-corruption group
Global Financial Integrity estimated that the country lost US$4
billion in illicit financial flows, US$3.86 billion of which was asa result of trade mis-invoicing.48 A form of money laundering,trade mis-invoicing happens when companies fraudulently
manipulate the price, quantity, or quality of a good or service
that is being imported or exported on documents submitted
to customs.49 Global Witness appeared to have uncovered one
such scam in 2015, when investigators were able to obtain
documents showing logging tycoon and close associate of
Hun Sen, Try Pheap, substantially changing the value oftimber being exported to Hong Kong apparently to avoid
customs duties.50
Cambodia’s natural resources sector is another favourite
recourse for the Hun family’s investments. We have establishedHun family holdings in a number of agricultural companies,
most notably in the rubber sector, which is Cambodia’s second
largest crop after rice.51 The family also has links to six mining
companies that hold licences for largely untapped projects in
at least five provinces.52 With extraction of Cambodia’s oil andminerals set to begin soon, it is a pivotal time for the country’s
burgeoning mining industry and those involved stand to makehuge profits.53 Global Witness exposés over the last 20 years
have also revealed the corruption, human rights abuses andenvironmental destruction at the heart of this sector, showing
how the country’s ruling elite has been able to plunder thecountry’s natural wealth with total impunity - first forests,
then oil, gas and mineral reserves, and most recently land
for agribusiness.54

Construction and real estate is now big business in Cambodia,
with investment in 2015 totaling US$3.34 billion – a 33%
increase from the previous year.55 The sector, in which the
Hun family has interests in seven companies, is reported to becorrupt with rich elites said to be able to pay off inspectors andtherefore ignore regulations.56
Cambodia’s media sector is highly concentrated in the hands ofpolitical and business elites, many of whom own private media
companies.57 The Hun family fully own two media companies –Bayon Media and Kampuchea Thmey – which enables them tobroadcast across TV, radio and print.58 In 2015, Freedom House
categorised Cambodia’s press environment as ‘Not Free’ stating“most outlets are openly aligned with a political faction, leaving
little space for balanced views and journalism conducted in the
public interest”. 59
Special Economic Zones - Members of the Hun family and theirassociates also dominate Cambodia’s Special Economic Zones(SEZ) – industrial parks largely devoted to manufacturing where
factories and workers’ accommodation stand side by side.60
Business and trade laws differ from the rest of the country,offering companies who invest in SEZs a number of fiscal perks
such as concessions on customs duties and VAT.61
Of the estimated US$12 billion worth of goods exported by
Cambodia in 2015, around 10% came from these special
zones.62 Companies applying to become zone developers,
thereby taking on the establishment and management of an
SEZ, first need approval from the Council for the Developmentof Cambodia, which is composed of senior government
ministers and chaired by Hun Sen himself.63 The Council
reviews investment applications and grants incentives,
giving its members enormous power over Cambodia’s
investment decisions.64
Cambodia currently has 34 approved SEZs which, unlike inmost other countries, are managed by private companies rather
than the government.65 Of the 31 SEZs for which information isavailable, at least 12 have been allocated to business tycoons
with close connections to the Hun family or the CPP.66 This
includes Dy Chendavy (also known as Hok Chendavy), Hun
Manith’s wife, and her mother, Men Pheakdey, who have thelicence to develop the US$52 million D & M (Bavet) SEZ Co’s
Special Economic Zone in Svay Rieng Province.67 NLC Import
Export, chaired by Hun Sen’s sister-in-law Leang Vouch Chheng,holds another SEZ in Svay Rieng Province which government
data lists as having capital of US$13 million.68
For a full list of the family’s business holdings see theinfographic on page 16 or Annex 1 on page 33.

HOSTILE TAKEOVER JULY 2016 11

Lining the pockets of the Hun Family
The corporate empire of Prime Minister Hun Sen’s family spansthe majority of Cambodia’s most lucrative business sectors. So
much so that residents of Phnom Penh might struggle to avoid
lining their pockets multiple times a day…

KEY
1. Hun Sen’s youngest
daughter chairs TK
Avenue, Phnom Penh’s
first luxury shopping mall.
2. Hun Mana hasinterests in K Thong
Huot Telecom, whichclaims to have exclusive
distribution rights
for Nokia phones in
Cambodia.
3. Hun Mana chairs
NVC Corporation whichmakes Vital bottled waterpromoted by the Ministryof Tourism for use in
official events.
4. His nephew is adirector of LHR Asean
Investment, which runs
a network of petrol
stations across thecountry.

5. Hun Sen’s eldest
daughter, Hun Mana,
owns newspaper
Kampuchea Thmey Daily,
which is read by almost
100,000 Cambodians.

FIGURE 1: What business sectors do companies affiliatedto the Hun family operate in?

6. His niece is the chairof Gloria Jean’s Coffees,
which has six stores in
Cambodia.

Trading
Finance
Hospitality and entertainment

7. Three of Hun Sen’s
children are listed asowners of company
Electricity Private - whichsells energy to the state.
8. Hun Mana owns
Bayon Media whichbroadcasts via three TV
stations and on Bayon
Radio, considered to be
pro-government.

Tourism
RetailConstruction and real estate
MiningEnergyMedia
Transport
Agriculture

SectorTelecomms
Gambling
Professional services (legal or tax advisors)

9. The wife of Hun Sen’s
nephew chairs iOne,
Cambodia’s leadingApple retailer.

Manufacturing
Security
Special Economic Zones
Garments
Forestry
Pharmaceuticals
Unknown
0

5

10

15

Number of companies in sector with links to the Hun family

20

25

12

THE HUN FAMILY’S DOMINANCE
OF THE ENERGY SECTOR
The Cambodian energy sector has also been fertile investment
ground for the Hun family. Cambodian electricity prices areamong the highest in the region and the world.69 In July 2015,
residents of the capital Phnom Penh complained after suffering
seemingly arbitrary price increases despite unchanged usage
patterns and frequent blackouts.70 In October of the same year,
Cambodians demanded lower petrol prices, noting that thecrude oil prices had plummeted globally from more than US$90
per barrel to US$50, yet the price of gas in Cambodia had fallen
only by 16%.71
Phnom Penh absorbs around 90% of the country’s electricity,whereas rural areas - home to around 80% of the population tend to lack access.72 This looks set to change. In 2013 Hun Sen
promised that all Cambodian villages would have electricity
by 2020, and 70% of households by 2030.73 Given this meteoric
expansion it is perhaps not surprising that the Hun family has
significant stakes in the country’s energy sector.
We were able to establish family links to five* energy
companies.74 Hun Maly’s husband, Sok Puthyvuth, is the chairof Soma Energy, which the Ministry of Commerce lists as having
a share capital of US$10 million.75 In 2012, the Soma Groupsigned an Memorandum of Understanding involving a US$3
million biomass power deal with US corporate giant General
Electric.76 This deal was the first project to be implemented
following General Electric’s 2011 Alternative Energy
Development Agreement with the Cambodian Government.77
Hun To, who was accused of being part of an international
drug-trafficking and money-laundering syndicate – allegations

he denied – is listed as the chair of oil company LHR
Asean Import Export and agent and director of LHR Asean
Investment.78 The latter runs a network of petrol stations
across Cambodia.79
Cambodia’s second largest domestic electricity supplier,Cambodia Electricity Private, is a joint venture between threeelite families - the Hun family, along with the relatives offeared late police chief Hok Lundy and Cambodia People’s
Party senator Ly Yong Phat.80 It runs the largest power stationnear Phnom Penh selling electricity to state energy provider
Electricite du Cambodge.81 The company is jointly-owned bythree of Hun Sen’s children - Hun Manith, Hun Mana and Hun
Maly – as well as Men Pheakdey, who is both Hok Lundy’s
widow and Hun Manith’s mother-in-law and two of senator
Ly Yong Phat’s relatives.82 Dy Vichea, Mana’s husband and
Hok Lundy’s son, was a shareholder in the company until heresigned in 2013.83 As a member of the military, Hun Manith’s
directorship of the company is illegal under Cambodian law.84
The Hun family also has links to petroleum company
Kampuchea Tela. Bun Rany was a shareholder until she
resigned on an undisclosed date.85 Moeung Kompheak, Hun
Mana’s ex-husband and son of the head of the Ministry of
Defense’s Department of Logistics and Finances, was director
general of the company before he divorced Mana.86 In 2004,
local media reported that Kampuchea Tela had signed a deal
to supply petroleum to the Ministries of Interior and Finance.87
It is unclear whether Bun Rany or Moeung Kompheak had
resigned their involvement with the company by this point.
In addition, the Ministry of Commerce lists Sok Puthyvuth as
the chairperson of ‘Tela E & P’.88 Absolutely no information
is publicly available on the company which led investigators
to speculate that it is part of, or at least connected to,Kampuchea Tela. Regardless, it has long been suggested that
Kampuchea Tela is a proxy of the Hun family and that the listed
shareholders are nothing more than ‘front men’ there
to conceal the involvement of the family.89

HUN SEN’S EVER-GROWING TITLE
Hun Sen’s official title has become longer as his
premiership has continued. Since 2007, he has been
officially known by the title “Samdech Akka Moha Sena
Padei Techo Hun Sen” which roughly translates as “Lord
Prime Minister and Supreme Military Commander”.
In May 2016, Associated Press reported that it had beencalled to a meeting by Cambodia’s Information Ministry
and instructed that all journalists must now use Hun Sen’s
full title in the opening lines of their coverage.90

In 2015 Hun Sen promoted his middle son, Hun Manith, tobe the director of Cambodia’s powerful military intelligence unit.

*The original version of this report stated that Jaya Holding Limited, a Cambodiancompany chaired by Hun Mana, was a subsidiary of a Singaporean company with asimilar name. Since publication it has been brought to our attention that there is infact no connection between the two companies.

HOSTILE TAKEOVER JULY 2016 13

A LOOK INSIDE HUN MANA’SINVESTMENT PORTFOLIO

Hun Mana and Dy Vichea.
Photo obtained from Hun
Mana’s Facebook page.

Hun Sen’s eldest daughter Hun Mana
has the largest number of businessholdings of any member of the family,
with interests in 22 companies withlisted share capital of more than
US$66 million.91 This figure is likely to
be significantly higher as it excludes
the capital of five companies for which
Global Witness was unable to findfinancial data.

For 18 of the 22 companies Mana is listed as chair or director,
giving her control over the companies’ decision-making. Her
business interests span many of Cambodia’s major sectors,
including energy, construction, tourism, financial services andgambling.92 She is currently looking to expand her business
empire and is applying huge pressure on domestic privatecompanies to grant her shares, according to a well-placedsource in Cambodia.93
MEDIA: Mana is one of only two media moguls in Cambodia tohave holdings across radio, TV and newspapers.94 She chairs
and owns 100% of the shares of media company Bayon Media
Hight System.95 The company broadcasts via three TV stations– Bayon TV, BTV News and ETV – and also runs Bayon Radio
which is considered to be one of the leading mouthpieces of

the Cambodia People’s Party (CPP).96 According to information
obtained by Global Witness in 2010, as part of the Cambodian
government’s scheme known as the ‘culture of sharing’ underwhich private companies sponsor military units, Bayon TV andRadio sponsors two army battalions.97 Mana also chairs andfully owns the newspaper Kampuchea Thmey Daily, which isone of Cambodia’s most read Khmer-language newspapers
and is also known to be pro-CPP.98 Mana also chairs marketingand event management company Bayon CM Organizer which
she jointly owns with Thailand’s CMO Group.99 Mana is thecompany’s chair and also holds 25% of its shares.100
ADVERTISING: Mana chairs Moon Media which specialises
in outdoor advertising and is behind a large proportionof the billboards and large format ads you see around thecountry.101 The company’s client list extends to a number of big
international brands such as Visa, Unilever, Procter & Gamble,
Honda and Mango.102 It also counts Mana’s sister, Hun Maly, asa director and shareholder.103
TOURISM: She is a shareholder in the The Museum Company
Ltd which manages the Angkor National Museum in Siem
Reap and is listed by the Ministry of Commerce as having
capital of US$2.5 million.104 The museum showcases many of
Cambodia’s most precious artefacts taken from Angkor’s vast
network of ancient temples and, each year, a large proportionof Siem Reap’s one million visitors pay the US$12 entry fee.105
Mana also chairs the MLM Resort Group for which no further
information is available.106

Here is an overview of some of the international and domestic
companies that Hun Mana has interests in or is affiliated to:14

Moon Media is chaired by Hun Mana and boasts an impressive client list including Visa, Unilever and Tiger Beer.

AVIATION: Mana is listed as chair of three Cambodianregistered aviation companies – Helistar, Star Aviation andStar Airline.107 No information is available for the latter two,but Helistar is best known for tourist flights around the
Angkor temples which cost up to US$5,000.108 Flying out ofmilitary air force bases in Phnom Penh and Siem Reap, thecompany also specialises in chartered helicopter flights forgovernment officials, VIPs, agricultural concession surveys
and mining exploration.109
MANUFACTURING: NVC Corporation, of which Mana is chair, isa food and beverage manufacturer that makes Vital Premium
Water, one of the Cambodia’s leading bottled water brands.110
Vital Water’s website states that it “…is the only national
product that was accepted as an official partner for use in
the Asian Tourism Forum in 2011 in Cambodia. The Ministryof Tourism also recommends its use officially for any national
and internal ceremonies”.111 The company shares a registeredaddress with more than 30 companies belonging to powerful
CPP senator Lao Meng Khin, his wife Choeung Sopheap (alsoknown as Yeay Phu) and their family members.112 The couple
own companies Shukaku Inc. and Pheapimex that have been

responsible for widespread illegal logging and land grabs,
which have displaced thousands of people.113
FINANCE: Mana has interests at least two companies in thefinance sector. She is a director and shareholder in RoyalGroup Investment Company, which is chaired by Kith Meng,
arguably Cambodia’s most prominent business tycoon withextensive interests in banking, agriculture, hydropower,
media, real estate and telecoms and known for involvement
in land grabbing and illegal logging.114 Mana is also listedby the Ministry of Commerce data as the ‘representative’ of
NH Holding which appears to be affiliated to the ‘5 Siblings’
construction firm that is linked to the family of CPP senator
Lao Meng Khin.115 She also chairs registered companies Ocasis
Cambo Investment Group and Ocasis Cambo Investment
whose names suggest may also be in the finance sector. 116
TELECOMS: Through NH Holding, Mana has a six percent
shareholding in Viettel (Cambodia) which owns Cambodia’s
largest mobile phone provider Metfone.117 Viettel (Cambodia)
is part of Vietnam’s largest mobile network operator, the Viettel
Group, which is a fully state-owned enterprise operated by thecountry’s Ministry of Defence.118 Joining Mana as a shareholder

HOSTILE TAKEOVER JULY 2016 15

in Viettel (Cambodia), and adding to the company’s links to
the military, is Tao Toeun, the wife of Cambodia’s National
Defense Minister General Tea Banh.119 In 2010, Hun Sen
publicly endorsed Metfone and advised all Cambodiansoldiers to use the company.120 Also in telecoms, Mana
appears to be affiliated to the Dragon Royal Group via her
chairmanship of its telecommunications arm, Dragon Royal
Telecom which lists share capital of US$2 million.121 The
Group owns a luxury hotel and condominium in Siem Reap
and has plans to expand into pharmaceuticals, property,
petroleum and other natural resources.122 Mana is alsoa director and shareholder of K Thong Huot Telecom,
which was founded in 2002 to distribute Nokia phones in
Cambodia.123 The firm is also the local business partner ofLenovo-IBM, and holds exclusive distribution licences for
Pioneer and Electrolux products.124

A forest patrol unit using a helicopter belonging to Helistar,
which is chaired by Hun Mana. Photo obtained from the
Wildlife Alliance’s Facebook page in March 2016.

ENERGY: Along with three other members of her family andtwo of senator Ly Yong Phat’s relatives, Mana is a directorof and shareholder in Cambodia Electricity Private,
Cambodia’s second largest domestic electricity supplier.125
Ly Yong Phat and his wife, Kim Heang are infamous forowning sugar companies which have committed humanrights abuses, including violent forced evictions andland grabbing, child labour, and the use of the military tointimidate villagers.126 In a letter to Global Witness dated 25th
January 2016, Yong Phat and Heang denied all allegations
made in this report against both them and their companies,
the LYP Group and Kampong Speu Sugar.
CONSTRUCTION: Mana chairs company NVN Corporation,
which appears to be in the construction sector and lists
capital of US$0.5 million. She also has interests in the sector
via NH Holding.127 Both companies appear to have strong
links to the family of CPP senator Lao Meng Khin.128 Mana
also chairs Orkidé Villa 3.129 The Ministry of Commerce
lists a similarly-named company, Orkidé Villa, chaired bytycoon Khieu Sar Sileap who has multiple business links
to associates of the Hun family.130 Both companies areregistered to the same address.131 In November 2015,
local media described Orkide Villas as one of Cambodia’s“fastest-growing developers” after Sileap announced
publicly that the company will be building a US$350 million
condominium and mall project that will cover a 36-hectare
area of Phnom Penh.132
In January 2016, Global Witness contacted Hun Mana andthe other people and companies mentioned in this chapter,
except for Moeung Kompheak who was unreachable. In ourletters we requested comments in response to the evidence
detailed above. Only Sok Puthyvuth replied. His email isoutlined on page 20.

Child working on a sugar plantation owned by special economic
advisor to Hun Sen and powerful CPP senator, Ly Yong Phat.

A POLITICAL DYNASTY OF OKNHAS
Traditionally supposed to be reserved for those who
contribute to the public good, the “oknha” title is now
bestowed on business people who make donations ofat least US$100,000 to Hun Sen’s party. In return they
increase their chances of securing lucrative government
contracts or licences to extract natural resources. By 2014
there were at least 700 oknhas, compared to just 20 a
decade earlier.133 This highlights the increasingly blurredlines between the state and private sector as well as the
rapid expansion of Hun Sen’s patronage network. Manyoknhas are implicated in violating human rights andcausing environmental destruction with impunity.
Global Witness urges the Cambodian government tostrip those found to be violating Cambodian laws orinternational human rights standard of the honorific title‘oknha and bring an end to the system under which thetitle is granted in return for a US$100,000 donation.

16

HOSTILE TAKEOVER JULY 2016 17

AFFILIATED TO• NVC Corporation• Ocasis Cambo
Investment Group Co• Ocasis Cambo
Investment Co• Star Aviation (Cambodia)• Star Airline (Cambodia)• Helistar (Cambodia)• Moon Media (listed as
Moon Advertising by
the MoC)• Bayon Media Hight
System Co• Bayon CM Organizer Co• Jaya Holding Ltd

The infographic below shows all of the Cambodian companies that members of the Hun family have interests in,as revealed when researching Hostile Takeover. For more detail on their holdings see Annex 1 on page 33.
AFFILIATED TO• TK Avenue• Cambodia
Electricity Private• (Cambodian) Food
Industries Co• Decampharma• Moon Media (listed as
Moon Advertising by
the MoC)• Stone Grill

AFFILIATED TO• Soma Group• Soma Energy• Soma Ever Green• Soma Kova Holding• Tela E&P• Soma Construction& Development• Phnom Penh Boat
Ride Co

AFFILIATED TO• G Gear Co• Khmer Latex Co• CMN Star Investment• Lady Cosmetic International
Corporation• Zenoteq Solutions Co• Legend Cinema Co• PMV Entertainment Co• Brands Management Ltd

PICH CHANMONYSOK PUTHYVUTHMARRIED TO

HUN MANETMARRIED TO

AFFILIATED TO• Decampharma• YLL Resorts Co• Machhoem Bopea
Trading Group Co• Phu Yang Ltd• Paradis Ltd• Sovannaphum Mine
Exploration &Development Co

YIM CHHAY LIN

AFFILIATED TO• Khun Sea Import
Export Co

BROTHER

AFFILIATED TO• Cambodia
Electricity
PrivateAFFILIATED TO•D & M
(Bavet) SEZ
Co’s Special
Economic Zone

• Dragon Royal Telecom• Kampuchea Thmey
Daily Co
• NVN Corporation Co• MLM Resort Group Co• K Thong Huot Telecom• NH Holding• Viettel (Cambodia) PTE• Royal Group Investment
Company• The Museum Company• Vina (HK)• Cambodia Electricity
Private• Orkide Villa 3

AFFILIATED TO• Dy Corp• Emperor Group• VC Group• Poseidon Co Ltd(listed as ‘Poseldon’by the MoC)

AFFILIATED TO• D & M (Bavet)
SEZ Co• CVI Resorts• CVI Land
• Cambodia
Electricity Private

YIM LEANGMARRIED TO

DY VICHEA

HUN MANYMARRIED TO

MEN PHEAKDEY

MOTHER TO

HUN MALY
HUN MANACHILDRENBUN RANYAFFILIATED TO• Pich Sambath
Import Export
Co.
• C Pimex Co.

HUN MANITH
DIVORCEDFROMMARRIED TOMARRIED TO

DY/HOK CHENDAVYDY CHOUCH
DIVORCEDFROMSENG KENG

COUSINSAFFILIATED TO• D & M (Bavet)
SEZ CoHUN SEN
HUN SENG NY

HUN SANCHILDREN

AFFILIATED TO•R ith Mony
Samnang Leap Co•S
 eng Kheang
Apivath Co•G rand HarvestInternational(GHI)

BROTHERS& SISTERSHUN NENG

HUN KIMLENG

THAI JACKIETAI HIEN
AFFILIATED TO• Hun Chea Transport Co.
• CHSN Transportation Co.
• CHLK Trading Co.
• (Cambodian) HC TradingCo.
• PSZ Trading

AFFILIATED TO• HML Xat Consulting• Eastern (Cambodia)
International Investment• F & B Life Style Investment• Gloria Jean’s Coffees (Cambodia)• HD Rock Café & Shop
• HKLCH Import Export• HML Consulting• Worldwide Investment Group• Worldwide Investment
Incorporation• Kam Chin International
Cooperation GroupHUN CHANTHAHUN SEANG HENG

HUN TOMARRIED TO

AFFILIATED TO• Metal Mining• D.G.F.
(Cambodia) PLC(Cambodia) Co.
• Rong De Group• Garuda Import• UNT Wholesale Co
Export• Attwood(Garuda Group)
Investment Group• Hatti Marketing Co • SL Garments• Hovercraft HiTec• HLH Agriculture(Cambodia) Co• Garuda Security• Metal Mining
Services(Cambodia) Co(Garuda Group)

LEANG VOUCH CHHENG

CHILDREN

HUN
CHANTHOU

HUN CHEAMARRIED TO

AFFILIATED TO• Heritage
Investment
Corporation
Co.

AFFILIATED TO• HTK Co
• HTTK Co.
• Gold Quest• LHR Asean
Import Export Co• LHR Asean
Investment Co

AFFILIATED TO• Camcorp
Capital Group• Camcorp
Capital Investment Group• Camcorp
CapitalInvestment Ltd

MARRIED TO

SOK SOPHEAK
AFFILIATED TO• iOne Co• Cemtes(Cambodia) PTE• Mtesh Gadgets Co• AFZ Co• Security
Services Asia

AFFILIATED TO• NLC Import Export• Pacifica Investment
Co. (listed as
Ppcifica Investment
Co. by the MoC)

AFFILIATED TO• Fortress Group• Fortress Travel Agency• Fortress Construction Co• Fortress Investment
Company International• Advance Development
Group (ADG) Co• SPK 1• SPK Group• SID Cambodian Co• Cambodian Top
Investment (CTI)• Gold 999 99• Tourism (Cambodia) Co.
• (Cambodian) International
Franchise Co.

18

THE HUN FAMILY’S LINKSTO INTERNATIONAL BRANDS
Cambodia has experienced rapid economic growth for the
past two decades and increasing numbers of international
companies and investors have flocked to enter the market,
enticed in part by Cambodia’s minimal regulatory red tapeand its cheap labour force.134 In 2015, the UK was the secondlargest foreign investor in Cambodia after China.135 The US is
Cambodia’s largest trading partner and export market, andtrade between the two countries totals around US$3 billion ayear.136 The two countries are currently negotiating a Bilateral
Investment Treaty with the aim of spurring additional US
investment in-country.137
The Hun family are major gatekeepers to this influx of foreign
capital into Cambodia, and have managed to establish business
relationships with numerous big global brands. These links
include formal partnerships, franchising, exclusive distribution
deals and client relationships. These international companies
are clearly either unaware of or unconcerned by their choice ofbusiness partners, whose family relationship to Hun Sen shouldraise red flags regarding the potential risk of corruption.
Below are the Hun family links to international brands
that Global Witness was able to identify, it is likely many
more exist.
Sok Sopheak, the wife of Hun Sen’s nephew Hun Seang Heng,is linked to two global electronics giants. She chairs iOne,
Cambodia’s leading Apple retailer, and also chairs Cemtes,

a company whose website suggests it is Cambodia’s ‘Authorised
Agent’ for Canon products.138 Pich Chanmony, Hun Manet’s
wife, chairs G Gear, which is the exclusive Cambodian supplierand retailer of products made by South Korean multinational
LG Electronics.139
Also in electronics, Hun Mana is director and shareholder of
K Thong Huot Telecom, a partner of computer manufacturer
Lenovo-IBM which claims to have exclusive distribution
rights for Electrolux and Pioneer products in Cambodia andNokia Mobile in Cambodia and Laos.140 Nokia was acquired byMicrosoft in 2014.141
Hun Mana chairs Moon Media, of which her younger sister
Hun Maly is a shareholder.142 Listed as ‘Moon Advertising’,
the company specialises in outdoor marketing and boasts aclient list which includes international big names such as Visa,
Unilever, Procter & Gamble, Honda, Mango, and Tiger beer.143
Hun Maly meanwhile is the chair of TK Avenue, a high-end
shopping mall in Phnom Penh.144 It houses shops including
Mango, Zara and Adidas, the Singaporean chain Guardian
Pharmacy, Aussino furniture, Shiseido cosmetics, Pedro
Footwear and Accessories and Samsung.145
Her husband, Sok Puthyvuth, is the CEO of the Soma Group.146
In 2012, Soma Energy signed a US$3 million biomass power
deal with US conglomerate General Electric (GE).147 Forbes lists
GE as the world’s tenth most valuable brand and puts theirannual sales at US$122 billion.148
Hun Sen’s niece, Hun Kimleng, can also claim strong links
to international brands. She is chairperson of Gloria Jean’s

2009 opening of the Phnom Penh iOne store, Cambodia’s first Apple retailer. iOne is chaired by Hun Sen’s niece.

HOSTILE TAKEOVER JULY 2016 19

Hun Kimleng. Photo obtained
from the Prae Legal website.

Coffees Cambodia, and is listed as
the chair, board director and 75%
shareholder of Hard Rock Café’sCambodia branch.149 Kimleng’s
conglomerate Worldwide Investment
Group boasts on its website of having
helped bring to Cambodia Japanesefood chain Yoshinoya, and the luxury
Emperors of China Restaurant.150

Pich Chanmony, Hun Manet’s wife, who is listed as chairof seven companies by the Ministry of Commerce, is also a
director and shareholder of food and beverage franchisecompany Brands Management.151 The company has so far
brought Taiwanese bubble tea company Chatime, Malaysia’s
myBurgerLab, and Thailand’s Boat Noodle to Cambodia.152 Its
website lists its partners as including Heineken Beer as well
as a number of companies associated to the Hun family.153
Chanmony is also listed as the chair of Legend Cinema, thefirst theatre to secure the rights to screen big Hollywood
blockbusters in Cambodia. 154
Hun Seny Ny, the prime minister’s younger sister, chairs UNT
Wholesale.155 The company imports a range of big-brandproducts into Cambodia including Durex condoms, NescaféGold coffee and Nestlé ice cream.156 She is also a 50 per centshareholder in Attwood Investment Group which is closely
linked to Attwood Import Export, the largest distributor ofhigh-end alcoholic beverages in Cambodia.157 Attwood Import
Export brings in an array of internationally-branded alcohol
into Cambodia and has exclusive distribution rights forJohnnie Walker, Hennessey and Corona beer.158
Seng Keang, the ex-wife of Hun Sen’s cousin Dy Chouch andclose associate to Bun Rany, is listed as the chair of garment
manufacturer Grand Harvest International, an affiliate of Hong
Kong-based GHI Enterprise Ltd which manufactures garments
for some of the world’s leading brands, including Tommy
Hilfiger, Polo Ralph Lauren, All Saints, Armani Exchange,
Forever 21 and Fred Perry.159
Hun Many’s wife, Yim Chhay Lin, meanwhile chairs
Decampharma, which is listed as having share capital of
US$50,000.160 Her sister-in-law Hun Maly holds 10% sharesin the company, while Danish pharmaceutical company
Missionpharma holds 35%.161 Missionpharma is a “grade A”
pharmaceutical wholesaler for projects financed by the US
government’s development arm USAID.162
Global Witness wrote to Missionpharma in December 2015.
The company responded on 26th January 2016 and confirmed
the shareholding, but stated that Decampharma is currently
inactive. The company also stated that it does not supply USAID
directly but instead supplies projects in Africa run by different
implementing partners under USAID funding. Missionpharma
has no funded activities in Cambodia.

THE RISKS FOR FOREIGN INVESTORS
Beyond the ethical considerations that foreign investors
should weigh up when considering a commercial relationshipwith the Hun family, conducting business with them or otherCambodian elites can also present a number of serious legal,financial and reputational risks. Due to a lack of transparency
and pervasive corruption, all business transactions involving
the Cambodian government, including public procurement,
infrastructure contracts and natural resource allocation,
present heightened risk for foreign investors.163 Companies
considering a deal which in any way involves the state should
conduct enhanced due diligence to ensure it’s free from the riskof corruption.
In terms of the domestic legal framework, Cambodia’s 2010
Anti-Corruption Law makes illegal any act that knowingly
benefits from corruption.164 Any international company which
exploits its relationship to the Hun family to procure deals
involving state resources or infrastructure could theoreticallybe vulnerable to criminal charges for benefitting from
corruption and patronage. Either this is happening with theirknowledge, in which case they could face a prison sentence
and a fine, or they urgently need to improve their due diligenceprocedures to ensure they understand who they are doing
business with.165
Companies should not bank on the Cambodian government’s
habit of breaking or ignoring its own laws in this regard,
either. Foreign investors also risk falling foul of powerful anticorruption legislation in other jurisdictions such as the UK and
US. The 1977 US Foreign Corrupt Practices Act (FCPA) prohibits“offering to pay, paying, promising to pay, or authorizing thepayment of money or anything of value to a foreign official
in order to influence any act or decision of the foreign official
in his or her official capacity or to secure any other improper
advantage in order to obtain or retain business”.166 It also
prohibits a company from making a corrupt payment to aforeign official through a third party or intermediary.167 Theseanti-bribery provisions apply to US persons and businesses,
but also to any company that is listed on US stock exchanges
or required to file periodic reports with the Securities Exchange
Commission (SEC).168 They can also be extended to cover any
transaction conducted in US dollars.169 This puts investors
in Cambodia at particular risk since the US dollar is the only
currency used for non-local business transactions in
the country.
Meanwhile the 2010 UK Bribery Act applies to UK nationals or
residents, as well as organisations that were either establishedin the UK or conduct at least some part of their business in the
UK.172 It prohibits a person from offering, promising, or giving a“financial or other advantage to another person” and applies toboth the public and private sectors.171 Like the FCPA, the
UK Bribery Act also extends to cover corrupt practices bya third party.172

20

Similarly, under Australia’s 1995 Criminal Code it is an offence
to provide or offer to someone (directly or indirectly) a benefit
that is not legitimately due to that person with the intention of
influencing a foreign public official in the exercise of their duties
in order to obtain or retain business or a business advantage.173
Australian authorities can prosecute companies andindividuals for such offences provided a sufficient connection
can be established between the entity under investigation
and Australia – namely either the offence was committed inAustralia or by an Australian citizen or corporation.174
Along with 38 other countries, the UK, US and Australia
are signatories of the 1997 Anti-Bribery Convention of theOrganisation for Economic Co-operation and Development(OECD), which also presents risks for investors.175 The
Convention establishes legally-binding standards for states tocriminalise the bribery of foreign public officials in international
business transactions.176 Under the Convention, all 32 member
countries of the OECD – which in addition to the UK, US andAustralia also include major Cambodian investors Japan,
Korea and Canada – are required to prosecute its nationals
for offences committed abroad.177
These risks are very real, as recent history shows. In March
2016, the CEO of Australia’s main stock exchange was forced
to resign over allegations that a gambling company he once
managed had bribed the Hun family several years ago.178
Australian company BHP Billiton was found to have made apayment to the Cambodian government in 2013 in exchange formining exploration rights in a deal that was allegedly overseen
by Hun Sen himself.179 In a letter to Global Witness in 2008, thecompany confirmed having paid the government US$1 million,
but stated that it was a formal transaction in accordance withthe terms of the mineral exploration agreement. Despite theirdenials, these allegations against BHP Billiton, among others,
led to an investigation by both the US Securities Exchange
Commission (SEC) and the Department of Justice, and thecompany eventually agreed to pay a US$25 million penalty to
the SEC for violating the FCPA.180 This is a stark illustration of

the major legal risks around corruption that extend beyond a
company’s own jurisdiction or where they operate.

American investors are generally reluctant
to resort to the Cambodian judicial system
to resolve commercial disputes because
the courts are perceived as unreliable andsusceptible to external political influence orbribery. Both local and foreign businesses
report frequent problems with inconsistentjudicial rulings, corruption, and difficulty
enforcing judgments. For these reasons,most commercial disputes are currently
resolved through negotiations facilitatedby the Ministry of Commerce, the Council
for the Development of Cambodia, theCambodian Chamber of Commerce, andother concerned institutions*. 181– US State Department’s ‘2013 Investment Climate
Statement for Cambodia’*It should be noted that all three institutions listed by the
US State Department for resolving commercial disputes areunder the control or influence of Hun Sen. As prime minister hecontrols the Ministry of Commerce, he chairs the Council for theDevelopment of Cambodia and his close business associate andpersonal friend, Kith Meng, is the president of the Cambodia
Chamber of Commerce.182 This means that the very institutions
supposedly conducting commercial dispute resolution in theabsence of a functioning judiciary are controlled by corrupt elites
and cannot be relied upon to be independent.

• F or many years, my family has• I hope that my activities and
A SINGLE HUN FAMILY
objectedtomytaking
a
role
at
the
our group can help support the
RESPONSE TO GLOBAL
governmental level. So I have chosenof Cambodia in someWITNESS ALLEGATIONS the private sector to test my ability to development
way or form. With more human
In January 2016, Global Witness wrote
to all 27 members of the Hun family
mentioned in this report including
the prime minister. Only Hun Maly’s
husband, Sok Puthyvuth, responded,with a long email dated 8th February.
Here are some excerpts:• “I see many issues and many obvious
solutions, but I have seen again andagain that the good solutions are
seldom implemented correctly…

build an effective organization.

• I can understand your assumptionthat I have abused my power to get towhere I am today, but I can assure youthat I take seriously the challenge ofbuilding a responsible and respectedprivate sector group. I admit it is awork in progress.

• I understand that I live in the shadowsof my family.

resource capacity and stronger
institutions, I hope we can speed up
the process of healing and help makeCambodia a model country that will
positively contribute to the global
community in the future.

• Once again thank you for yourinterest in Cambodia. I look forward
to see real understanding and thepositive impact from the work of
Global Witness to help my country,
the international community, andthe world.”

HOSTILE TAKEOVER JULY 2016 21

THE HUN FAMILY’SDISREGARD FOR THE LAW
One of the key themes to characterise the Hun kleptocracy
is impunity.183 Cambodia’s judiciary is firmly under the prime
minister’s control, lent on to protect his family’s interests byignoring their legal infractions and criminalising their critics.184
As a result, family members and the companies they areaffiliated to have routinely broken the law seemingly without
fear of prosecution. At best this has may have shielded the
Hun family from facing the consequences of petty crimes orbad behaviour.185 At worst, forced evictions in which wholecommunities have faced being uprooted from their homes orrobbed of their farmland or forests have gone unpunished.186
This chapter provides examples of some of the key ways inwhich members of the Hun family, and the companies linked
to them, have been able to get away with breaking a range ofCambodian laws including anti-corruption provisions as wellas those designed to protect human rights, social justice andthe environment.

CASHING IN ON STATE RESOURCES

Polling by the International Republican
Institute and USAID across all 24 Cambodian
provinces in 2013 found that “morecorruption” and “nepotism” were two of
the three top reasons respondents gave
as to why the country was headed in the“wrong direction.” 188
The Hun family is Cambodia’s prime example of a culture ofnepotism enjoyed by its privileged elite, in which politicalallegiance opens doors on to vast wealth.189 For decades, thissmall group has helped itself to huge chunks of Cambodia’sland, forests, and other natural resources, without facing hardquestions from the country’s aid donors or business partners.
With few natural assets left to plunder, Hostile Takeover shows
how the elite has diversified and expanded its corrupt model tothe rest of the Cambodian economy.
This investigation has uncovered numerous examples ofwhere companies linked to members of the Hun family havemanaged to secure lucrative public contracts and state
concession licences. Given Hun Sen’s history of corruption andthe lack of transparency in Cambodia’s opaque public sector,
this pattern should raise serious alarm bells. It suggests that
his family members could have received special treatment in
the allocation of state resources. This is despite the fact that
Cambodia’s Criminal Code and 2010 Anti-Corruption Law
criminalise the granting of unfair advantages or preferential
treatment by the state in return for any kind of donation,
gift or promise.190

Members of Hun Sen’s thousands-strong bodyguard unit which functions
as his private army and is central to maintaining his grip on power.

The judiciary in Cambodia is corrupt anddeteriorating, making it virtually useless asa tool for ordinary people to secure redress.
Authorities and well-connected elites alsofrequently abuse the court system, using
criminal charges as a tool to intimidate,harass and demobilize human rights activists.
Meanwhile, for many real crimes, impunity
reigns: People of wealth and influence
pay their way out of police custody andthe courts. 187– Licadho, a leading Cambodian human rights NGO

Members of the Hun family need to provide evidence toshow that these state resources have been allocated to theircompanies in a way which is legal and free from corruption.
Unless otherwise explained, the examples below would
certainly seem to be grounds to suspect grand corruption:• Members of the family and their business associates havebeen granted numerous concessions in the natural resource
sector, including licences for mining projects in at least
five provinces, a sand dredging licence for a four-kilometre
stretch of the Mekong River, and at least three Economic Land
Concessions for agriculture.191• Construction firm Soma Construction & Development, which
is chaired by Hun Sen’s son-in-law Sok Puthyvuth, has thecontract to build the office of Cambodia’s State Secretariat
of Civil Aviation and is part of the US$100 million project toexpand Phnom Penh airport.192

22• Of the 31 Special Economic Zones (SEZs) which Global

Witness was able to obtain ownership information for (out ofa total of 34), 2 have been allocated to companies belonging
to members of the Hun family. Authorisation for at least an
additional ten has been granted to business tycoons withlinks to family members.193• Cambodia’s second-largest domestic energy supplier,Cambodia Electricity Private, is part-owned by Hun Mana,
Hun Manith and Hun Maly. It sells electricity to state energy
provider Electricité du Cambodge, representing a serious
conflict of interest.194• The government granted the licence to operate Le Macau

Casino to Vina (HK), a company that is chaired by Kim
Heang, wife of senator Ly Yong Phat, and counts Hun Mana
as a shareholder.195 In a letter to Global Witness dated 25th
January 2016, Heang denied benefitting from a system ofpatronage that is headed by Hun Sen and which amounts to
grand corruption.

• The Ministry of Tourism recommends that Vital Water madeby NVC Corporation, which Hun Mana chairs, is used in
all national and internal ceremonies.196 According to thecompany’s website, Vital Water was the only national productthat was accepted as an official partner for use in the AsianTourism Forum in 2011 in Cambodia.197• Hun Kimleng’s HML Law Firm & Consultants boasts on its• Hun Sen’s eldest daughter Hun Mana
was director of and shareholder in
Chinese company WS Mining Industry
Holdings from 2009 to 2012.201

In 2008 the company was granted a
97,000-hectare exploration licence (anarea roughly the size of the German
Hun Mana. Photo obtained
capital Berlin) on Kuy indigenous
from her Facebook page.
land in northern Cambodia, where
communities subsisted largely from artisanal mining, smallscale agriculture and collecting non-timber forest products.202
Once the company’s mining exploration began, thesecommunities were forced away from the natural resources
which had sustained them for generations, eliminating amajor source of their livelihood and pushing them deeper
into poverty.203 The military was drafted in to guard WS Mining
operations, with soldiers from Hun Sen’s Bodyguard Unit
allegedly in charge of security.204 Soldiers cordoned off accessto many of the community’s rice paddy fields, and cyanide wasused to leach gold from the ground, illegally contaminating
the water supply. Many people reportedly fell ill and muchof their livestock died.205 In contravention of Cambodian law,
local authorities say that the company brought in workers from
China rather than hiring locals to work at the mine.206
 un Mana cut ties with WS Mining in 2012, but these problems
H
have still not been resolved.207

website that it is “particularly well-positioned to ensure good
cooperation and results” from lobbying government ministries
and offices.198 In particular, the company claims to deliver
results when dealing with the Council for the Development of
Cambodia, Cambodia’s highest government body overseeing
investment which is chaired by Hun Sen himself.199• Following the Cambodian government’s 2011 Alternative

Energy Development Agreement with General Electric, Sok
Puthyvuth’s company, the Soma Group, signed an MoU
involving a US$3 million biomass power deal with the US
conglomerate.200

THE COST TO PEOPLE AND ENVIRONMENTThe extent of the Hun family’s private sector holdings, theirapparent access to lucrative state resources and their immunity
to Cambodia’s legal system, point strongly to the fact that Hun
Sen’s Cambodia is built on grand corruption. These are far fromvictimless crimes: the Hun hegemony has had devastatingconsequences for the country’s population and many of theircompanies have got away with ignoring Cambodian law andharming people and the environment in the process.
Below are some specific examples of the Hun family’s terriblesocial and environmental footprint:

Phnom Penh resident facing eviction by a company
linked to the Hun family removes the live cobra thatthugs threw through his window in 2013.

• Brother-in-law to Hun Many, Yim Leang, has held ten per centof company Khun Sea Import Export since February 2011
when tycoon Khun Sear, who still holds the remaining 90
percent of the company, transferred over his shares.208 Khun
Sear is described by local press as ‘a politically connectedbusinessman who has major interests in agriculture and realestate’.209 The company lists capital of US$2 million on the
Ministry of Commerce database.210 It was awarded an 8,200
Economic Land Concession to grow rubber and other crops in
Oddar Meanchey Province’s Kulen Promtep Wildlife Sanctuary
on 6th July 2012, less than 18 months after Leang became

HOSTILE TAKEOVER JULY 2016 23

Police beating a man during a crackdown on striking workers from SL Garments.
Factory workers claim Hun Sen’s sister is the company’s Director General.

a shareholder.211 This allocation of land by the government
occurred two months after Hun Sen placed a moratorium on
the issuance of new concessions.212
	In addition, Khun Sea Import Export came into conflictwith residents of Phnom Penh’s Tuol Kork district when it
attempted to get hold of their land for redevelopment. The
company is accused of carrying out forced evictions andenlisting thugs to intimidate and assault residents who
refused to move, including by using arson and throwing
live cobras into their homes.213 The dispute was listed in acase filed at the International Criminal Court in October
2014 which describes the associated crimes committed by
Khun Sea Import Export as ‘Several episodes of assault andattempted murder against [name of victim removed due tosecurity concerns], persecution on political grounds”214. The
case, which lists the company among tens of others to havecommitted the crime of forcible transfer in Cambodia, argues
that the Cambodian government, state security forces andgovernment-connected business leaders have committed‘crimes against humanity’ against Cambodian civilians during
their widespread and systematic campaign of land seizures.215
	When asked by local reporters about the case, Yim Leang
confirmed that he did own the land, but claimed that hewas not aware of any issues with local residents.216 Due tohis position in the Cambodian army, Leang’s shareholding in
Khun Sea Import Export contravenes Article 25 of the 1998
General Statute of Military Personnel of the Royal Cambodian
Armed Forces which prohibits military personnel from“conduct[ing] any business which may harm the honour anddignity of the Royal Cambodian Armed Forces”.217• Sok Puthyvuth, Hun Maly’s husband and CEO of the Soma

Group conglomerate, is also linked to an urban land grab.218
Soma Construction & Development, which he chairs, is partof the team expanding Phnom Penh International Airport, aproject which began in 2014 and is rumoured to be costing
US$100 million.219

	The project threatens to displace approximately 165
households - residents were told that their homes would
all be destroyed, but that they wouldn’t be receiving
compensation despite having possession rights to theirland under Cambodia’s 2001 Land Law.220 In 2012, eightprotesters from the community were arrested by armed
police and detained for 12 hours after painting SOS signs on
the roofs of their houses in the hope that President Obama
would see their cries for help as he flew in to attend theASEAN summit.221 A year later, having identified that theInternational Finance Corporation (IFC) was part-financing
the project, 59 potentially-affected households lodged aformal complaint with the IFC’s ombudsman concerning
possible forced evictions. The complaint remains open at timeof writing.222 Work on the airport now appears to have stalled,
but Cambodian land expert told Global Witness that thecommunities fear the delay is just a ploy to prevent protests
ahead of Cambodia’s commune elections in 2017.223 In May
2016, local media reported that 531 families potentiallyaffected by the airport’s expansion conducted a public protest
outside the Council of Ministers urging it to resolve thedispute which had been ongoing at that point for four years.224
The land dispute is yet to see a resolution.

24

Cambodia’ details how the company came into conflict withindigenous Suy communities when it flooded their agricultural
fields and contaminated local water sources.232

Forest loss in Cambodia accelerated faster than in any other country between
2001 and 2014 thanks to rampant illegal logging and land grabbing by thecountry’s ruling elite. © Global Witness• Seng Keang, ex-wife of Hun Sen’s cousin Dy Chouch and close
associate to Bun Rany, was exposed by Global Witness in 2007as leading Cambodia’s premier logging syndicate which had
allegedly committed multiple crimes including corruption,
kidnapping and attempted murder.225 She was again linked toillegal logging in 2012, this time in and around Vietnameseowned rubber plantations. In addition to causing widespread
deforestation, local communities described to Global Witness
investigators how the logging was devastating their livelihoods
which previously relied upon collecting tree resin in order tomake an array of local products.226
Despite the substantial evidence of her involvement inillegal logging and other crimes, Seng Keang chairs threecompanies.227 As far as Global Witness is aware, no legal
action has even been taken against her.

• H un Seng Ny, the prime minister’s

younger sister, is linked to threecompanies that have been accusedof breaking Cambodian laws without
facing legal consequences.

According to local communities, media
and human rights workers, she has
Hun Seng Ny. Photo obtained
a major stake in HLH Agriculture.228
from http://www.johnnyhon.
The company is part of the Singaporecom/Gallery/Cambodia/
photos.htm
based HLH Group which is currently
building a luxury apartment complex
and shopping mall in Sihanoukville and recently announced a
US$10 million investment in a 400-hectare agricultural foodprocessing park.229 Global Witness wrote to the company inDecember 2015 asking them to respond to the allegation thatthey have links to Seng Ny. In their reply, dated 7th January
2016, they failed to either confirm or deny the connection. In
2010, in response to allegations of land grabbing, government
officials and a manager at HLH Agriculture denied Seng Ny’s
connection to the company to local reporters. 230
 LH Agriculture has reportedly been embroiled in a landH
dispute with villagers in Kampong Speu since 2010 and has
been accused by local communities of illegal logging in the
Phnom Oral Wildlife Sanctuary in 2013.231 A 2012 report by the
UN Special Rapporteur on the ‘Situation of Human Rights inI n June 2014, a fully-owned subsidiary of the HLH Group,
D’Lotus Development, signed an agreement to buy part of theland that used to be Boeung Kak Lake from private company
Shukaku Inc. in contravention of Cambodia’s Land Law which
prohibits one concessionaire from selling on land to another.233
One of the most high-profile land grabs in Cambodia, theallocation of Boeung Kak Lake to Shukaku Inc., owned by
CPP senator Lao Meng Khin and his wife Choeung Sopheap,
led to the illegal displacement of 4,000 families. As a result,in 2011, the World Bank suspended all new direct financing
to Cambodia.234 In the face of substantial opposition from the
Boeung Kak Lake communities and civil society, the Bank
reversed this decision in May 2016 despite many affected
community members still not having received free or faircompensation for their losses.235
 lobal Witness put these allegations to HLH Agriculture in ourGletter of December 2015. In the response, HLH Group confirmedthat D’Lotus Development had entered into an agreement with
Shukaku Inc. to acquire land. The letter stated that during thecourse of the negotiations over Boeung Kak Lake neither HLHGroup nor D’Lotus Development had any dealings with her or
Hun Sen. The agreement with Shukaku Inc. was apparently
terminated in December 2014 “due to commercial reasons”.
The company’s letter makes no reference to the fact that,were the deal to go ahead, it would have been illegal.
 un Seng Ny also appears to have links to the
H
SL Garment factory where workers claim they were told
she was director general of the company. In 2013, 75 private
security guards from the security wing of Seng Ny’s company,
the Garuda Group, were sent into the factory to deal withstriking workers.236 Trade Union officials accused the Garuda
security guards of intimidating and using violence against
striking workers.237 In April 2016, an investigation conductedby a conservation organisation and published in international
media, alleged that SL Garments’ factory is burning illegallylogged timber taken from protected areas to heat water forwashing machines and steam presses.238
According to the Ministry of Commerce data, Seng Ny is also a
50 per cent shareholder in Attwood Investment Group.239 The
company is chaired by prolific businesswoman Lim Chhiv Hoand was revealed by Global Witness to be linked to a smuggling
operation involving the military in 2007.240 Local media
reported in 2009 that the Preah Sihanouk provincial authorities
had accused the company of illegally dredging thousands oftonnes of sand using unlicensed boats. Local people claimed
that the dredging was destroying fish stocks and negatively
impacting upon their livelihoods, allegations that thecompany denied.241
At time of writing, Global Witness was unaware of any
investigations by the authorities into these allegations let alone
punitive actions being taken against any of the perpetrators.

HOSTILE TAKEOVER JULY 2016 25

TAKING ADVANTAGE OF PERSONAL IMPUNITY
As information on company ownership in Cambodia issketchy at best, it is perhaps not surprising that Cambodian
citizens have been unable to hold the Hun family to accountfor the illegal activities of companies they are linked to,particularly when those links are hidden. However, the levelof impunity enjoyed by the family extends well past corporate
wrongdoing to also cover crimes committed by family members
as individuals.
The three people profiled below provide examples ofwhere family members appear to have got away withcommitting serious crimes, but have gone on to be granted
honorific titles or powerful positions within the state
apparatus as well as managing to accumulate numerous
business holdings.

• Hun Sen’s nephew Hun To was named

as a ‘major drug trafficker’ in interviews
conducted by Global Witness withwell-placed sources in 2006.242 Thesame investigation also revealed that
he had links to Cambodia’s premierlogging syndicate at the time.243 Hun To
was back in the limelight in 2012 whena media report again connected him to the trafficking of US$1
billion worth of narcotics to Australia – allegations he denies.244
The Age newspaper alleged that Hun To was the subjectof a multi-year-long investigation by an Australian Crime
Commission into heroin trafficking and money laundering,where drugs were smuggled in shipments of timber. Australia’splans to arrest and question To in Melbourne were allegedly
derailed when the Australian Foreign Ministry denied him a visa
on the basis that his arrest by Australian Police could cause a‘diplomatic incident’.245
Known as something ofa playboy, Hun To is said
to own several luxury
cars, allegedly including
a customised McLarenP1 estimated to cost inexcess of US$1 million.246
McLaren P1. Photo obtained
from Hun To’s Facebook page.
He was also rumoured tobe the owner of Phnom
Penh’s former rich-kid hang out Spark Nightclub and is listed
as the chair of four companies as well as director of LHR Asean
Investment which runs a large network of petrol stations
across Cambodia.247• Dy Proem, Hun Sen’s cousin, wassentenced to two-and-a-half years injail in 2011 for bribing a civil servant
US$200,000 to forge a deed to a plotof land. The fake document granted
Proem ownership of 5.6 hectares of landin Phnom Penh which actually belonged
to an elderly widow.248 No warrant toimprison her was ever issued, however. Instead, Dy Proem wasgiven the title of oknha.249 Traditionally a rare title of nobility
bestowed by the king, today the oknha title is handed out by
government to people who donate US$100,000 to Hun Sen’s
political party, and make a vague commitment to direct someof their wealth toward ‘the greater good’.250
In February 2016, shortly after Global Witness wrote tomembers of the Hun Family to give them an opportunity
to comment on the allegations contained in this report, Dy
Proem’s case entered Cambodia’s Court of Appeals and isongoing at the time of writing. In the five years since charges
were levied against Dy Proem, however, much of the land
she has been accused of unlawfully acquiring has beensold off.251• Hun Chea, another of Hun Sen’s

nephews, was arrested in 2000 with six
others, all sons of government officials,
after shooting erupted at a Phnom
Penh night club. Hun Sen was quoted assaying: “Every son, whomever’s son, evenmy son, if they commit wrongdoing, theymust be punished by the law.” Four days
later, Chea was released on bail.252
Less than two years’ later, in December 2001, Chea and his
first cousin Hun To were arrested in connection with a shootout that erupted at a beer garden in Phnom Penh. Local
media reported that the incident was an apparent attempted
assassination of Hun To. Gunmen fired almost 50 shots at To,
Chea and their party, which included relatives of Deputy Prime
Minister Sar Kheng. Local police said that the shooting was theresult of a ‘personal dispute’.253 Hun Chea was arrested at thetime and Hun Sen later also ordered the arrest of Hun To overthe incident, stating that “Regardless who it is—my nephew, mychild—everyone must be equal before the law.” They spent lessthan a week in prison before being released in time to attend
the wedding of their cousin, Hun Manith, to the daughter of
National Police Chief Hok Lundy. The case was dropped a few
weeks later, allegedly because of a lack of evidence.254
Chea was also reportedly involved in a hit-and-run
incident in 2008 which resulted in the death of a motorbike
driver. The case never went to court but witnesses allegedthat they saw Chea standing at the crash site next to thevehicle in question.255
Chea was promoted to become a brigadier general in
Cambodia’s police force in 2014.256 He also chairs four
companies in the trading and transportation sectors.257
In January 2016, Global Witness wrote to all the people
mentioned in this chapter requesting their response to theevidence presented. Only Sok Puthyvuth replied but failed toaddress any of the specific allegations made against him. His
email is outlined on page 20. Global Witness also wrote to thecompanies mentioned but only received a response from the
HLH Group which is summarised on page 24.

26

THE HUN HEGEMONY –REINFORCING CONTROL
Prime Minister Hun Sen is making efforts to bridge the gap between the politicaland private sector by cultivating mutually beneficial relationships with the country’s
most prominent business tycoons. These business leaders contribute money to theruling Cambodian People’s Party (CPP) and Hun Sen can call on them to fund charities
and public works projects and to attract foreign investment, achievements for which
the CPP can claim credit. In return, the business tycoons enjoy the added credibility
and legitimacy of having the Prime Minister’s support. These symbiotic relationships
illustrate the networks of business tycoons, political figures, and government officialsthat have formed in Cambodia, which reinforce the culture of impunity and limit
progress on reforms such as Hun Sen’s self-declared “war on corruption. 258– Extract from a cable entitled ‘Cambodia’s Top Ten Tycoons’ sent in 2007 by the US Embassy inPhnom Penh to various US government departments in Washington DC

The Hun family’s business holdings are part of a broad systemof patronage which extends well-beyond the private sector into
almost every aspect of Cambodian society. During Hun Sen’s
three decades’ of power, this system has been maintained
through a blend of nepotism, propaganda, repression andalliances with other elites.259
The sections below look past the private sector holdings of thefamily to describe some of the other key ways in which they
maintain control:

PUBLIC OFFICE AND
STATE SECURITY FORCES

On 10th January 2016, in a closed meetingof the CPP, Hun Sen warned officials of
the dangers that nepotism poses for the
Cambodian government and urged them tokeep their relatives out of ministry affairs.260
Due to high-levels of corruption, those in public office are able
to get away with handing out state jobs to their relatives andnone more so than the Hun family. This reveals both their
desire to consolidate power but also the deep mistrust thatexists between many Cambodian elites.

MILITARY
Hun Sen’s eldest son, Hun Manet - often
touted as the obvious successor to hisfather - is a Lieutenant General andholds four notable positions - deputy
chairman of the Royal Cambodian
Armed Forces Joint Staff, commanderof the national counter-terrorism
special forces, deputy commander of the army and deputy
commander of the prime minister’s bodyguard unit.261 Hun
Sen’s elite bodyguard unit, which numbers in the thousands,
has long-been accused of committing brutal human rights
abuses.262 In March 1997, it was involved in a grenade attack
on an opposition rally in which 16 people died and more than
150 were injured.263 The unit functions as Hun Sen’s privatearmy and is central to maintaining his grip on power.264 In 2015,
three soldiers from the unit brutally attacked two opposition
lawmakers as they left parliament.265
Manet’s middle brother Hun Manith isalso a Lieutenant General in the army.
In 2015, he was promoted to directorof the Royal Cambodian Armed Forces’(RCAF) powerful military intelligenceunit.266 This was described by one of
Cambodia’s most respected politicalcommentators as an attempt by thepremier to consolidate power.267 Yim Leang, Hun Many’s
brother-in-law, became Cambodia’s youngest general in the airforces in 2002.268 In another move also described by a source
as a power grab by Hun Sen, he was made head of senate
president Chea Sim’s bodyguard unit until Sim died in 2015.269

HOSTILE TAKEOVER JULY 2016 27

POLICE
Hun Sen’s son-in-law Dy Vichea is headof the National Police’s Central Security
Department, a powerful position
which places him in charge of multiple
departments including internal
intelligence and the anti-terrorism
department which has played a keyrole in the CPP’s recent clampdown on its critics.270 Nephew
Hun Chea was promoted to be a one-star police general in2014, despite numerous brushes with the law.271

POLITICSIn politics, youngest son, Hun Many,
is a CPP member of parliament for
Kampong Speu Province.272 Hun Sen’s
brother, Hun Neng, is the former
governor of both Kampong Cham andSvay Rieng Provinces and now sits
alongside Hun Many in Cambodia’s
lower house.273 Following the releaseof Global Witness’ 2007 report “Family
Trees” which exposed how relativesof Hun Sen were leading Cambodia’s
most powerful logging syndicate, Nengreportedly said that “If they [Global
Witness] come to Cambodia, I will hit
them until their heads are broken.”274

MARRIAGES TO CREATE ALLIANCES
Arranged marriages, although declining, are stillcommon in Cambodian society, used as a means ofconsummating financial ties and shoring up politicalalliances. All five of Hun Sen’s children are married to theoffspring of powerful Cambodian elites, as are a numberof his nieces and nephews:• T he prime minister’s eldest son, Hun Manet, is married

to Pich Chanmony, the daughter of Pich Sophoan, aprominent Cambodian People’s Party member and current
Secretary of State at the Ministry of Labour.275• H un Mana, Hun Sen’s eldest daughter, is married to

Dy Vichea, the son of the much feared late police chief
Hok Lundy.276 Previously, Mana was married to Moeung
Kompheak, son of Moeung Samphan, a three-star generaland head of the Ministry of Defense’s Department Generalof Logistics and Finances.277 Vichea was previously married
to Hun Sen’s niece, Hun Chantha.278• H un Manith, Hun Sen’s middle son is married to Dy
Chendavy who is Dy Vichea’s sister.279• Youngest son, Hun Many, wed the daughter of deputy

prime minister Yim Chhay Ly in 2004.280 The wedding wasreported by local media to be a lavish affair, with large
numbers of military police, police officers and two fireengines on hand to ensure the 3,000 guests and theirhundreds of vehicles were kept secure.281• Youngest daughter Hun Maly is married to Sok Puthyvuth,

the CEO of the Soma Group and son of Sok An, who is also
deputy prime minister and a long-term ally of Hun Sen’s.282• Hun Sen’s niece, Hun Kimleng, is married to National
Police Commissioner Neth Savoeun.283• K imleng’s brother, Hun Seang Heng is married to Sok

Sopheak who is the daughter of Sok Phal, a powerfulpolice intelligence figure and current head of Cambodia’s
immigration department.284

All three of Hun Sen’s sons have received
scholarships or training from the US Military.

These marriages are mutually beneficial and help the Hunfamily to maintain its control over Cambodian politics,
economics and ultimately society. It’s a control that thefamily does not expect to dissipate any time soon. Hun
Sen, who is currently 63 years old and the world’s seventh
longest-serving leader, said in 2013 that he planned tostay in power until he is 74.285 It has long been presumed
that he is grooming his eldest son, Hun Manet, to be his
successor.286 However, in December 2015, Hun Many also
expressed his intention to become Cambodia’s next prime
minister.287 Either way it seems that the Hun family plan tolead Cambodia for decades to come, and they continue to
put in place the structures and connections to ensure they
stay in power.

28

CHARITY ENDS AT HOME

The CPP is now doing hundreds ofthousands of projects, small and large projects,
for which the budget, rather than from thenational budget, comes from CPP members…
When the election comes, if people don’t votefor [the CPP], we will be disheartened andwill stop giving… I spend hundreds of millionsof dollars paying for projects, including
raising orphans, disabled children and otherorganizations. I don’t even use thenational budget. 288– Excerpts from a public speech made by Hun Sen on 5th March
2013, less than four months before the July 2013 general election
which the CPP almost lost.
Members of the Hun family are also at the helm of a number ofcharitable organisations. As well as conferring legitimacy and an
air of compassion on the family, this arrangement allows themto fundraise for humanitarian projects such as digging wells andrepairing bridges and schools, ‘good works’ that can then be
attributed to the ruling party.289
The first lady plays a particularly key role in this revolving door
between charity and politics. Bun Rany is president of theCambodian Red Cross (CRC), Cambodia’s largest charity.290
A member of the Red Cross’ international federation, the CRC
purports to uphold the network’s core principles of neutrality
and independence but does little to hide its political allegianceand has been referred to as the ‘humanitarian wing’ of theCambodian People’s Party.291 It functions as a microcosm of
Hun Sen’s patronage system and its central committee comprises
many of the Hun family’s business associates, CPP officials
and their family members.292
In October 2013, following serious flooding which displacedtens of thousands of Cambodians, Rany was giving out bags ofrice and other supplies paid for by CRC donors at a CRC staged
event in front of hundreds of people. Addressing the crowds,
and following a denunciation of the opposition party, Rany said,“When there are floods or any other incidents, fathers and mothers
and brothers and sisters have seen that there is no other party
coming to help you here…there is only the CPP, because all civil
servants are CPP.”293
Between 2006 and 2009, the CRC’s income was US$27.8 million,
71% of which (just under US$20 million) came from domestic
sources including Hun Sen and business tycoons with links to
his family.294 Over the same time period, the CRC received a
total of US$8 million from international donors including theInternational Committee of the Red Cross, the International
Federation of Red Cross and Red Crescent Societies, UNICEF,

UNDP and 11 other national Red Cross partners, with
US$1 million coming from the Australian Red Cross alone.295
Global Witness urges the International Federation of the Red
Cross and Red Crescent Societies to expel the Cambodian
Red Cross from its membership due to the way in which theorganisation is used by the Hun family and the ruling Cambodian
People’s Party for political gain.
CPP Member of Parliament and Hun Sen’s youngest son,Hun Many, is the president of the Union of Youth Federationsof Cambodia (UYFC), one of Cambodia’s largest youth
organisations.296 Also reportedly counting Many’s brother-in-law,
Dy Vchea, as a high-ranking member, the UYFC is described bypolitical commentators as “a political organisation of the CPP”
and is widely viewed as its youth wing, despite the organisation’s
claims to be non-partisan.297 In November 2015, Many wasawarded the Gusi Peace Prize – which on its website claims to“approximate the honor and respect accorded to the Nobel Peace
Prize of Norway, and the Pulitzer of the United States of America”— for his work in “Youth Leadership and Humanitarianism”.298
Hun Many returned home from Manila to be greeted by morethan a thousand cheering UYFC members.299 A month earlier,members of the UYFC were rumoured to have been part of alarge protest against opposition leader Kem Sokha outside the
National Assembly where two opposition MPs were brutallybeaten by members of Hun Sen’s bodyguard unit.300
Hun Sen’s daughter-in-law, Pich Chanmony, also heads up
her own charitable organisation called the Samdech Techo
Volunteer Youth Doctor Association (TYDA) of which she isa founder, alongside her husband Hun Manet, and the vicechairwoman of the association’s board of directors.301 Despite
being a humanitarian aid organisation, the group is also said tobe pro-CPP and shares the first two words of its name, ‘Samdech
Techo’, with Hun Sen’s official title.302 In August 2015, local media
reported that TYDA was in talks with St. John Brigade Singapore
which has also worked with the CRC in the past.303
In January 2016, Global Witness wrote to the Cambodian Red
Cross, the Union of Youth Federations of Cambodia and theSamdech Techo Volunteer Youth Doctor Association but did notreceive a response.

MEDIA – OFFLINE AND ONLINE
The cult of personality surrounding Hun Sen and his family
also helps maintain their firm grip on Cambodian society.304
The premier’s photo is plastered all over the country, both on
urban street corners and in rural villages, even more so than
Cambodia’s king. Karaoke videos singing the praises of Hun Sen
or Bun Rany air relentlessly across many Cambodian TV stations
and not only laud the couple generally but also promote recent
government policy decisions.305 Many state institutions andpublic spaces such as libraries, streets and schools are named
after Hun Sen.306
Media ownership remains extremely concentrated in Cambodia
and many of the country’s most influential outlets are controlled

HOSTILE TAKEOVER JULY 2016 29

Bun Rany is president of the Cambodian Red Cross and is repeatedly accusedof using the charity to further the interests of the CPP and her family.

by business and political elites with close ties to the Hunfamily.307 As a result, freedom of speech is not fully protected
and the authorities use lawsuits, criminal prosecution andviolent attacks as means of intimidation against journalists.308
The Hun family and its associates have managed to gain amajor hold over Cambodia’s private media companies, allowing
them to control much of the information that Cambodians
are able to access. A recent study funded by the German
government and released in 2015 by the Cambodian Centre for
Independent Media and Reporters without Borders surveyed
41 of Cambodia’s most significant media outlets, owned by 27
individuals. Of these 27 people, the research found that nine
are business or political tycoons with strong links to the CPP.
The list includes Hun Mana, and major private sector players
and business associates of the Hun family Kith Meng and Ly
Yong Phat.309
As described on page 13, Hun Mana is one of only two media
moguls in Cambodia to have holdings across radio, TV andnewspapers.310 She owns Bayon Media Hight System, one of
Cambodia’s’ key media companies, that broadcasts acrossboth television and radio.311 One of three TV stations run by thecompany, BTV News is the second most popular news channel
in the country and airs Cambodia’s most popular evening news
programme.312 Mana also owns Bayon Radio which is among
the most popular radio stations in Cambodia and a leading
CPP mouthpiece.313 In addition, she fully owns newspaper
Kampuchea Thmey Daily, which has six percent of the national
readership and is also widely known to be pro-CPP.314
The dominance of private media companies by the Hunfamily and their cronies has profound impacts across theentire media sector. A 2015 study by the Cambodian Centre of
Independent Media found that almost half of local journalists
fear repercussions as a result of their work and 17% havebeen attacked due to their reporting. Only 45 cent felt that theinstitutions they worked for were free from political influence.315
In 2015, Reporters Without Borders identified Cambodia andIndia as the two deadliest countries to be a journalist covering
environmental issues, citing four killings in Cambodia between
2012 and 2014.316
With numbers of social media users in Cambodia rocketingin the last five years, the Hun family has become increasingly
active online. Hun Sen has been posting regularly on his
Facebook page since October 2015 and, at the time of writing,
had over four million followers.317 In March 2016, a high-profile
spat erupted after local media and Sam Rainsy, exiled leaderof the opposition party, accused him ofbuying ‘likes’ from foreign click-farms
to artificially boost his popularity.318 In
order to further strengthen his online
presence, in January 2016, Hun Sen
launched the “Samdech Prime Minister”
app which provides regular updates on
his activities.319
Hun Sen’s online presence is increasingly spilling over into
the real world. Members of the Hun family have become
increasingly aggressive in response to criticism levelled againstthem online, threatening defamation lawsuits and arrestingusers.320 In January 2016, following the arrest of a man that
had posted a prediction of Hun Sen’s death, the prime minister
warned Facebook users who insult him that they could be
easily traced.321

30

In contrast to the crackdown, Hun Sen is also using Facebook
to hand out random favours to ordinary citizens. He has
civil servants from seven government ministries trawlingposts on his Facebook page looking for public grievances
to solve.322 In March 2016, he intervened in the case of two
community members who had been arrested over a land
dispute in Kampong Speu Province. He posted on Facebook
that the provincial governor should work immediately for
the women’s release and then reportedly sent his sons - CPP
lawmaker Hun Many and head of the army’s intelligenceunit Hun Manith - to meet the women in person as they werereleased from prison on bail.323
The way in which Hun Sen is using Facebook to both harass
critics and manipulate the justice system by arbitrarily
dispensing favours is typical of the way in which he has
maintained control over Cambodia for the past three
decades. The tools have changed, but the strategy andoutcomes remain the same.

CONCLUSION
This report lays bare the extent and audacity of the myththat Hun Sen is selling to the outside world. According to the
Cambodian government, the key to achieving the economic
growth necessary for the country to meet its development
goals is the establishment of a ‘healthy private sector’.324
In an attempt to woo businesses from Asian countries andWestern jurisdictions such as the US and EU, the government
has recently ramped up its efforts to promote Cambodia as
a great investment destination, touting the country’s lack ofregulation and cheap labour force.325 Despite this, Hun Sen andhis government have completely failed to tackle the corruptionthat is rife in both the public and private sectors and which
undermines all attempts to create a responsible businessenvironment. In fact, Hun Sen and his associates are at theheart of the graft, personally benefiting from grand corruption
at the expense of Cambodia’s citizens.
Based almost solely on data from Cambodia’s Ministry ofCommerce corporate registry, the evidence presented in
Hostile Takeover reveals that members of prime minister Hun
Sen’s family have links to 114 domestic companies listing
share capital of over US$200 million. These figures only include
business holdings which the family has chosen to declare.
Therefore their total business interests are almost certainly
much larger.
The family’s holdings span the majority of Cambodia’s mostlucrative business sectors as well those characterised by highlevels of corruption, human rights abuses and environmental
damage. Companies in which the family has interests havecommitted abuses resulting in disastrous consequences for
Cambodian citizens directly impacted by their operations. More
broadly, corruption and the elite capture of state resourcesby the Hun family and their associates is keeping ordinary

Cambodians trapped in poverty as money is siphoned away
into personal bank accounts instead of being spent on vital
public services such as health and education.326 Due to apoliticised judiciary which remains firmly in the pocket of Hun
Sen, his family members and the companies to which they arelinked have been able to operate without fear of prosecution.
They have managed to establish relationships with majorinternational brands and gain interest in numerous companies
which Cambodians and tourists to the country will struggle
to avoid.
Having extensive private sector holdings is vital for enabling
Hun Sen and his family to maintain their system of patronage.
Many of these companies have been able to secure lucrative
public contracts and concession licences for natural resource
extraction and land. This increases the family’s personal
wealth which is required to continuously reward the country’s
elites who expect to be bestowed with ‘gifts’ in return for
their unwavering support.327 Without this income, the Hunfamily’s network would surely have collapsed over the past
three decades.
Cambodia is currently experiencing a backwards slide in termsof democratic freedoms and openness. A look at the events of2015 and 2016 reveal an onslaught of new repressive legislation
and a harsh crackdown against all government critics including
the legitimate opposition party.328 Hun Sen and his family
members have become increasingly aggressive in defending
their reputations and the situation looks set to deteriorate
further as they seek to consolidate power ahead of electionsin 2017 and 2018.
Hun Sen and his cronies certainly don’t appear to be planning
to relinquish power or change their ways any time soon, unlessoutside pressure starts to tell. In the latest election in 2013,
despite allegations of systematic fraud and vote rigging by his
government, Hun Sen suffered near defeat, prompting him
to vow that only “death or incapacitation to the point of being
unable to work” could unseat him.329 At the time of writing
opposition leader, Sam Rainsy, is still in exile and it is unclear
whether or not he’ll be able to return in time for the 2018
general election.330
Recent events, coupled with the findings laid out in Hostile
Takeover should act as major warning sign for potential
investors. As the rule of law diminishes, investors are left
vulnerable to arbitrary decision-making by elites. In addition,
the opaque business environment with high-levels ofcorruption poses major legal, financial and reputational risks
for companies. They face potentially becoming embroiled indriving human rights abuses, environmental destruction andcorruption. To avoid this, investors must conduct thoroughchecks to ensure that they’re not getting into bed with thecountry’s corrupt elites. Otherwise, the ‘healthy private sector’that the government claims it is working towards will nevermaterialise and ordinary Cambodians will continue to pay
the price.

HOSTILE TAKEOVER JULY 2016 31

RECOMMENDATIONS
Companies and investors should:

These recommendations relate to all companies andinvestors with links to members of the Hun family and theirassociates. This is regardless of whether the links are via formal
partnerships, franchising, through supply chains, exclusive
distribution deals or even loose client relationships.
1. Conduct stringent due diligence to ascertain who is
involved in the investment. Where there is the involvementof business or political elites with a history of corruption
allegations, or their family members, do not proceed with
the investment. Where this relates to an existing investment,
then exit the business relationship as soon as possible orwithin a maximum of 12 months.
	If evidence of involvement in corruption is uncovered
through the due diligence process then companies andinvestors should self-report the findings to all relevant
authorities that have legal jurisdiction.
2. Apply the Financial Action Task Force’s definition of
Politically Exposed Persons (PEPs) which also applies to allfamily members and associates of those identified. Create
stringent processes to identify PEPs. Where a potential
business partner is identified to be a PEP then enhanced due
diligence systems must be put in place to ensure that theperson in question is not involved in money laundering orother corrupt practices.
3. Ensure through a stringent due diligence process thatbusiness activities and investments in Cambodia are
not violating domestic or international anti-corruption
legislation or conventions. Give particular consideration
to ensuring compliance with the 1977 US Foreign Corrupt
Practices Act which covers any transaction conducted in US
dollars and therefore all non-local business transactions thattake place in Cambodia.
International governments providing Cambodia withfinancial aid and other types of assistance:
4. Use the Cambodian Development Cooperation Forum (CDCF)
as the basis upon which to negotiate with the Cambodian
government for the implementation of the recommendations
made in this report. Ensure through these negotiations thatall donor money to Cambodia is managed transparently,
does not end up in the pockets of elites, and is spent in a way
which benefits the citizens of Cambodia.
5. W arn home country investors about the high-risk of
becoming embroiled in corruption when investing in
Cambodia. Advise them to conduct stringent due diligence toensure that they are not entering commercial relationships
with business or political elites with a history of corruption
allegations or their family members. Advise them that certain
sectors, such as natural resource extraction, are particularly
high-risk and therefore should be avoided.

6. E
 nsure that the fulfilment of human rights obligations aswell as transparency requirements are incorporated into all
future investment treaties of which Cambodia is a signatory.
In particular, ensure that these obligations are included in
the Bilateral Investment Treaty currently being negotiatedbetween Cambodia and the US.
7. Publicly oppose recently passed regressive laws – LANGO,
Telecommunications and Trade Union Laws – from being
implemented in an arbitrary way that targets government
critics and the introduction of additional regressive laws
such as the State Secrets Law. Support the process to devise
the Freedom of Information Law to ensure it increases
transparency around government decision-making.
The Royal Government of Cambodia should:
8. Conduct thorough, independent and transparent
investigations into the allegations made in this report andprosecute those individuals and companies found to be
breaking Cambodian law. In particular, conduct a thoroughand transparent investigation into Prime Minister Hun Sen,and the members of his family named in this report, for thecrimes of illicit enrichment and the granting and receiving of
unfair advantages over the allocation of state resources.
9. E
 nsure that the Ministry of Commerce restores its full
corporate registry in which all information submitted bycompanies is included. Remove the need to register an
email address and login when searching the Ministry ofCommerce’s corporate registry and ensure it is both publicly
accessible and fully searchable. Correct all data inputted
into the registry – particularly the names of individuals,
companies and streets - to increase the registry’s usability.
10. Reform the Anti-Corruption Law so that it is fit for purpose.
In particular;

- Amend Article 11 so that the chair and vice-chair of theAnti-Corruption Unit are selected through an independentand transparent process and are no longer appointed by theprime minister.

- Amend Article 16 so that the Anti-Corruption Unit’s

operations budget is no longer part of the budget package of
the Office of the Council of Ministers.

- In order to avoid a conflict of interest, amend Article 16

so that the Anti-Corruption Unit no longer has the right toreceive donations or assistance from national organisations.
	- Based upon the Financial Action Task Force standards,
extend Article 17 so that the family members and close
associates of public officials are also required to declaretheir assets.

- Amend Article 20 so that asset declaration is conductedpublicly and Cambodian citizens are able to access theinformation.

32

11. Ensure that the Access to Information Law currently being
drafted increases transparency around government decisionmaking and is not undermined by the upcoming State
Secrets Law.
12. R
 emove Prime Minister Hun Sen as the chair of the Council
for the Development of Cambodia (CDC) and replace himwith an independent chair without links to the CPP or the
Hun family.
13. End secrecy and improve accountability around natural
resource governance including;	- Disclosing all relevant documentation relating to theextraction of natural resources including mining, Economic
Land Concessions and sand dredging.

	- Reinstating the Ministry of Agriculture, Forestry

and Fisheries’ online database of Economic Land
Concessions. Expand the original database to coverSocial Land Concessions.

	- Creating independent oversight and monitoring processes

14. End the persecution of all government critics including;- Members and supporters of the opposition party.
- Online critics- Human rights defenders- Land and forest defenders
In particular, put an end to the misuse of the Anti-Corruption
Unit as a political tool to attack and intimidate civil society.
Release those currently being detained and drop all charges
against them.
Members of the Hun family, including Prime Minister
Hun Sen, should:
15. Make full public declarations of their assets including
all existing connections to domestic and international
companies, whether those connections are formal
or informal.
16.Refrain from abusing their power to pressure private
Cambodian companies to grant them shareholdings.

for natural resource allocation and management including
opportunities for oversight from both the legislature and civilsociety including affected communities.

Hun Sen, Bun Rany and Hun Manith visiting a temple in Preah Vihear in 2010.

HOSTILE TAKEOVER JULY 2016 33

ANNEXESANNEX 1 - OUR FINDINGS IN FULL
The table below lists 114 private domestic companies that are affiliated to members of the Hun family. Almost all of this information
is taken from the Ministry of Commerce corporate registry, but in a handful of cases has been supplemented by other sources ofgovernment information and media reports.
Hun family Company*
memberRelationship tocompany/type ofaffiliation*

Record on Cambodia Corporates
or alternative source of information*This is based on the best
information available
including the MoC data set,
external information such as
corporate websites and, insome cases, the name of thecompany. For full references
contact Global Witness

R2425
A1319

5,000.00
5,000.00

Trading
Trading

R15979R123805,000.00
5,000.00

VC Group
Poseidon Co Ltd (listed as'Poseldon' by the MoC)
D & M (Bavet) SEZ Co

Chair
R16097
Director; Shareholder A4879

1,000.00
Unknown

Unknown
Conglomerate - Financial
services, construction/real
estate, watch and jewellery,hospitality/entertainment,
media, furniture and furnishing,as well as food and beverage
MiningGambling

Developer

52,000,000.00

Special Economic Zone

Fortress Group
Fortress Travel Agency
Fortress Construction Co
Fortress Investment Company
International
Advance Development Group(ADG) CoSPK 1
SPK Group
SID Cambodian Co
Cambodian Top Investment(CTI)
Gold 999 99
Tourism (Cambodia) Co.
(Cambodian) International
Franchise Co.

Chair
Chair
Chair
Chair

Official Cambodian government datacollated and displayed on the Open
Development Mekong website, https://
cambodia.opendevelopmentmekong.net/
profiles/special-economic-zones/?map_
id=6 (last accessed 1st June 2016)
R18381
R18380
R5424
R162728,000,000.00
8,000,000.00
2,000,000.00
8,000,000.00

Unknown
Tourism
Construction/real estate
Finance

Chair

R160245,000.00

Trading

Chair
Chair
Chair
Chair

R25317
R3559
R232
R15642

1,000.00
5,000.00
1,000,000.00
200,000.00

Unknown
Unknown
Unknown
Finance

Chair
Chair
Director; Shareholder(through Fortress
Investment Company
International)
Chair

R19191
R15530
A5727

175,000.00
6,000.00
5,000.00

Unknown
Tourism
Trading

R18390500,000.00

Finance

Chair
Chair
Chair
Chair
Director; Shareholder
(10%)
Chair

R4509
R3133
R2146
R1002
A5147

5,000.00
5,000.00
5,000.00
5,000.00
5,000.00

Transport
Transport
Trading
Trading
Trading

R25296

100,000.00

Chair; Shareholder
(49%)
Chair
Chair

A799

5,000,000.00

Professional services (taxadvisors)
Trading

R18498R189025,000.00
5,000.00

Unknown
Hospitality/entertainment

Chair; Director;
Shareholder (75%)
Chair
Chair

R8322; A9983; A9875

5,000.00

Hospitality/entertainment

R23359R25187

10,000,000.00
100,000.00

Trading
Professional services - Legalthe table as they are affiliated not stated it means
to more than one memberthat the informationof the Hun family
was unavailable

Dy Vichea
Dy Vichea

Dy Vichea
Dy Vichea
Dy/HokChendavy

Hun Chantha
Hun Chantha
Hun Chantha
Hun Chantha
Hun Chantha
Hun Chantha
Hun Chantha
Hun Chantha
Hun Chantha
Hun Chantha
Hun Chantha
Hun Chantha

Hun
Chanthou
Hun Chea
Hun Chea
Hun Chea
Hun Chea
Hun Chea

Sector**The majority of thesefigures can be found bydownloading the raw
data spreadsheets ofcompany registrations
from Cambodia
Corporates

					
					
*Companies highlighed in*Where the size of					
red appear more than once in the shareholding is			Dy Chouch
Dy Chouch

Company capital atregistration in USD*

Pich Sambath Import Export Co. Chair
C Pimex Co.
Chair; Director:
Shareholder
Dy Corp
Chair
Emperor Group
Chair

Heritage Investment
Corporation Co.
Hun Chea Transport Co.
CHSN Transportation Co.
CHLK Trading Co.
(Cambodian) HC Trading Co.
PSZ Trading

Hun Kimleng HML Xat Consulting
Hun Kimleng Eastern (Cambodia)
International Investment
Hun Kimleng F & B Life Style Investment
Hun Kimleng Gloria Jean’s Coffees(Cambodia)
Hun Kimleng HD Rock Café & Shop
Hun Kimleng HKLCH Import Export
Hun Kimleng HML Consulting

34

Hun family Company*
memberRelationship tocompany/type ofaffiliation*

Record on Cambodia Corporates
or alternative source of information

Company capital atregistration in USD**The majority of thesefigures can be found bydownloading the raw
data spreadsheets ofcompany registrations
from Cambodia
Corporates*Companies highlighed in*Where the size of
red appear more than once in the shareholding is
the table as they are affiliated not stated it means
to more than one memberthat the informationof the Hun family
was unavailable

Sector**This is based on the best
information available
including the MoC data set,
external information such as
corporate websites and, insome cases, the name of thecompany. For full references
contact Global Witness

Hun Kimleng Worldwide Investment Group

Chair; Director;
Shareholder

A5952

25,000.00

Hun Kimleng Worldwide Investment
Incorporation

Chair; Shareholder(100%)

A5415

25,000.00

Hun Kimleng Kam Chin International
Cooperation Group
Hun Maly
TK Avenue
Hun Maly
Cambodia Electricity Private

Shareholder (51%)

A6710

Unknown

Conglomerate - Food &beverages, advisory services,
tourism, construction/real
estate, mining, trading,hospitality/entertainment
Conglomerate - Food &beverages, advisory services,
tourism, construction/real
estate, mining, trading,hospitality/entertainment
Forestry

1,500.00
Unknown

RetailEnergyUnknown
50,000.00
5,000.00

Unknown
Pharmaceuticals
Media

5,000.00
Unknown

Hospitality/entertainment
Manufacturing10,000.00

Unknown
Unknown
Transport
Transport
Transport
Media

Hun Maly
Hun Maly
Hun Maly
Hun Maly
Hun Mana
Hun Mana
Hun Mana
Hun Mana
Hun Mana
Hun Mana
Hun Mana

Chair
R25949Director; Shareholder A6979; A7920; Electric Authority of(5%)
Cambodia, Decision on first revision of thelicense document no.132LD dated May 31 ,2006 for (Cambodia) Electricity Private Co.,
Ltd. for providing electric power generation
service at Phnom Penh city for revisingownership of licensee, 27th November
2013. Document obtained by Global
Witness investigators in October 2015.
(Cambodian) Food Industries Co Director; Shareholder A6257
Decampharma
Shareholder (10%)
A7567; A10029
Moon Media (listed as Moon
Shareholder; Director A651
Advertising by the MoC)
Stone Grill
Shareholder
A7307
NVC Corporation
Chair; Director;
A5839
Shareholder (via NH
Holding)
Ocasis Cambo Investment
Chair
R7623
Group Co
Ocasis Cambo Investment Co
Chair
R7622
Star Aviation (Cambodia)
Chair
R18119Star Airline (Cambodia)
Chair
R18113
Helistar (Cambodia)
Chair
R18118
Moon Media (listed as Moon
Chair; Director;
A311; A651
Advertising by the MoC)
Shareholder (51% via
NH Holding)Hun Mana

Bayon Media Hight System Co

Hun Mana

Bayon CM Organizer Co

Hun Mana
Hun Mana
Hun Mana

Jaya Holding Ltd
Dragon Royal Telecom
Kampuchea Thmey Daily Co

Hun Mana
Hun Mana
Hun Mana

NVN Corporation Co
MLM Resort Group Co
K Thong Huot Telecom

Hun Mana
Hun Mana

NH Holding
Viettel (Cambodia) PTE

Hun Mana

Royal Group Investment
Company
The Museum Company
Vina (HK)
Cambodia Electricity Private

Hun Mana
Hun Mana
Hun Mana

Chair; Director;
Shareholder (100%)
Chair; Shareholder(25% via Bayon Media
Hight System Co)
Chair
Chair; Director
Chair; Director;
Shareholder (100%)
Chair
Chair
Director; Shareholder(20%)
Representative
Shareholder (6% via
NH Holding)
Director; Shareholder

A7110

10,000.00
5,000.00
5,000.00
5,000.00
5,000.00 (figure only
counted once in total
despite repetition ofcompany in table)
Unknown

R22109; A4765

5,000.00

Media

R15680
A4764
R6193; A473

222,000.00
2,000,000.00
5,000.00

Unknown
Telecomms
Media

R1850
R3836
A6195

500,000.00
5,000.00
Unknown

Construction/real estate
Tourism
RetailA311; A5839; A2534
A2588

Unknown
44,877,168.00

Finance
Telecomms

A4610

5,000.00

Finance

Shareholder
Shareholder
Director; Shareholder
(10%)

A4617
2,500,000.00
A5068
16,000,000.00
A6979; A7920; Electric Authority ofUnknown
Cambodia, Decision on first revision of thelicense document no.132LD dated May 31 ,2006 for (Cambodia) Electricity Private Co.,
Ltd. for providing electric power generation
service at Phnom Penh city for revisingownership of licensee, 27th November
2013. Document obtained by Global
Witness investigators in October 2015.

Media

TourismGambling
EnergyHOSTILE TAKEOVER JULY 2016 35

Hun family Company*
memberRelationship tocompany/type ofaffiliation*

Record on Cambodia Corporates
or alternative source of information

Company capital atregistration in USD*

Sector**Companies highlighed in*Where the size of
red appear more than once in the shareholding is
the table as they are affiliated not stated it means
to more than one memberthat the informationof the Hun family
was unavailable*The majority of thesefigures can be found bydownloading the raw
data spreadsheets ofcompany registrations
from Cambodia
Corporates*This is based on the best
information available
including the MoC data set,
external information such as
corporate websites and, insome cases, the name of thecompany. For full references
contact Global Witness

Hun Mana
Hun Manith

Orkide Villa 3
Cambodia Electricity Private

500,000.00
Unknown

Construction/real estate
EnergyHun Seng Ny
Hun Seng Ny

1,000,000.00
5,000.00

Unknown
Trading

Hun Seng Ny
Hun Seng Ny
Hun Seng Ny
Hun Seng Ny
Hun Seng Ny

D.G.F. (Cambodia) Co.
Garuda Import Export (Garuda
Group)
Hatti Marketing Co
Hovercraft HiTec (Cambodia) Co
Metal Mining (Cambodia) Co
Metal Mining (Cambodia) PLC
Rong De GroupChair
R32257
Director, Shareholder A6979; A7920; Electric Authority of(5%)
Cambodia, Decision on first revision of thelicense document no.132LD dated May 31 ,2006 for (Cambodia) Electricity Private Co.,
Ltd. for providing electric power generation
service at Phnom Penh city for revisingownership of licensee, 27th November
2013. Document obtained by Global
Witness investigators in October 2015.
Chair
R3035
Chair
R22816
R21768
R21662
R16769; A5955
A8006
A1816

5,000.00
5,000.00
7,500.00
Unknown
5,000.00

Media
Unknown
MiningMiningUnknown

Hun Seng Ny

UNT Wholesale Co

A5841; A5545

Unknown

Trading

Hun Seng Ny
Hun Seng Ny

Attwood Investment GroupSL Garments

Chair
Chair
Chair
Chair; Shareholder
Chair; Director;
Shareholder
Chair; Director;
Shareholder (50%)
Shareholder (50%)
Director General

1,000,000.00
Unknown

Trading
Garments

Hun Seng Ny

HLH Agriculture

Unknown

Unknown

Agriculture

Hun Seng Ny

Garuda Security Services(Garuda Group)

Unknown

Unknown

Security

Hun ToHun ToHun ToHun ToHTK CoHTTK Co.
Gold Quest
LHR Asean Import Export Co

5,000.00
5,000.00
175,000.00
5,000.00

Unknown
Unknown
RetailEnergyHun ToLeang Vouch
ChhengLeang Vouch
ChhengLHR Asean Investment Co
NLC Import Export

Chair
Chair
Chair
Chair; Director;
Shareholder
Director; Agent
Chair

A4769
Cambodia Daily, Hun Sen’s sister linked
to private security firm at SL factory,
14th November 2013, https://www.
cambodiadaily.com/archives/hun-senssister-linked-to-private-security-firm-atsl-factory-46946/ (last accessed 4th June
2016)
Cambodia Daily, Hun Sen’s sister tied tocompany in Boeung Kak land sale, 25th
June 2014, https://www.cambodiadaily.
com/archives/hun-sens-sister-tied-tocompany-in-boeng-kak-land-sale-62344/(last accessed 3rd June 2016); Phnom Pneh
Post, Court summons Omlaing trio, 19th
July 2010, http://www.phnompenhpost.
com/national/court-summons-omlaingtrio (last accessed 3rd June 2016); Phnom
Penh Post Petition delivered: Villagers
demand land be returned, 11th November
2014, http://www.phnompenhpost.com/
national/petition-delivered-villagersdemand-land-be-returned / (lastaccessed 3rd June 2016); Phnom Penh
Post, Chainsaws stayed busy in past
year , 26th December 2013, http://www.
phnompenhpost.com/national/chainsawsstayed-busy-past-year (last accessed 3rdJune 2016)
R22816; Cambodia Daily, Hun Sen’ssister linked to private security firm at SL
factory, 14th November 2013, https://www.
cambodiadaily.com/archives/hun-senssister-linked-to-private-security-firm-atsl-factory-46946/ (last accessed 4th June
2016)
R14878R25100
R3066
A6749
R20011
R204415,000.00
5,000.00

EnergyTrading

R12435

10,000,000.00

Finance

Pacifica Investment Co. (listed
as Ppcifica Investment Co. by
the MoC)

Chair

36

Hun family Company*
memberRelationship tocompany/type ofaffiliation*

Record on Cambodia Corporates
or alternative source of information*The majority of thesefigures can be found bydownloading the raw
data spreadsheets ofcompany registrations
from Cambodia
Corporates*Companies highlighed in*Where the size of
red appear more than once in the shareholding is
the table as they are affiliated not stated it means
to more than one memberthat the informationof the Hun family
was unavailable
Men
Pheakdey

D & M (Bavet) SEZ Co

Chair; Director;
Shareholder (60%);
Developer

Men
Pheakdey
Men
Pheakdey
Men
Pheakdey

CVI Resorts

Chair; Shareholder(30%)
Shareholder

PichChanmony
Pich
Chanmony
Pich
Chanmony
Pich
Chanmony
Pich
Chanmony
Pich
Chanmony
Pich
Chanmony
Pich
Chanmony
Seng Keang
Seng Keang
Seng Keang

G Gear Co

Sok
Puthyvuth
Sok
Puthyvuth
Sok
Puthyvuth
Sok
Puthyvuth
Sok
Puthyvuth
Sok
Puthyvuth
Sok
Puthyvuth
Sok Sopheak

CVI LandCambodia Electricity Private

Company capital atregistration in USD*

Sector**This is based on the best
information available
including the MoC data set,
external information such as
corporate websites and, insome cases, the name of thecompany. For full references
contact Global Witness

A939; Official Cambodian government
data collated and displayed on the Open
Development Mekong website, https://
cambodia.opendevelopmentmekong.net/
profiles/special-economic-zones/?map_
id=6 (last accessed 1st June 2016)
A5205

5 2,000,000.00 (figure
only counted once intotal despite repetition ofcompany in table)

Special Economic Zone

5,000.00

Tourism

A5070

5,000.00

Unknown

Director; Shareholder A6979; A7920; Electric Authority ofUnknown(10%)
Cambodia, Decision on first revision of thelicense document no.132LD dated May 31 ,2006 for (Cambodia) Electricity Private Co.,
Ltd. for providing electric power generation
service at Phnom Penh city for revisingownership of licensee, 27th November
2013. Document obtained by Global
Witness investigators in October 2015.
Chair
R5729
200,000.00

EnergyChair; Director;
Shareholder (100%)
Chair

A8441

Unknown

Manufacturing

R7682

5,000.00

Finance

Lady Cosmetic International
Corporation
Zenoteq Solutions Co

Chair

R191335,000.00

Retail

Chair

R4574

50,000.00

Unknown

Legend Cinema Co

Chair

R7606

5,000.00

Hospitality/entertainment

PMV Entertainment Co

Chair

R5734

100,000.00

Hospitality/entertainment

Brands Management Ltd

Director; Shareholder
(5%)
Chair
Chair
Chair

A8001

20,000.00

Hospitality/entertainment

R2728
R15426
R207265,000.00
5,000.00
5,000.00

Agriculture
Unknown
Garments

CEO

Soma Group company website, http://
www.somagroup.com.kh/index.php/
about-soma/our-teams/ (last accessed 2ndJune 2016)
R3327; A7766

Unknown

Conglomerate: Trading,agriculture, energy, education,
construction/real estate

10,000,000.00

EnergyR1435

5,000.00

Agriculture

Khmer Latex Co
CMN Star Investment

Rith Mony Samnang Leap Co
Seng Kheang Apivath Co
Grand Harvest International(GHI)
Soma Group

Soma Energy

RetailSoma Ever Green

Chair; Shareholder(100%)
Chair

Soma Kova Holding

Chair

R136255,000.00

Trading

Tela E&P

Chair

R18807

12,500.00

EnergySoma Construction &Development
Phnom Penh Boat Ride Co

Chair

R252075,000,000.00

Construction/real estate

Chair

R245222,000,000.00

Tourism

iOne Co

Chair; Director;
Shareholder
Chair
Chair

R18674; A365; A2212

500,000.00

Retail

R12909R7834

5,000.00
100,000.00

RetailRetailSok Sopheak Cemtes (Cambodia) PTE
Sok Sopheak Mtesh Gadgets Co

HOSTILE TAKEOVER JULY 2016 37

Hun family Company*
memberRelationship tocompany/type ofaffiliation*

Record on Cambodia Corporates
or alternative source of information*Companies highlighed in*Where the size of
red appear more than once in the shareholding is
the table as they are affiliated not stated it means
to more than one memberthat the informationof the Hun family
was unavailable
Sok Sopheak AFZ Co

Sok Sopheak
Thai Jackie
Tai Hien
Thai Jackie
Tai Hien
Thai Jackie
Tai Hien
Yim Chhay
Lin

Security Services Asia
Camcorp Capital Group

Yim ChhayLin
Yim ChhayLin
Yim ChhayLin
Yim ChhayLin
Yim ChhayLin
Yim Leang

Chair; Director;
R20697; A5956; A73; A1891
Shareholder(shareholding
transferred from Sok
Sopheak to 'SEM TES(CAMBODIA) PTE LTD
Represented by Mrs.
Sok Sophak' in 2009.
Shareholding of ''SEM
TES (CAMBODIA) PTE
LTD' then transferred'I ONE represented
by Mrs.Sok Sopheak'in 2010)Chair
R12220
Chair
R8719

Company capital atregistration in USD*

Sector**The majority of thesefigures can be found bydownloading the raw
data spreadsheets ofcompany registrations
from Cambodia
Corporates*This is based on the best
information available
including the MoC data set,
external information such as
corporate websites and, insome cases, the name of thecompany. For full references
contact Global Witness

5,000.00

Unknown

5,000.00
1,000,000.00

Security
Hospitality/entertainment

Camcorp Capital Investment
Chair
Group
Camcorp Capital Investment Ltd Chair

R7499

3,000,000.00

Finance

R7574

3,000,000.00

Finance

Decampharma

Chair; Shareholder(20%)

R6884; A7567; A10029

Pharmaceuticals

YLL Resorts Co

Chair

R11849

50,000.00 (figure only
counted once in total
despite repetition ofcompany in table)
5,000.00

Machhoem Bopea TradingGroup Co
Phu Yang Ltd

Chair

R178875,000.00

Trading

Shareholder

A1570

5,000.00

MiningParadis Ltd

Shareholder

A5590

Unknown

Unknown

10,000.00

Mining2,000,000.00

Agriculture; Construction/real
estate; Trading

Sovannaphum Mine Exploration Director; Shareholder A1214& Development Co(50%)
Khun Sea Import Export Co
Shareholder (10%)
A1009; A2247

TOTAL:

201,223,668.00

Tourism

38

ANNEX 2 - METHODOLOGY
Global Witness was able to obtain original company registration
documents and subsequent amendments for almost 23,000
companies registered in Cambodia.331 This constitutes all of
the company records that were contained in the Ministry ofCommerce’s online corporate registry in February 2016.
In April 2015, the Ministry of Commerce upgraded its corporate
registry but the new version suffers severe search limitations
and is missing information that was included on the previous
version, namely the nationality of company chairs. In addition,
it presents a major security risk as the connection to the
database is not encrypted plus users must now register andlogin to the site, allowing the government to monitor who’s
using it and what searches are being conducted.332 In an
increasingly repressive environment this is simply too big arisk for many civil society actors, journalists and ordinary
citizens to take.
Global Witness has used the Ministry of Commerce dataset –which totals 22,808 company registration entries, and 7,502
amendments - to identify the business holdings of members ofthe Hun family as well as their private sector links to some of
Cambodia’s top business tycoons. Investigators searched forcompany registration documents and amendments that listed
the people in question as chairpersons, directors, shareholders
representatives or agents. Registered addresses of companies
and company chairpersons were also checked in order to
identify hidden links. Results from these searches were thencross-checked against other sources of information including
additional desk-based research and face-to-face interviews.
In order to increase transparency and corporate accountability
in Cambodia, Global Witness is launching Cambodia Corporates
alongside this briefing. This fully searchable and publicly
accessible database includes the entire dataset upon which thisinvestigation is based. If you’re an investigator wanting to know
more about who owns a particular company, or an investor
wanting to make sure you know who you’re getting into bed
with, then visit: www.cambodiacorporates.globalwitness.org

ANNEX 3 - THE LEGAL FRAMEWORKAs outlined in the main report, members of the Hun family
and companies linked to them have broken various laws in thecourse of their operations, most notably in the natural resource
sector. However, in addition, the family’s accumulation ofbusiness holdings, and the role this plays in the broader
system of patronage which allows the Hun family to maintaincontrol over Cambodian society, does violate national laws
in and of itself.
This section describes some of the provisions in Cambodia’s
legal framework aimed at stopping corruption and the inherent
weaknesses in those laws which allow the Hun family and theirassociates to ignore them.

THE ANTI-CORRUPTION UNIT
In 2010, Cambodia passed its first Anti-Corruption Law.333
The Law established the Anti-Corruption Unit (ACU) which
was tasked with driving the country’s efforts to end all formsof graft including:• Implementing all laws and regulations related to corruption.
• Directing the work of preventing andcombating corruption.

• Receiving and investigating complaints of corruption
and taking action against perpetrators.334

However, despite Article 11 of the Anti-Corruption Law statingthat the ACU will “independently undertake its duties”, theinstitution remains firmly under the control of Hun Sen.335
He appoints the body’s chairman and vice-chairman and its
operations budget is part of the budget package of the Officeof the Council of Ministers (Cambodia’s cabinet) which iscontrolled by the prime minister.336 The law also grants the ACU
the right to receive donations from national and internationalorganisations, leaving the door open for companies and cronies
to buy their way out of corruption charges.337
As a result, the ACU is widely considered to be little help in
the fight against corruption and, since its creation, corruption
levels remain high.338 In April 2016, the ACU sunk to a new
low when it summoned and interrogated seven humanrights workers the authorities accused of attempting tobribe the mistress of the deputy opposition leader to deny
their extramarital affair. The move was heavily criticised byinternational and Cambodian human rights organisations as anoutrageous misuse of the ACU as a political tool to attack andintimidate civil society.339

ASSET DECLARATIONThe Anti-Corruption Unit (ACU) is responsible for managing
the system of asset declaration, a key tool in any fight against
corruption.340 Articles 17 and 18 of the Anti-Corruption Law
requires politicians, civil servants, police, and military and civilsociety leaders to declare their assets every two years.341
At least four members of the Hun family – Hun Manith, Yim
Leang, Dy Vichea and Hun Chea - hold public office and havebusiness holdings which, by law, should be declared.342
However, declarations are not conducted publicly and theinformation on the business holdings of those required toparticipate is only made available to the ACU.343 Article 38 of
the Anti-Corruption Law lays out the punishment for failingto declare assets as just 1 month to a year in prison and afine of one hundred thousand Riel (US$25) to two million Riel
(US$500).344 However as the process happens behind closed
doors, it is impossible to know if members of the Hun family are
failing to declare any of their personal assets.
Another major weakness of the asset declaration process
outlined in the Anti-Corruption Law is that it does not requirefamily members of those required to declare their assets to do

HOSTILE TAKEOVER JULY 2016 39

the same.345 Therefore, members of the Hun family that do nothold public office are under no obligation to reveal to the publictheir private sector holdings. This enables them to operate
under the radar.

ILLICIT ENRICHMENT
Article 36 of the Anti-Corruption Law categorises ‘illicit
enrichment’ as a crime. The law defines it as “an increase in
the wealth of an individual and the individual cannot provide
reasonable explanation of its increase in comparison to his or her
legal income.” It states that assets belonging to persons who
cannot explain their wealth should be confiscated and become
state property.346
Hun Sen certainly appears to be in contravention of thislaw and therefore acting illegally. He has claimed that hesurvives solely on his government salary which, according toa statement he made to local reporters, was 4.6 million Riel
(US$1,150) per month in 2011.347 However, his lavish lifestyleincluding assets such as luxury houses appears to discount
this possibility.
Further disproving his claim, in June 2012, amid widespread
protests against rampant land grabbing, the prime ministerlaunched a new land titling scheme. He sent 1,600 student
volunteers out into the countryside to demarcate and allocate
private titles to villagers all over Cambodia. He boasted that he
was paying the student volunteers a monthly salary of around
US$220 out of his own pocket.348 If all volunteers were activeat any one time this would cost the prime minister US$352,000
per month, more than 300 times his official monthly salary.
In another example, in 2013, Hun Sen reportedly boasted in a
public speech “I spend hundreds of millions of dollars paying for
projects, including raising orphans, disabled children and otherorganisations. I don’t even use the national budget.”349
Despite this evidence however, the verdict as to whether aperson is guilty of illicit enrichment is based solely on theinformation provided through asset declaration to the AntiCorruption Unit (ACU).350 As this is done in private, and Hun
Sen has de facto control of the ACU, there is slim chance of him
or his family members being prosecuted for the crime of illicit
enrichment or any other corruption-related offence.

CAMBODIA’S CRIMINAL CODE
There are a number of corruption-related offences included in
Cambodia’s Criminal Code which are also referenced in Article
32 of the Anti-Corruption Law.351 The evidence laid out in thisreport and backed up by two decades of media exposés andreports from Global Witness and other NGOs, makes a strong
case that Hun Sen has broken Cambodian law by contravening
Articles 595 and 599 which state the following:• Article 595: Definition of Influential Deal352

Passive influential deal is an act committed by a civil servant ora citizen entrusted with public mandates through an election
to directly or indirectly solicit or accept without authorization
the donation, gift, promise, or any interest in order to obtainfrom a State institution due to real or assumed influence a job,a contract, an insignia or other preferences.

• Article 599: Definition of Favouritism353

Favouritism is an act committed by a civil servant or a citizen
entrusted with public mandates through an election to
unlawfully give advantages to other persons while making
public contract.
Examples of where members of the Hun family would appear tohave violated these laws are littered throughout this report andare also listed on pages 21-22.

POLITICALLY EXPOSED PERSONS (PEPs)
All Hun family members should be considered ‘politically
exposed persons’ (PEPs), either due to their relationship to
Hun Sen or, in many cases, as a result of the fact that they
themselves hold public office or top positions within state
security forces.
PEPs are defined by the inter-governmental Financial Action
Task Force (FATF) as “individuals who are or have been entrusted
domestically with prominent public functions, for example Heads
of State or of government, senior politicians, senior government,
judicial or military officials, senior executives of state-owned
corporations, important political party officials.”354 Financial
institutions are required by the FATF to ‘reasonable measures’to identify PEPs. Where a potential customer or business
partner is identified to be a PEP then enhanced due diligencesystems must be put in place to ensure that the person inquestion is not involved in money laundering or other corrupt
practices. FATF is clear that these requirements should also
apply to family members or close associates of PEPs.355
Cambodia’s 2007 Anti-Money Laundering Law does require
reporting entities to pay special attention to business relations
and transactions with PEPs and “seek additional information
as to the origin and destination of the money, the purpose of
the transaction and the identity of the transacting parties”.356
However, Cambodia’s definition of PEPs only encompasses
individuals who are or have been entrusted with prominent
public function in a foreign country. Neither individuals
entrusted with prominent public function in Cambodia nor
their family members and close associates are included.357
According to this definition therefore, not one member ofthe Hun family would be considered a PEP. As a result, in
Cambodia’s most recent FATF mutual evaluation, which was
carried out by the World Bank in 2007, the country is ranked as
Non-Compliant in terms of meeting FATF’s recommendations
on PEPs.358

40

Global Witness urges the Cambodian government to amend
the definition of Politically Exposed persons (PEPs) to include(i) domestic persons and (ii) PEPs’ family members andclose associates.
The problem with PEPs does extend further than justCambodia. There is no global comprehensive database of PEPs
and investors must instead rely on disparate lists put together
by various governments, multilateral institutions and risk
management firms. There have been attempts to consolidate
this information online. In May 2016, Global Witness conductedsearches on one such website which collated information on
PEPs from a range of sources including CIA World Leaders,the European External Action Service Consolidated Lists, theUN Security Council’s Consolidated List and the World Bank’s
Debarred suppliers for procurement. The only members of the
Hun family to be listed were Hun Sen himself and his brother
Hun Neng who is a CPP lawmaker. Not one of the other family
members listed in this report were named as a PEP, including
Hun Sen’s three sons, two of which hold top posts in the
military and the third who is a parliamentarian.359

MILITARY PERSONNEL
Members of the of the Hun family who hold positions in the
military and have private sector holdings may well havecontravened Article 25 of the 1998 General Statute of Military
Personnel of the Royal Cambodian Armed Forces which, in an
attempt to combat abuse of power, prohibits the following:• Us[ing] influence and power of their own functions to
exploit any advantage…

• Conduct[ing] any business which may harm the honourand dignity of the Royal Cambodian Armed Forces.

• Join[ing] as members of the board of directors or to
manage companies privately.360

Under this statute, Hun Manith’s directorship of Cambodia
Electricity private is illegal.361 Yim Leang’s 10 per centshareholding in agriculture and real estate company Khun
Sea Import Export also points to illegal behaviour.362 Although
Leang is not a director, when asked by local reporters about
a land dispute between the company and a group of Phnom
Penh residents, he confirmed that he did own the land inquestion.363 This indicates that his role is broader than the one
usually played by a minority shareholder and that he may
well be breaking the law by playing a management role in a
private company. In addition, Khun Sea Import Export hasreceived negative national and international attention overthe intimidation and harassment of residents who refused toleave their homes after their land had been allocated to thecompany.364 This again violates the 1998 General Statute of
Military Personnel of the Royal Cambodian Armed Forces by“harm[ing] the honour and dignity of the Royal Cambodian
Armed Forces.”

Global Witness urges the Cambodian government to enforce
Article 25 of the 1998 General Statute of Military Personnel ofthe Royal Cambodian Armed Forces by ensuring that military
personnel contravening the statute either resign from theirmilitary position or get rid of their business holdings.

CORPORATE SECRECY AS A BARRIER TO
IDENTIFYING ILLEGALITY
Like in many countries, corporate governance in Cambodia
is largely conducted behind a wall of secrecy. The Law on
Commercial Enterprises stipulates that companies file anannual declaration with the Ministry of Commerce and outlines
the punishment they face for filing ‘false and misleading
reports’.365 However, company reports are not made public and
it is therefore impossible to access the information they file orknow which companies are complying.
In another blow to corporate transparency, Article 230 of the
Law on Commercial Enterprises allows a company that “hasnot issued any securities to the public, or that does not haveany outstanding securities held by more than one person” tochoose not to appoint an auditor.366 As more than a quarter(26%) of the companies linked to members of the Hun family
are classified by the Ministry of Commerce as Single Member
Private Limited Companies (meaning that they only have one
shareholder), this reduces the level of scrutiny by removing therequirement for them to hire an auditor.367

HOSTILE TAKEOVER JULY 2016 41

ANNEX 4 - BREAKDOWN OF KEY FINDINGS
Below is a breakdown of two of the key findings outlined in Hostile Takeover. The information isbased solely on official data from Cambodia’s Ministry of Commerce.

• Figure 2 below shows a breakdown of the ways in which the Hun family are linked to the

114 companies which they have interests in. 103 of these companies (90%) count the family
member as chairperson, director or as having a shareholding of more than 25%, meaning thatthey exercise total or substantial control.368

1

14

9
Chairmanships (unknown if also a shareholder)

2

Where family member is both chair and shareholder

Type of holding

Where family member is listed solely as director

67

Where family member is both director and shareholder
Shareholder only
Representative

21•Figure 3 shows the breakdown of the type of companies that Hun family members are linked to. It should be notedthat 30 companies (26%) of the total 114 with links to the family are listed as a ‘Single Member Private Limited
Company’ meaning that the entire share capital issued is held or owned by one single person. Hun family members
are listed as company directors or chairs in all 30 of these cases, therefore it his highly likely that a member of thefamily is the sole owner of the majority, if not all, of these companies.369

1

11
30
Single Member Private Limited Company

Type of company

Private Limited Company
Public Limited Company
Unknown72

42

ENDNOTES
1 References for the points made in this section can be found in the main body of the report
unless otherwise indicated.
2 Radio Free Asia, Hun Sen declares assets, 1st April 2011, http://www.rfa.org/english/news/
cambodia/assets-04012011163501.html (last accessed 5th June 2016)
3 Anti Corruption Law of the Kingdom of Cambodia, 2010, Article 11, http://www.cambodiainvestment.gov.kh/land-law_010430.html (last accessed 4th June 2016); Radio Free
Asia, Hun Sen declares assets, 1st April 2011, http://www.rfa.org/english/news/cambodia/
assets-04012011163501.html (last accessed 5th June 2016); Phnom Penh Post, Hun Sen set
to declare assets, 1st April 2011, http://www.phnompenhpost.com/national/hun-sen-set-declare-assets (last accessed 5th June 2015)
4 Anti Corruption Law of the Kingdom of Cambodia, 2010, Articles 13, 17, 18 & 38, http://
www.cambodiainvestment.gov.kh/land-law_010430.html (last accessed 4th June 2016);
Radio Free Asia, Hun Sen declares assets, 1st April 2011, http://www.rfa.org/english/news/
cambodia/assets-04012011163501.html (last accessed 5th June 2016);
5 Transparency International, Corruption Perception Index, 2015, http://www.transparency.
org/cpi2015#results-table (last accessed 5th June 2016)
6 Radio Free Asia, Hun Sen declares assets, 1st April 2011, http://www.rfa.org/english/news/
cambodia/assets-04012011163501.html (last accessed 5th June 2016)
7 Brad Adams, New York Times, 10,000 Days of Hun Sen, 31st May 2012, http://www.
nytimes.com/2012/06/01/opinion/10000-days-of-hun-sen.html (last accessed 4th June2016); Sebastian Strangio, Hun Sen’s Cambodia, 2014, p.134, https://books.google.
co.uk/books?id=xRY2BQAAQBAJ&pg=PA134&lpg=PA134&dq=sebastian+strangio,+combined+wealth+billion+dollars&source=bl&ots=ecSAtu2foe&sig=U0fHEy6D9svsP2KdG2Ca8hm1uc4&hl=en&sa=X&ved=0ahUKEwiYyMqR5eDKAhWGXBQKHXtJDTYQ6AEIKTAB#v=onepage&q=sebastian%20strangio%2C%20combined%20wealth%20billion%20dollars&f=false(last accessed 5th June 2016)18 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry, data extracted in December 2014 and February 2016 by Global Witness. All data accessible at https://cambodiacorporates.globalwitness.org/. For informationon company type download the raw data spreadsheets of company registrations.
19 Human Rights Watch, 30 Years of Hun Sen - Violence, Repression, and Corruption in
Cambodia, January 2015, pp.2 & 22, https://www.hrw.org/sites/default/files/reports/cambodia0115_ForUpload.pdf (last accessed 3rd June 2016);
20 Human Rights Watch, 30 Years of Hun Sen - Violence, Repression, and Corruption in
Cambodia, January 2015, p.3, https://www.hrw.org/sites/default/files/reports/cambodia0115_ForUpload.pdf (last accessed 3rd June 2016);
21 Human Rights Watch, 30 Years of Hun Sen - Violence, Repression, and Corruption in
Cambodia, January 2015, pp.49, 50-51, 54-55, https://www.hrw.org/sites/default/files/
reports/cambodia0115_ForUpload.pdf (last accessed 4th June 2016); Human Rights Watch,Cambodia: Threats, Intimidation Mar Campaign, 26th July 2008, https://www.hrw.org/
news/2008/07/26/cambodia-threats-intimidation-mar-campaign (last accessed 5th June2016)
22 Human Rights Watch, 30 Years of Hun Sen - Violence, Repression, and Corruption in
Cambodia, January 2015, p.2, https://www.hrw.org/sites/default/files/reports/cambodia0115_ForUpload.pdf (last accessed 3rd June 2016);
23 Office of the United States Trade Representative, https://ustr.gov/countries-regions/southeast-asia-pacific/Cambodia- (last accessed 2nd June 2016); Royal Embassy of Cambodia
to UK, Denmark, Finland, Ireland, Norway, Sweden, Ethiopia and African Union, Investing
Cambodia, 2013-2014, p.20, http://www.cambodianembassy.org.uk/publications/PDF/
Tourism/Investing%20in%20Cambodia%202013-2014.pdf (last accessed 5th June 2016);
Organisation for Economic Co-operation and Development (OECD) website, Aid at a glancecharts, https://public.tableau.com/views/OECDDACAidataglancebyrecipient_new/Recipients?:embed=y&:display_count=yes&:showTabs=y&:toolbar=no?&:showVizHome=no (select‘Cambodia’ from the drop down menu – last accessed 5th June 2016)
24 CNN, In Cambodia, John Kerry balances trade ties with warning on human rights, 26th
January 2016, http://edition.cnn.com/2016/01/26/asia/kerry-cambodia-human-rights/ (lastaccessed 5th June 2016)

8 Human Rights Watch, 30 Years of Hun Sen - Violence, Repression, and Corruption in
Cambodia, January 2015, pp.1, 42-44 & 55, https://www.hrw.org/sites/default/files/reports/
cambodia0115_ForUpload.pdf (last accessed 5th June 2016); Human Rights Council, United
Nations General Assembly, Report of the Working Group on the Universal Periodic Review– Cambodia, 27th March 2014, pp.10,12,13 & 15, https://documents-dds-ny.un.org/doc/
UNDOC/GEN/G14/127/27/PDF/G1412727.pdf?OpenElement (last accessed 5th June 2016);
United Nations General Assembly, Report of the Working Group on the Universal Periodic
Review – Cambodia, 4th January 2010, pp.10, 18 & 55, http://lib.ohchr.org/HRBodies/UPR/
Documents/Session6/KH/A_HRC_13_4_KHM_E.pdf (last accessed 5th June 2016);

25 Remarks by President Barak Obama at opening session of US-ASEAN summit, WhiteHouse press office, 15th February 2016, https://www.whitehouse.gov/the-press-office/2016/02/15/remarks-president-obama-opening-session-us-asean-summit (last accessed
5th June 2016); Diplomat, What did the US-ASEAN Sunnylands Summit achieve?, 18th
February 2016, http://thediplomat.com/2016/02/what-did-the-us-asean-sunnylands-summit-achieve/ (last accessed 5th June 2016); Reuters, Obama, Southeast Asia leaders eye
China and trade at California summit, 16th February 2016, http://www.reuters.com/article/
us-usa-asean-idUSKCN0VO0GO (last accessed 5th June 2016); LA Times, Obama hosts
ASEAN summit, a first in the US, 15th February 2016, http://www.latimes.com/world/asia/
la-fg-asean-summit-qa-20160215-story.html (last accessed 5th June 2016)

9 This comprises 21 members of the family, including three of Hun Sen’s children, all five of
his children-in-law and numerous members of his extended family, including his younger
sister and some of his nieces and nephews and their spouses.

26 CNN, In Cambodia, John Kerry balances trade ties with warning on human rights, 26th
January 2016, http://edition.cnn.com/2016/01/26/asia/kerry-cambodia-human-rights/ (lastaccessed 5th June 2016)

10 Human Rights Watch, Cambodia: New Waves of Repression, 27th January 2016, https://www.hrw.org/news/2016/01/27/cambodia-new-waves-repression (last accessed 5th June
2016)

27 Khmer Times, Cambodia is open for business, PM tells Americas, 15th February 2016,
http://www.khmertimeskh.com/news/21410/cambodia-is-open-for-investment--pm-tellsamerica/ (last accessed 5th June 2016);

11 World Bank, Poverty has fallen, yet many Cambodians are still at risk of slipping back intopoverty, new report finds, 20th February 2014, http://www.worldbank.org/en/news/press-release/2014/02/20/poverty-has-fallen-yet-many-cambodians-are-still-at-risk-of-slipping-backinto-poverty (last accessed 5th June 2016)28 Council for the Development of Cambodia, Cambodian Investment Board and Cambodian Special Economic Zone Board website, Investment Trend, http://www.cambodiainvestment.gov.kh/investment-enviroment/investment-trend.html (last accessed 2nd June 2016)

12 United Nations Development Programme (UNDP) website, About Cambodia, http://www.
kh.undp.org/content/cambodia/en/home/countryinfo.html (last accessed 5th June 2016)13 Sebastian Strangio, Hun Sen’s Cambodia, 2014, p.134, https://books.google.co.uk/
books?id=xRY2BQAAQBAJ&pg=PA134&lpg=PA134&dq=sebastian+strangio,+combined+wealth+billion+dollars&source=bl&ots=ecSAtu2foe&sig=U0fHEy6D9svsP2KdG2Ca8hm1uc4&hl=en&sa=X&ved=0ahUKEwiYyMqR5eDKAhWGXBQKHXtJDTYQ6AEIKTAB#v=onepage&q=sebastian%20strangio%2C%20combined%20wealth%20billion%20dollars&f=false(last accessed 5th June 2016)
14 This comprises 21 members of the family, including three of Hun Sen’s children, all fiveof his children-in-law and numerous members of his extended family, including his younger
sister and some of his nieces and nephews and their spouses.
15 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry, data extracted in December 2014 and February 2016 by Global Witness. All data accessible at https://cambodiacorporates.globalwitness.org/. For informationon company capital download the raw data spreadsheets of company registrations.
16 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry, data extracted in December 2014 and February 2016 by Global
Witness. All data accessible at https://cambodiacorporates.globalwitness.org/; Note that
25% is suggested by the Financial Action Task Force (the body that sets the internationalanti-money standards) as the threshold at which a person becomes a “beneficial owner”, or
ultimate owner, of a company. See Financial Action Task Force, International Standards on
Combating Money Laundering and the Financing of Terrorism & Proliferation, February 2012,
p.60 http://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recommendations.pdf (last accessed 8th June 2016)17 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry, data extracted in December 2014 and February 2016 by Global
Witness. All data accessible at https://cambodiacorporates.globalwitness.org/

29 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry, data extracted in December 2014 and February 2016 by Global
Witness. For a complete list of companies linked to the Hun family see the infographic on
page 16 or Annex 1 on page 33.
30 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry, data extracted in December 2014 and February 2016 by Global Witness. All data accessible at https://cambodiacorporates.globalwitness.org/. For informationon company capital download the raw data spreadsheets of company registrations; For acomplete list of companies linked to the Hun family see the infographic on page 16 or Annex
1 on page 33.
31 Sebastian Strangio, Hun Sen’s Cambodia, 2014, p.134, https://books.google.co.uk/
books?id=xRY2BQAAQBAJ&pg=PA134&lpg=PA134&dq=hun+family+shell+companies&source=bl&ots=ecTBnr9frl&sig=2ED9hIEYx2dkMjqcJqQiTETszIc&hl=en&sa=X&ved=0ahUKEwjsm5_O5o7NAhUFJsAKHR9-D08Q6AEIHDAA#v=onepage&q=hun%20family%20
shell%20companies&f=false (last accessed 4th June 2016); The agriculture company
Timbergreen that was linked to an illegal logging syndicate operating in Koh Kong province
and whose former employee was charged with murder over the killing of forest activist Chut
Wutty in 2012 is also rumored to be a Hun business by proxy. The link has never been provenbut the company does share an address with a number of sand dredging companies all
directed by individuals with business ties to the Hun family.
32 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R18831,A1009,A2247; Phnom Penh Post, Fight gets venomous, 31st October
2013, http://www.phnompenhpost.com/national/fight-gets-venomous (last accessed 3rdJune 2016); Phnom Penh Post, First snakes, now ‘arson’, 18th March 2014, http://www.
phnompenhpost.com/national/first-snakes-now-%E2%80%98arson%E2%80%99 (lastaccessed 3rd June 2016); Phnom Penh Post, For communities, threats routine, 8th May 2014,
http://www.phnompenhpost.com/national/communities-threats-routine (last accessedHOSTILE TAKEOVER JULY 2016 43

4th June 2016); Official government data from the Cambodian Ministry of Commerce’s
online corporate registry - extracted in December 2014 and February 2016 by Global Witness.
Accessible on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/
search?type=ids&id=R22816; Cambodia Daily, Hun Sen’s sister linked to private security firm
at SL factory, 14th November 2013, https://www.cambodiadaily.com/archives/hun-sens-sister-linked-to-private-security-firm-at-sl-factory-46946/ (last accessed 4th June 2016)
33 Licadho, press release, LICADHO Calls for Restoration of Open Access to Companies
Register, 25th June 2015, http://www.licadho-cambodia.org/pressrelease.php?perm=387(last accessed 5th June 2015)34 Royal Government of Cambodia Ministry of Commerce company registration database,
http://www.moc.gov.kh/en-us/company-registration (last accessed April 2016). Note that thewebsite is often unavailable.
35 Licadho, Going offline? The threat to Cambodia’s new found internet freedoms, May 2015,
p.16, https://www.licadho-cambodia.org/reports/files/205LICADHOReport-GoingOfflineInternetFreedoms-English.pdf (last accessed 5th June 2016); Asian Correspondent, Cambodia
asks Interpol to help nab Facebook user for insulting PM’s wife, 20th January 2016, https://asiancorrespondent.com/2016/01/cambodia-asks-interpol-to-help-nab-facebook-user-forinsulting-pms-wife/ (last accessed 4th June 2016); Cambodia Daily, Hun Manet launches
lawsuit over Facebook post, 23rd January 2016, https://www.cambodiadaily.com/news/hunmanet-launches-lawsuit-over-facebook-post-106215/ (last accessed 4th June 2016); Cambodia Daily, Police arrest free woman in latest facebook case, 26th January 2016, https://www.cambodiadaily.com/news/police-arrest-free-woman-in-latest-facebook-case-106377/(last accessed 4th June 2016); Associated Press (AP), Cambodian to appeal jail sentence for
Facebook comment, 16th March 2016, http://bigstory.ap.org/article/db63270ac5d849d3bb673b66c279fc44/cambodian-appeal-jail-sentence-facebook-comment (last accessed 4thJune 2016)36 Licadho, New Draft Law Reaffirms Culture of Control , 11th June 2015, p.1, http://www.
licadho-cambodia.org/reports/files/207LICADHOMemo-LANGODraftJune2015-English.pdf.
pdf (last accessed 5th June 2016)37 Licadho, Cambodia’s Law On Telecommunications - A Legal Analysis, March 2016, pp.1-2,
https://www.licadho-cambodia.org/reports/files/214LICADHOTelecomsLawLegalAnalysis_March2016ENG.pdf (last accessed 5th June 2016)
38 Licadho, Going offline? The threat to Cambodia’s new found internet freedoms, May 2015,
p.16, https://www.licadho-cambodia.org/reports/files/205LICADHOReport-GoingOfflineInternetFreedoms-English.pdf (last accessed 5th June 2016);
39 United Nations Development Programme (UNDP) website, About Cambodia, http://www.
kh.undp.org/content/cambodia/en/home/countryinfo.html (last accessed 5th June 2016)
40 Human Rights Watch, 30 Years of Hun Sen - Violence, Repression, and Corruption in
Cambodia, January 2015, pp.48, 52 & 54, https://www.hrw.org/sites/default/files/reports/
cambodia0115_ForUpload.pdf (last accessed 5th June 2016); Voice of America, Opposition
Leader Claims He Was Right to Choose Exile, 5th May 2016, http://www.voacambodia.com/a/
opposition-leader-claims-he-was-right-to-choose-exile/3315539.html (last accessed 5thJune 2016); A number of Cambodians involved in Global Witness’ 2007 Family Trees reportwere forced to leave Cambodia for their own security as well as that of their families.
41 Global Witness, Cambodia Corporates, www.cambodiacorporates.globalwitness.org
42 Phnom Penh Post, Hun Sen gives new cabinet its tasks, 11th December 1998, http://www.
phnompenhpost.com/national/hun-sen-gives-new-cabinet-its-tasks (last accessed 5th June2016); Cambodia Daily, Hun Sen hands more four star promotions to 6 police chiefs, 6th
February 2014, https://www.cambodiadaily.com/archives/hun-sen-hands-more-four-starpromotions-to-6-police-chiefs-51541/ (last accessed 5th June 2016); Reuters, Cambodia’s
ruling party promotes PM’s sons, top allies, 2nd February 2015, http://www.reuters.com/
article/us-cambodia-politics-idUSKBN0L611S20150202#Iz3OoIohm1AOOuHZ.97 (lastaccessed 4th June 2016); Tim Kelsall and Heng Seiha, Effective States and Inclusive Devleopment (esid), The political settlement and economic growth in Cambodia, September 2014,
page 26, http://www.effective-states.org/wp-content/uploads/working_papers/final-pdfs/
esid_wp_37_kelsall_seiha.pdf; Royal Government of Cambodia Ministries of Interiorand Ministry of Land Management, Inter-Ministerial Prakas on Appointment of Cadastral
Commission Members at Municipal and Provincial Levels, No. 076 PK/, 16th July 2002, http://
www.skpcambodia.com/Laws%20&%20Regulations%20of%20the%20Kingdom%20of%20
Cambodia/Property%20&%20Land%20Law/PKJ-MOI-MLUMPC-076-02-Appoint%20PMCC-E.
pdf (last accessed 4th June 2016); Asian Parliamentary Assembly (APA),The 8th Plenary Session, List of Participants, 7-12th December 2015, p.2, http://apa.nac-kh.org/doc/8th/List%20
of%20PARTICIATIONS%20of%20All%20Delegations,%2008%20Dec.%202015.pdf (lastaccessed 4th June 2016); Human Rights Watch, 30 Years of Hun Sen - Violence, Repression,and Corruption in Cambodia, January 2015, p.58, https://www.hrw.org/sites/default/files/
reports/cambodia0115_ForUpload.pdf (last accessed 5th June 2016); Agence Kampuchea
Presse (AKP), Techo Volunteer Youth Doctor Association Provides Free Medical Treatment
for People in Siem Reap Province , 2nd Februray 2015, http://www.akp.gov.kh/?p=57597(last accessed 4th June 2016); Phnom Penh Post, Saint John expands humanitarian services
through Phnom Penh Corps, 7th August 2015, http://www.phnompenhpost.com/post-plus/
saint-john-expands-humanitarian-services-through-phnom-penh-corps (last accessed 4thJune 2016)43 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry, data extracted in December 2014 and February 2016 by Global Witness. All data accessible at https://cambodiacorporates.globalwitness.org/. For a complete
list of companies linked to the Hun family see the infographic on page 16 or Annex 1 on page33.
44 Brad Adams, New York Times, 10,000 Days of Hun Sen, 31st May 2012, http://www.
nytimes.com/2012/06/01/opinion/10000-days-of-hun-sen.html (last accessed 4th June2016); Sebastian Strangio, Hun Sen’s Cambodia, 2014, p.134, https://books.google.

co.uk/books?id=xRY2BQAAQBAJ&pg=PA134&lpg=PA134&dq=sebastian+strangio,+combined+wealth+billion+dollars&source=bl&ots=ecSAtu2foe&sig=U0fHEy6D9svsP2KdG2Ca8hm1uc4&hl=en&sa=X&ved=0ahUKEwiYyMqR5eDKAhWGXBQKHXtJDTYQ6AEIKTAB#v=onepage&q=sebastian%20strangio%2C%20combined%20wealth%20billion%20dollars&f=false(last accessed 5th June 2016); Bertil Lintner, Asia Times, One big happy family, 20th March
2007, http://www.atimes.com/atimes/Southeast_Asia/IC20Ae03.html (last accessed 4thJune 2016); Cambodian Human Rights Taskforce, Hun Sen and Bun Rany’s children, 19th
December 2015, http://www.chrtf.net/2015/12/19/hun-sen-and-bun-ranys-children/ (lastaccessed 2nd June 2016)45 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry, data extracted in December 2014 and February 2016 by Global
Witness. For an overview of the breakdown by sector of companies linked to the Hun family
see figure 1 on page 11. For a complete list of companies linked to the Hun family see theinfographic on page 16 or Annex 1 on page 33.
46 To see the links between the Hun family and trading companies go to Cambodia Corporates (https://cambodiacorporates.globalwitness.org ) and search for the following records:
registration 2425 (Pich Sambath Import Export – Dy Chouch), amendment 1319 (C Pimex– Dy Chouch), amendment 5727 ([Cambodian] International Franchise – Hun Chantha), registration 16024 (Advance Development Group – Hun Chantha), amendment 5727 (CambodianInternational Franchise – Hun Chantha), registration 1002 ([Cambodian] HC Trading – Hun
Chea), registration 2146 (CHLK Trading – Hun Chea), amendment 5147 (PSZ Trading – Hun
Chea), amendment 799, (Eastern [Cambodia] International Investment – Hun Kimleng),
registration 23359 (HKLCH Import Export – Hun Kimleng), amendment 5952 (Worldwide
Investment Group – Hun Kimleng), registration 22816 (Garuda Import Export – Hun Seng Ny),amendment 5841 (UNT Wholesale – Hun Seng Ny), amendment 4769 (Attwood Investment
Group – Hun Seng Ny), registration 20441 (NLC Import Export – Leang Vouch Chheng), registration 13625 (Soma Kova Holding – Sok Puthyvuth), registration 17887 (Macchoem Bopea
Trading Group – Yim Chhay Lin), registration 18831 (Khun Sea Import Export – Yim Leang)
47 World Bank World Integrated Trade Solution website, Cambodia Trade Summary 2013
Data, http://wits.worldbank.org/CountryProfile/en/Country/KHM/Year/2013/Summary (lastaccessed 1st June 2016)48 Dev Kar and Joseph Spanjers, Global Financial Integrity, Illicit Financial Flows from
Developing Countries: 2004-2013, December 2015, p.34 and p.36, http://www.gfintegrity.org/
wp-content/uploads/2015/12/IFF-Update_2015-Final.pdf (last accessed 1st June 2016)49 Global Financial Integrity website, Trade Misinvoicing page, http://www.gfintegrity.org/
issue/trade-misinvoicing/ (last accessed 1st June 2016)
50 Global Witness, The Cost of Luxury, February 2015, pp.20-21 https://www.globalwitness.
org/documents/17788/the_cost_of_luxury_1.pdf (last accessed 1st June 2016)
51 To see the links between the Hun family and four agricultural companies go to Cambodia
Corporates (https://cambodiacorporates.globalwitness.org) and search for the following
records: registration 2728 (Rithmony Samnang Leap – Seang Keang), registration 1435 (SomaEver Green – Sok Puthyvuth), amendment 8441 (Khmer Latex – Pich Chanmony) and amendment 2247 (Khun Sea Import Export – Yim Leang); Food and Agriculture Organization of theUnited Nations (FAO), Country fact sheet on food and agriculture policy trends: Cambodia,
April 2014, p.1, http://www.fao.org/docrep/field/009/i3761e/i3761e.pdf (last accessed 1stJune 2016).
52 To see the links between the Hun family and mining companies go to Cambodia Corporates (https://cambodiacorporates.globalwitness.org) and search for the following records:
registration 16097 (The VC Group – Dy Vichea), registration 16769 (Metal Mining Cambodia Co– Hun Seng Ny), amendment 8006 (Metal Mining Cambodia PLC – Hun Seng Ny), amendment
5415 (Worldwide Investment Incorporation - Hun Kimleng), amendment 1570 Phu Yang
Cambodia – Yim Chhay Lin) and amendment 1214 (Sovannaphum Mine Exploration & Development – Yim Chhay Linn); For information on the mining licences held by these companies
see the following sources of information:• Worldwide Investment Incorporation company website, Mining page, http://www.worldwidegroup.com.kh/portfolio/mining/ (last accessed 1st June 2016). Company Worldwide
Investment Group - concession in Oddar Meanchey province.
• Phnom Penh Securities PLC, Mining Sector in Cambodia, June 2011, p.4, http://www.pps.
com.kh/PPSWEB/PPSUploadFiles/iv/161_en-us.pdf (last accessed 1st June 2016). Company
Phu Yang – concessions in Battambang and Pailin provinces.
• Ministry of Industry, Mines and Energy Exploration License No 532, August 4, 2008, http://
www.opendevelopmentcambodia.net/references/Exploration_License_Titan_Mineral_Group__04.08.2008.pdf (last accessed 1st June 2016). Company VC Group – concessions
in Stung Treng and Preah Vihear.
53 Natural Resource Governance Institute website, http://www.resourcegovernance.org/
our-work/country/cambodia (last accessed 1st June 2016)
54 Global Witness website, Cambodia page, https://www.globalwitness.org/en-gb/campaigns/cambodia/
55 Phnom Penh Post, Approved construction investments up 30 per cent in 2015, 14th
January 2016, http://www.phnompenhpost.com/real-estate/approved-construction-investments-30-cent-2015 (last accessed 1st June 2016)
56 To see the links between the Hun family and seven construction companies go to
Cambodia Corporates (https://cambodiacorporates.globalwitness.org) and search for thefollowing records: registration 5424 (Fortress Construction – Hun Chantha), amendment5952 (Worldwide Investment Group – Hun Kimleng), registration 25207 (Soma Construction& Development – Sok Puthyvuth), registration 12380 (Emperor Group – Dy Vichea), registration 1850 (NVN Corporation – Hun Mana), registration 32257 (Orkide Villa 3 – Hun Mana),registration 18831 (Khun Sea Import Export – Yim Leang); Phnom Penh Post, Rules being

44

ignored amid building boom, 2nd March 2016, http://www.phnompenhpost.com/national/
rules-being-ignored-amid-building-boom (last accessed 1st June 2016)
57 Reporters Without Borders and the Cambodian Centre for Independent Media, Who Owns
the Media? Media Ownership Monitor (MOM) project website, data from 2015, http://momkh.com/en/pages/concentration & http://mom-kh.com/en/pages/affiliations (last accessed
1st June 2016)
58 Official government data from the Cambodian Ministry of Commerce’s online
corporate registry - extracted in December 2014 and February 2016 by Global Witness.
Accessible on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/
search?type=ids&id=A7110 & https://cambodiacorporates.globalwitness.org/search?type=ids&id=A473,R6193; Reporters Without Borders and the Cambodian Centre for
Independent Media, Who Owns the Media? Media Ownership Monitor (MOM) project website,data from 2015, http://mom-kh.com/en/companies/11 & http://mom-kh.com/en/print_media/27
59 Freedom House, Freedom of the Press 2015, Cambodia page on website, https://freedomhouse.org/report/freedom-press/2015/cambodia (last accessed 1st June 2016)
60 Analysis conducted by Global Witness based on official Cambodian government datacollated and displayed on the Open Development Mekong website, https://cambodia.opendevelopmentmekong.net/profiles/special-economic-zones/ (last accessed 1st June 2016)
61 Council for the Development of Cambodia, Cambodian Investment Board and Cambodian Special Economic Zone Board website, http://www.cambodiainvestment.gov.kh/
incentives.html (last accessed 1st June 2016)
62 The statistics portal website, Cambodia: export of goods from 2005 to 2015, http://www.
statista.com/statistics/438746/export-of-goods-to-cambodia/ (last accessed 1st June 2016);
The Cambodia Herald, Cambodia’s 2015 goods export value up about US $4.5 Billion, 11th
December 2015, http://thecambodiaherald.com/cambodia/cambodia%E2%80%99s-2015goods-export-value-up-about-us-45-billion-9106 (last accessed 1st June 2016)
63 Council for the Development of Cambodia, Cambodian Investment Board and Cambodian Special Economic Zone Board website, http://www.cambodiainvestment.gov.kh/legalframe-for-the-special-economic-zone-sez-scheme.html & http://www.cambodiainvestment.
gov.kh/about-us/who-we-are.html (last accessed 1st June 2016)
64 Council for the Development of Cambodia, Cambodian Investment Board and Cambodian Special Economic Zone Board website, http://www.cambodiainvestment.gov.kh/
about-us/what-we-can-provite.html, (last accessed 1st June 2016)
65 Official Cambodian government data collated and displayed on the Open Development
Mekong website, https://cambodia.opendevelopmentmekong.net/profiles/special-economic-zones/ (last accessed 1st June 2016)

Export – Hun To), amendment 6749 (LHR Asean Import Export – Hun To), amendment 6529
(Kampuchea Tela – Bun Rany under her birth name Bun Sam Heang) and amendments 6979
and 7920 (Cambodia Electricity Private – Hun Mana, Hun Manith, Hun Maly, Dy Vichea and
Men Pheakdey)
75 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R3327,A7766. For information on company capital download the raw data
spreadsheets of company registrations from Cambodia Corporates.
76 Soma Energy company website, http://www.somaenergy.com.kh/project.php#.VmXCYTEnwqM (last accessed 2nd June 2016)
77 General Electric company fact sheet, date unknown, p.2 http://www.ge.com/cb/
docs/1443625388354_FACT_SHEET_CB_Sept_15.pdf (last accessed 2nd June 2016)
78 Sydney Morning Herald, Drugs: our man in Cambodia, 26th March 2012, http://www.smh.
com.au/national/investigations/drugs-our-man-in-cambodia-20120325-1vsiz.html (lastaccessed 2nd June 2016); Phnom Penh Post, Drug connection denied, 27th March 2012,
http://www.phnompenhpost.com/national/drug-connection-denied (last accessed 4thJune 2016); Cambodia Daily, Hun To hits back at allegations of drug smuggling, 19th March
2012, https://www.cambodiadaily.com/archives/hun-to-hits-back-at-allegations-of-drugsmuggling-1576/ (last accessed 4th June 2016); Voice of America Khmer, Hun Sen Nephew
Denies Australian Report of Drug Trafficking, 26th March 2012, http://www.voacambodia.
com/a/hun-sen-nephew-denies-australian-report-of-drug-trafficking-144286045/1353234.
html (last accessed 4th June 2016); Official government data from the Cambodian Ministryof Commerce’s online corporate registry - extracted in December 2014 and February 2016
by Global Witness. Accessible on Cambodia Corporates at https://cambodiacorporates.
globalwitness.org/search?type=ids&id=A6749 & https://cambodiacorporates.globalwitness.
org/search?type=ids&id=R20011
79 Visions Cambodia, Weekly publication of the Royal Embassy of Cambodia to UK,
Denmark, Finland, Ireland, Norway, Sweden, Ethiopia and African Union, Issue 11: 7th -13th
March 2016, p.2 http://www.cambodianembassy.org.uk/publications/PDF/Visions_of_Cambodia/2014/Newsletter%20Issue%2011_%2007%20-%2013%20MAR%202016.pdf (lastaccessed 2nd June 2016); Links to online listings of LHR petrol stations include:• Yellow Pages Cambodia, http://yp.com.kh/listings/kh53592-lhr-gas-station-2• Facebook, https://www.facebook.com/pages/Lhr-Gas-Station/183972255024182• Four Square, https://foursquare.com/v/lhr-petrol-station/4f407e00e4b020398cac8bc2• Glopoi, https://glopoi.com/cambodia/places/lhr-gas-station-petrol-pump-mphey-osakphea-svay-pao-batd%C3%A2mb%C3%A2ng

66 Analysis conducted by Global Witness based on official Cambodian government datacollated and displayed on the Open Development Mekong website, https://cambodia.opendevelopmentmekong.net/profiles/special-economic-zones/ (last accessed 1st June 2016)• Trip Advisor, https://www.tripadvisor.co.uk/ShowUserReviews-g1893367-d4206543-r37650
0416-Adventure_Rider_Asia_Motorcycle_Private_Tours-Sen_Monorom_Mondulkiri_Province.html

67 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A939; Official Cambodian government data collated and displayed on the Open
Development Mekong website, https://cambodia.opendevelopmentmekong.net/profiles/
special-economic-zones/?map_id=6 (last accessed 1st June 2016)• Vacations map, http://www.vacationsmap.com/en/cambodia/poi/fuel/lhr-map (all sources
last accessed on 2nd June 2016)

68 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R20441; Official Cambodian government data collated and displayed on theOpen Development Mekong website, https://cambodia.opendevelopmentmekong.net/
profiles/special-economic-zones/?map_id=22 (last accessed 1st June 2016)
69 Kongchheng Poch, Economic Institute of Cambodia, August 2012, Cambodia’s Electricity
Sector in the Context of Regional Electricity Market, Integration, p.3, http://www.eria.org/
Chapter%207-Cambodia’s%20Electricity%20Sector%20in%20the%20Context%20of%20
Regional%20Electricity%20Market%20Integration.pdf o/wiki/Cambodia_Energy_Situation(last accessed 2nd June 2016)70 Phnom Penh Post, Power bill spike raises alarm, 3rd July 2015, http://www.phnompenhpost.com/national/power-bill-spikes-raise-alarm (last accessed 2nd June 2016)
71 Khmer Times, Consumers demand lower gas prices, 21st October 2015, http://www.
khmertimeskh.com/news/17022/consumers-demand-lower-gas-prices/ (last accessed 2ndJune 2016)
72 Mark Grimsditch, 3S Rivers Protection Network and International Rivers, 2012, 3S Rivers
Under Threat: Understanding new threats and challenges from hydropower development
to biodiversity and community rights in the 3S River Basin, pp.15-16, http://www.internationalrivers.org/files/attached-files/3s_rivers_english.pdf (last accessed 3rd June 2016);
World Bank data shows Cambodia’s rural population from 2011-2014 as 12,183,722 in a total
population of 15.33 million (79.48%). World Bank website, Rural population, http://data.
worldbank.org/indicator/SP.RUR.TOTL & http://data.worldbank.org/country/cambodia (lastaccessed 3rd June 2016).
73 The Cambodia Herald, Hun Sen says all villages to have electricity by 2020, 20th February
2013, http://www.thecambodiaherald.com/cambodia/hun-sen-says-all-villages-to-haveelectricity-by-2020-3449 (last accessed 2nd June 2016)
74 To see the links between the Hun family and energy companies go to Cambodia Corporates (https://cambodiacorporates.globalwitness.org) and search for the following records:
registration 3327 (Soma Energy – Sok Puthyvuth, registration 20011 (LHR Asean Import

80 Note that the company is listed as ‘(Cambodia) Electricity Private Co., Ltd C.E.P’ by
the Ministry of Commerce; Electric Authority of Cambodia, Report on power sector of
the Kingdom of Cambodia, 2013 edition, annex 3, p.77, http://eac.gov.kh/wp-content/
uploads/2014/07/report-2012en.pdf (last accessed 2nd June 2016); Electric Authority of
Cambodia, Report on power sector of the Kingdom of Cambodia, 2015 edition, annex 3,
p.88 http://eac.gov.kh/wp-content/uploads/2015/07/report-2014en.pdf (last accessed 2ndJune 2016); Official government data from the Cambodian Ministry of Commerce’s online
corporate registry - extracted in December 2014 and February 2016 by Global Witness.
Accessible on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/
search?type=ids&id=A6979,A7920; Electric Authority of Cambodia, Decision on first revisionof the license document no.132LD dated May 31 , 2006 for (Cambodia) Electricity Private Co.,
Ltd. for providing electric power generation service at Phnom Penh city for revising ownership of licensee, 27th November 2013. Document obtained by Global Witness investigatorsin October 2015.
81 Electric Authority of Cambodia, Report on power sector of the Kingdom of Cambodia,
2013 edition, annex 3, p.77, http://eac.gov.kh/wp-content/uploads/2014/07/report-2012en.
pdf (last accessed 2nd June 2016); Electric Authority of Cambodia, Report on power sectorof the Kingdom of Cambodia, 2015 edition, annex 3, p.88 http://eac.gov.kh/wp-content/uploads/2015/07/report-2014en.pdf (last accessed 2nd June 2016)82 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A6979,A7920; Electric Authority of Cambodia, Decision on first revision of thelicense document no.132LD dated May 31 , 2006 for (Cambodia) Electricity Private Co., Ltd.
for providing electric power generation service at Phnom Penh city for revising ownershipof licensee, 27th November 2013. Document obtained by Global Witness investigators in
October 2015.
83 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A6979,A7920
84 1998 General Statute of Military Personnel of the Royal Cambodian Armed Forces, Article
25, p.4, https://www.ilo.org/dyn/natlex/docs/ELECTRONIC/93508/109344/F811412622/
KHM93508%20Eng.pdf (last accessed 2nd June 2016)85 Bun Rany’s shareholding in Kampuchea Tela was listed under her birth name of ‘BunHOSTILE TAKEOVER JULY 2016 45

Sam Heang’; Harish C. Mehta, Julie B. Mehta, Strongman: The Extraordinary Life of Hun Sen,
15th May 2013, pp16, 28 & 389, https://books.google.com.kh/books?id=2SqJAAAAQBAJ&pg=PA389&lpg=PA389&dq=un+rany+sam+hieng&source=bl&ots=7y1vaYi4oq&sig=xN5KskSgIQhDItuJuIR5aPGqX9c&hl=en&sa=X&ved=0ahUKEwjn3v_Kg7DJAhUBkpQKHaY3D_oQ6AEIJjAB#v=onepage&q=Bun%20sam%20hieng&f=false (last accessed 2nd June 2016); Official
government data from the Cambodian Ministry of Commerce’s online corporate registry- extracted in December 2014 and February 2016 by Global Witness. Accessible on Cambodia
Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A6529
86 Cambodia Daily, Elite’s children find love in a hot political climate, 17th January 2004,
https://www.cambodiadaily.com/archives/elites-children-find-love-in-a-hot-political-climate-870/ (last accessed 2nd June 2016); Cambodia Daily, Sokimex, Tela wins gov’t oil bid,
‘big family’ bows out, 5th March 2004, https://www.cambodiadaily.com/archives/sokimextela-win-govt-oil-bid-big-family-bows-out-38792/ (last accessed 2nd June 2016)
87 Cambodia Daily, Sokimex, Tela wins gov’t oil bid, ‘big family’ bows out, 5th March 2004,
https://www.cambodiadaily.com/archives/sokimex-tela-win-govt-oil-bid-big-family-bowsout-38792/ (last accessed 2nd June 2016)
88 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R18807
89 Conversations between Global Witness investigators and well-placed sources inside
Cambodia; Khmer Intelligence Yahoo Group, 23rd May 2005, https://groups.yahoo.com/
neo/groups/khmerintelligence/conversations/topics/522?var=1 (last accessed 2nd June2016); Sebastian Strangio, Hun Sen’s Cambodia, 2014, pp. 133, https://books.google.co.uk/
books?id=xRY2BQAAQBAJ&pg=PA133&dq=hun+sen+and+kampuchea+tela&hl=en&sa=X&ved=0ahUKEwiPpantlonNAhVqJMAKHSrGC_IQ6AEIJTAA#v=onepage&q=hun%20sen%20
and%20kampuchea%20tela&f=false (last accessed 2nd June 2016)
90 Associated Press (AP), Call him Lord Prime Minister: Cambodia wants PM’s title used, 12th
May 2016, http://bigstory.ap.org/article/f9830936773f42dfa809b2e2de74283e/call-me-lordprime-minister-cambodia-wants-pm-title-used (last accessed 5th June 2016)
91 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry - extracted in December 2014 and February 2016 by Global Witness.
Hun Mana’s individual business holdings are listed in the infographic on page 16 or Annex 1
on page 33. The raw data can be found on Cambodia Corporates at https://cambodiacorporates.globalwitness.org.
92 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry - extracted in December 2014 and February 2016 by Global Witness.
Hun Mana’s individual business holdings are listed in the infographic on page 16 or Annex 1
on page 33. The raw data can be found on Cambodia Corporates at https://cambodiacorporates.globalwitness.org.
93 Email to Global Witness from a well-placed source in Cambodia who must remain anonymous, 11th May 2016.
94 Reporters Without Borders and the Cambodian Centre for Independent Media, Who Owns
the Media? Media Ownership Monitor (MOM) project website, data from 2015, http://momkh.com/en/pages/owner (last accessed 2nd June 2016)95 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A7110
96 Reporters Without Borders and the Cambodian Centre for Independent Media, Who Owns
the Media? Media Ownership Monitor (MOM) project website, data from 2015, http://momkh.com/en/companies/11%20/ & http://mom-kh.com/en/radio_media/21 (last accessed 1stJune 2016)
97 Based on an incomplete list of military-corporate sponsorships obtained by Global
Witness in 2010. For additional background information, see Global Witness’ press releasepublished when the ‘culture of sharing’ scheme launched: https://www.globalwitness.
org/en-gb/archive/global-witness-urges-cambodias-donors-condemn-sponsorship-military-units-private-businesses/
98 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R6193,A473; Reporters Without Borders and the Cambodian Centre for
Independent Media, Who Owns the Media? Media Ownership Monitor (MOM) project website,data from 2015, http://mom-kh.com/en/print_media/27 (last accessed 1st June 2016);
Human Rights Watch, Cambodia: Systematic Problems Undermine Elections, 26th July 2013,https://www.hrw.org/news/2013/07/26/cambodia-systematic-problems-undermine-elections (last accessed 2nd June 2016)
99 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A4765,R22109; CMO Group company website, http://www.cmo-group.com/
en/corp_info_milestone.php (last accessed 2nd June 2016); CMO Group annual report 2010,
p.6, http://cmo-group.com/ir/uploads/annual-report/2010_ar_23_en.pdf (last accessed 2ndJune 2016)
100 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A4765

101 Moon Media is listed as ‘Moon Advertising’ on the Ministry of Commerce database;
Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A311,A651; Moon Media company website, http://www.moonmedia.com.kh/(last accessed 2nd June 2016)
102 Moon Media company website, http://www.moonmedia.com.kh/ (last accessed 2ndJune 2016)
103 Moon Media is listed as ‘Moon Advertising’ on the Ministry of Commerce database; Official government data from the Cambodian Ministry of Commerce’s online corporate registry- extracted in December 2014 and February 2016 by Global Witness. Accessible on Cambodia
Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A651
104 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A4617; For information on company capital download the raw data spreadsheets of company registrations from Cambodia Corporates; The Nation Business website,
Thai firms prepare for evacuation, 17th October 2008, http://www.nationmultimedia.
com/2008/10/17/business/business_30086249.php (last accessed 2nd June 2016)
105 Angkor National Museum website, http://www.angkornationalmuseum.com/about_anm/1 (last accessed 2nd June 2016); Tourism Cambodia website, http://www.tourismcambodia.com/travelguides/provinces/siem-reap/what-to-see/426_angkor-national-museum.
htm (last accessed 2nd June 2016)
106 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R3836
107 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible on
Cambodia Corporates athttps://cambodiacorporates.globalwitness.org/search?type=ids&id=R18118,R18119,R18113
108 Helistar company website, http://helistarcambodia.com/category/siem-reap-explorer-tours/ (last accessed 2nd June 2016)
109 Helistar company website, http://helistarcambodia.com/flight-information/helipad-location/ & http://helistarcambodia.com/helistar-cambodia/ (last accessed 2nd June 2016)
110 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A5839; Vital company website, http://vital.com.kh/site/en/company/history.
html (last accessed 2nd June 2016)
111 Vital company website, http://www.vital.com.kh/site/en/qualification/supports.html(last accessed 2nd June 2016)
112 NVC Corporation shares a registered address (No.17, St.55, Sangkat Chak Tomuk,
Khan Daun Penh, Phnom Penh) with companies associated to Lao Meng Khin and his wife
Choeung Sopheap – specifically her brother, Choeung Thean Seng, and daughter, Choeung
Sokuntheavy; Official government data from the Cambodian Ministry of Commerce’s online
corporate registry - extracted in December 2014 and February 2016 by Global Witness.
Accessible on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/
search?type=address&house=No.17&street=55
113 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible on
Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A10055,A2264,A390,A4997 & https://cambodiacorporates.globalwitness.org/search?type=ids&id=A389,A251,A2263; Shukaku Inc and the Boeung Kak Lake land dispute – WorldBank Inspection Panel, Investigation Report, Cambodia: Land Management and Administration Project (Credit No. 3650 - KH), 23rd November 2010, p.27, point 92 and p.31, point
102, http://ewebapps.worldbank.org/apps/ip/PanelCases/60-Investigation%20Report%20(English).pdf (last accessed 2nd June 2016); Pheapimex (listed as ‘Phea Pimex Group’ by
the Ministry of Commerce) – Megan MacInnes, Global Witness, Land is life: An analysis of therole ‘grand’ corruption plays in enabling elite grabbing of land in Cambodia, August 2015,
pp.10-12, https://www.globalwitness.org/documents/18074/Global_Witness_Corruption_
and_large-scale_land_acquisitions_in_Cambodia_reformatted_28Aug15.pdf (last accessed
2nd June 2016)
114 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A4610; Official government data from the Cambodian Ministry of Commerce’s
online corporate registry - extracted in December 2014 and February 2016 by Global Witness.
Accessible on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/
search?type=individual&individual=Kith+Meng; Investine wesbsite, Cambodia’s top 10
tycoons, http://investvine.com/cambodias-top-10-tycoons/ (last accessed 2nd June 2016);
Royal Group company website, http://www.royalgroup.com.kh/who-we-are/milestones.php& http://www.royalgroup.com.kh/who-we-are (last accessed 2nd June 2016); International
Rivers website, Lower Sesan 2 Dam, https://www.internationalrivers.org/campaigns/lowersesan-2-dam (last accessed 2nd June 2016); Specific instance under the OECD Guidelines
for Multinational Enterprises submitted to the Australian National Contact Point (NCP) for theOECD Guidelines by Inclusive Development International and Equitable Cambodia, October
2014, pp2-3, http://www.inclusivedevelopment.net/wp-content/uploads/2014/10/Specific-Instance-against-ANZ-FINAL.pdf (last accessed 2nd June 2014); Khmer Times, Tensions

46

Escalate as Royal Group accelerates island development, 12th August 2015, http://www.
khmertimeskh.com/news/14333/tensions-escalate-as-royal-group-accelerates-island-development/ (last accessed June 2016); Cambodia Daily, Evictions Signal Coastal Development
Dilemma, 23rd March 2016 https://www.cambodiadaily.com/archives/evictions-signal-coastal-development-dilemma-110279/ (last accessed 2nd June 2016)
115 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A311,A5839,A2534 & https://cambodiacorporates.globalwitness.org/search?type=ids&id=R18393; 5 Siblings company website, http://www.5siblings.com/ (last accessed
2nd June 2016); Interview with well-placed source inside Cambodia, October 2015.
116 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R7622,R7623
117 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A2588; Metfone company website, Viettel (Cambodia) Pte. Ltd. (“Metfone”)
and Sotelco ltd. (“Beeline Cambodia”) agreement to licences & assets transfer transaction,
11th March 2015, http://www.metfone.com.kh/en/News/News/VIETTEL-(CAMBODIA)-PTELTD-(-METFONE-)-AND-SOTELCO-LTD-(-BEELINE-CAMBODIA-)-AGRREMENT-TO-LICENCESASSETS-TRANSFER-TRANSACTION-e2-80-8b.248.aspx (last accessed 2nd June 2016); Kim
Kierans, Asia’s Media Innovators – Chapter 7, September 2010, p.4, http://www.kas.de/
wf/doc/1555-1442-2-30.pdf (last accessed 2nd June 2016); Just Landed website, Mobile
networks in Cambodia, https://www.justlanded.com/english/Cambodia/Cambodia-Guide/
Telephone-Internet/Mobile-phones (last accessed 2nd June 2016); Phnom Penh Post,
Beeline bows out to Metfone, 20th March 2015, http://www.phnompenhpost.com/business/beeline-bows-out-metfone (last accessed 2nd June 2016).
118 Kim Kierans, Asia’s Media Innovators – Chapter 7, September 2010, p.4, http://www.kas.
de/wf/doc/1555-1442-2-30.pdf (last accessed 2nd June 2016); Just Landed website, Mobile
networks in Cambodia, https://www.justlanded.com/english/Cambodia/Cambodia-Guide/
Telephone-Internet/Mobile-phones (last accessed 2nd June 2016); Phnom Penh Post,
Beeline bows out to Metfone, 20th March 2015, http://www.phnompenhpost.com/business/beeline-bows-out-metfone (last accessed 2nd June 2016); Tuoi Tre news website, Viettel
dominates Vietnam’s mobile market with $2bn profit in 2015, 30th December 2015, http://
tuoitrenews.vn/business/32499/viettel-dominates-vietnams-mobile-market-with-2bn-profit-in-2015 (last accessed 2nd June 2016)
119 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A2588; Cambodian Human Rights Taskforce, Tea Banh and Tao Toeun’s family,
26th February 2015, http://www.chrtf.net/2015/02/26/tea-banh-and-tao-toeuns-family/ (lastaccessed 2nd June 2016)
120 Cambodia Daily, RCAF should use VN phones, PM says, 9th February 2010, https://www.
cambodiadaily.com/archives/rcaf-should-use-vn-phones-pm-says-96988/ (last accessed 2ndJune 2016)
121 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A4764. For information on company capital download the raw data spreadsheets of company registrations from Cambodia Corporates.
122 Dragon Royal Group company websites, http://www.dragonroyal.com/ & http://www.
dragonroyalcondominium.com/ & http://www.hotel-dragonroyal.com/ (all websites lastaccessed on 2nd June 2016)
123 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A6195; K Thong Huot company website, http://www.kth.com.kh/aboutus.
php?slide=1 (last accessed 2nd June 2016)
124 K Thong Huot company website, http://www.kth.com.kh/aboutus.php?slide=1 (lastaccessed 2nd June 2016)
125 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A6979,A7920; Electric Authority of Cambodia, Decision on first revision of thelicense document no.132LD dated May 31 , 2006 for (Cambodia) Electricity Private Co., Ltd.
for providing electric power generation service at Phnom Penh city for revising ownershipof licensee, 27th November 2013. Document obtained by Global Witness investigators in
October 2015; Electric Authority of Cambodia, Report on power sector of the Kingdom of
Cambodia, 2013 edition, annex 3, p.77, http://eac.gov.kh/wp-content/uploads/2014/07/
report-2012en.pdf (last accessed 2nd June 2016); Electric Authority of Cambodia, Report on
power sector of the Kingdom of Cambodia, 2015 edition, annex 3, p.88 http://eac.gov.kh/
wp-content/uploads/2015/07/report-2014en.pdf (last accessed 2nd June 2016)
126 UN Human Rights Council, Report of the Special Rapporteur on the situation of humanrights in Cambodia, Surya P. Subedi, A human rights analysis of economic and other land
concessions in Cambodia, 24th September 2012, pp.39-40 and p55, http://www.ohchr.org/
Documents/HRBodies/HRCouncil/RegularSession/Session21/A-HRC-21-63-Add1_en.pdf(last accessed 2nd June 2016); Communication Under Article 15 of the Rome Statute of theInternational Criminal Court, The Commission of Crimes Against Humanity in Cambodia

July 2002 to Present, 2014, pp.52,57 & 62. Currently not publicly available due to ongoingproceedings; Specific instance under the OECD Guidelines for Multinational Enterprises submitted to the Australian National Contact Point (NCP) for the OECD Guidelines by Inclusive
Development International and Equitable Cambodia, October 2014, p13, http://www.inclusivedevelopment.net/wp-content/uploads/2014/10/Specific-Instance-against-ANZ-FINAL.pdf(last accessed 2nd June 2014)
127 Official government data from the Cambodian Ministry of Commerce’s online
corporate registry - extracted in December 2014 and February 2016 by Global Witness.
Accessible on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/
search?type=ids&id=R1850 & https://cambodiacorporates.globalwitness.org/search?type=ids&id=A311,A5839,A2534. For information on company capital download the raw data
spreadsheets of company registrations from Cambodia Corporates.
128 NVN Corporation shares a registered address (A75, Russian Blvd, Sangkat Toeuk Thlar,
Khan Sen Sok, Phnom Penh) with companies associated to Lao Meng Khin and his wife
Choeung Sopheap – specifically her brother, Choeung Thean Seng, and daughter, Choeung
Sokuntheavy; NH Holding has links to construction company 5 Sibling & NH which is alsochaired by Choeung Thean Seng; Official government data from the Cambodian Ministryof Commerce’s online corporate registry - extracted in December 2014 and February 2016
by Global Witness. Accessible on Cambodia Corporates at https://cambodiacorporates.
globalwitness.org/search?type=address&house=A75&street=Russian & https://cambodiacorporates.globalwitness.org/search?type=ids&id=A311,A5839,A2534 & https://cambodiacorporates.globalwitness.org/search?type=id&id=R18393; 5 Siblings company website,
http://www.5siblings.com/ (last accessed 2nd June 2016); Interview with well-placed source
inside Cambodia, October 2015.
129 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R32257
130 Official government data from the Cambodian Ministry of Commerce’s online
corporate registry - extracted in December 2014 and February 2016 by Global Witness.
Accessible on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/
search?type=ids&id=R25149 & https://cambodiacorporates.globalwitness.org/search?type=address&house=No.24D&street=566 & https://cambodiacorporates.globalwitness.
org/search?type=ids&id=A6257 & https://cambodiacorporates.globalwitness.org/search?type=ids&id=A2313,A1605
131 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible on
Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=address&house=No.71&street=Samdech+Pan; Note that due to inconsistent spelling, thecompanies’ records don’t appear under the same address heading on Cambodia Corporates.
Scroll down the page to see Orkide Villa 3, which is registered to ‘No.71 St.Samdech Pan ,Sangkat Boeng Pror Let , Khan 7 Makara, Phnom Penh’. Orkide Villa is registered to the same
address but spelt differently as ‘No.71, St.Samdech Pan, Sangkat Boeung Prolit, Khan 7
Makara, Phnom Penh’ and appears in the top section.
132 Khmer Times, Developer Adds Touch of Nature in Luxury Condo Project, 12th November
2015 http://www.khmertimeskh.com/news/17765/developer-adds-touch-of-nature-in-luxury-condo-project (last accessed 2nd June 2015); Orkide Villa company website, http://www.
orkidevilla.com/?id=home#projectinformation (last accessed 2nd June 2016)133 Asian Tigers, African Lions: Comparing the Development Performance of Southeast
Asia and Africa,2013, p465 https://books.google.co.uk/books?id=JcneAQAAQBAJ&pg=PA465&lpg=PA465&dq=title+oknha+given+for+100,000+donation&source=bl&ots=4avfowyNNm&sig=REwdakzkVOScb21mjuPwze2rHHg&hl=en&sa=X&ved=0ahUKEwiSz6eRypPMAhUHVxoKHZMkAXgQ6AEIQDAF#v=onepage&q=title%20oknha%20given%20for%20
100%2C000%20donation&f=false (last accessed 5th June 2016) Cambodia Daily, As okhna
ranks grow, honorific title loses meaning, 21st June 2014, https://www.cambodiadaily.com/
archives/as-oknha-ranks-grow-honorific-loses-meaning-62057/ (last accessed 5th June
2016)
134 International Monetary Fund (IMF), Economic Health Check, Fast-Growing Cambodia
Can Reap Further Benefits from Reforms, 17th November 2015, http://www.imf.org/external/
pubs/ft/survey/so/2015/CAR111715A.htm (last accessed 2nd June 2015); Council for theDevelopment of Cambodia, Investment Environment and Opportunities in Cambodia, 2014,
presentation slides 9 & 24, http://www.cieca.org.tw/ConferenceData.aspx?mrid=698 (lastaccessed 2nd June 2016).
135 Council for the Development of Cambodia, Cambodian Investment Board and Cambodian Special Economic Zone Board website, Investment Trend, http://www.cambodiainvestment.gov.kh/investment-enviroment/investment-trend.html (last accessed 2nd June 2016)
136 Office of the United States Trade Representative, https://ustr.gov/countries-regions/southeast-asia-pacific/Cambodia- (last accessed 2nd June 2016)
137 Office of the United States Trade Representative , https://ustr.gov/about-us/policy-offices/press-office/press-releases/2012/august/us-cambodia-explore-investment-treaty (lastaccessed 2nd June 2016); Khmer Times, Cambodia and United States to sign investment
treaty, 23rd February 2016, http://www.khmertimeskh.com/news/21770/cambodia-andunited-states-to-sign-investment-treaty/ (last accessed 2nd June 2016)
138 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R12909,A4988,A2212. Note that ‘Sok Sopheak’ is spelt 2 different ways but thatboth spellings show chairmanships of companies registered to the address ‘No.4, St.123’;
ione company website, http://ione2u.com/about_ione/ (last accessed 2nd June 2016);
Company website for Cemtes/i-Qlick Marketing, http://cemtes.com/ (last accessed 2nd JuneHOSTILE TAKEOVER JULY 2016 47

2016)
139 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R5729; G Gear company website, http://ggear.com.kh/about-g-gear/ (lastaccessed 2nd June 2016)
140 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A6195; K Thong Huot company website, http://www.kth.com.kh/aboutus.
php?slide=1 (last accessed 2nd June 2016)
141 Microsoft press release, Microsoft officially welcomes the Nokia Devices and Services
business, 25th April 2014, https://news.microsoft.com/2014/04/25/microsoft-officially-welcomes-the-nokia-devices-and-services-business/#sm.0001ro2dptuu5dgw106xmdn0t9u4v(last accessed 20th June 2016)
142 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A651
143 Moon Media company website, http://www.moonmedia.com.kh/ (last accessed 2ndJune 2016)
144 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R25949
145 Cambodia Daily, New Tuol Kok mall to add to district’s growth, 31st December
2013, https://www.cambodiadaily.com/archives/new-tuol-kok-mall-to-add-to-districtsgrowth-49777/; Phnom Penh Shopping website, undated, ,http://phnompenhshopping.
com/shopping-centers/tk-avenue/; Yellow Pages Cambodia website, Guardian Pharmacies,
http://yp.com.kh/listings/kh61431-guardian-pharmacies (all websites last accessed 2ndJune 2016)
146 Soma Group company website, http://www.somagroup.com.kh/index.php/about-soma/our-teams/ (last accessed 2nd June 2016)147 Soma Energy company website, Projects, http://www.somaenergy.com.kh/project.
php#.VmXCYTEnwqM (last accessed 2nd June 2016); Phnom Penh Post, Forum breaks ice,yet more time needed, 16th July 2012, http://www.phnompenhpost.com/business/forumbreaks-ice-yet-more-time-needed (last accessed 2nd July 2016)

corporate registry - extracted in December 2014 and February 2016 by Global Witness.
Accessible on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/
search?type=ids&id=A4769 & https://cambodiacorporates.globalwitness.org/search?type=ids&id=A8453; Attwood Import Export company website, About Us, http://www.
attwoodcambodia.com/about-us.html (last accessed 3rd June 2016)
158 Attwood Import Export company website, http://www.attwoodcambodia.com/aboutus.html & http://www.attwoodcambodia.com/news.html (last accessed 3rd June 2016)
159 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R20726; GHI Enterprise company website, http://www.ghi.hk/ghi_cambodia.
php & http://www.ghi.hk/affiliate.php (last accessed 3rd June 2016)
160 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R6884,A7567,A10029. For information on company capital download the raw
data spreadsheets of company registrations from Cambodia Corporates.
161 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A10029
162 Missionpharma company website, Official Grade A wholesaler letter from USAID , Undated, http://www.missionpharma.com/content/us/about_us/news/2015/official_grade_a_wholesaler_letter_from_usaid (last accessed 3rd June 2016)
163 Matteson Ellis, FCP Americas website, The anatomy of corruption in public procurement,
http://fcpamericas.com/english/anti-corruption-compliance/the-anatomy-of-corruption-in-public-procurement/# (last accessed 3rd June 2016); UK Ministry of Justice, The
Bribery Act 2010: Guidance about procedures which relevant commercial organisations can
put into place to prevent persons associated with them from bribing, March 2011, p.26 http://
www.justice.gov.uk/downloads/legislation/bribery-act-2010-guidance.pdf (last accessed 3rdJune 2016); Organisation for Economic Co-operation and Development (OECD), Convention
on combating bribery of foreign public officials in international business transactions andrelated documents, Article 1.4 & Commentaries on the convention, Article 1. The Offence of
Bribery of Foreign Public Officials: Re paragraph 4, point 12, 2011, http://www.oecd.org/daf/anti-bribery/ConvCombatBribery_ENG.pdf (last accessed 3rd June 2016);
164 Cambodia’s Anti-Corruption Law, 2010, Article 37: Corruption proceeds offences, http://
www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 3rd June2016)

148 Forbes website, The world’s most valuable brands, 2016, http://www.forbes.com/
powerful-brands/list/#tab:rank; Forbes website, The world’s biggest public companies, 2016,
http://www.forbes.com/companies/general-electric/ (last accessed 2nd June 2016)

165 Cambodia’s Anti-Corruption Law, 2010, Article 37: Corruption proceeds offences, http://
www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 3rd June
2016)

149 Official government data from the Cambodian Ministry of Commerce’s online
corporate registry - extracted in December 2014 and February 2016 by Global Witness.
Accessible on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/
search?type=ids&id=R18902 & https://cambodiacorporates.globalwitness.org/search?type=ids&id=A9983

166 Criminal Division of the U.S. Department of Justice and the Enforcement Division of the
U.S. Securities and Exchange Commission, A Resource Guide to the U.S. Foreign Corrupt
Practices Act, 14th November 2012, p.10, http://www.justice.gov/criminal/fraud/fcpa/guidance/guide.pdf (last accessed 3rd June 2016)

150 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A5952; Worldwide Investment Group company website, Food & Beverages,
http://www.worldwidegroup.com.kh/?portfolio=food-beverages (last accessed 3rd June
2016)
151 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible on
Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&
id=R4574,R19133,R7682,R7606,R5734,R5729,A8441 & https://cambodiacorporates.globalwitness.org/search?type=ids&id=A8001
152 Brands Management company website, http://bmlcambodia.com/brands/ (lastaccessed 15th February 2016)
153 Brands Management company website, http://bmlcambodia.com/our-partners/page/2(last accessed 15th February 2016)
154 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R7606; Legend Cinema company website, http://www.legend.com.kh/Browsing(last accessed 3rd June 2016); Move to Cambodia website, Phnom Penh movie theatres,
http://www.movetocambodia.com/art-culture/phnom-penh-movie-theaters/ (last accessed
3rd June 2016)
155 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A5841,A5545. Note that ‘Hun Seng Ny’ is spelt 2 different ways but that bothspellings show chairmanships of companies registered to the address ‘No.139AB, Kampuchea Krom Blvd corner 139’.
156 UNT Wholesale company website, http://www.untwholesale.com/ & http://www.
untwholesale.com/about-us/ (last accessed 3rd June 2016)
157 Official government data from the Cambodian Ministry of Commerce’s online

167 Criminal Division of the U.S. Department of Justice and the Enforcement Division of the
U.S. Securities and Exchange Commission, A Resource Guide to the U.S. Foreign Corrupt
Practices Act, 14th November 2012, p.21, http://www.justice.gov/criminal/fraud/fcpa/guidance/guide.pdf (last accessed 3rd June 2016)
168 Criminal Division of the U.S. Department of Justice and the Enforcement Division of the
U.S. Securities and Exchange Commission, A Resource Guide to the U.S. Foreign Corrupt
Practices Act, 14th November 2012, pp.10-12, http://www.justice.gov/criminal/fraud/fcpa/
guidance/guide.pdf (last accessed 3rd June 2016)
169 Allen & Overy, The Foreign Corrupt Practices Act Guide: A Retreat on Correspondent
Bank Account Jurisdiction Under Section 78dd-3?, http://www.allenovery.com/publications/en-gb/Pages/The-Foreign-Corrupt-Practices-Act-Guide-A-Retreat-on-Correspondent-BankAccount-Jurisdiction-Under-Section-78dd-3.aspx (last accessed 3rd June 2016)
170 UK Ministry of Justice, The Bribery Act 2010: Guidance about procedures which relevant
commercial organisations can put into place to prevent persons associated with them frombribing, March 2011, p.9, http://www.justice.gov.uk/downloads/legislation/bribery-act-2010guidance.pdf (last accessed 3rd June 2016)
171 UK Ministry of Justice, The Bribery Act 2010: Guidance about procedures which relevant
commercial organisations can put into place to prevent persons associated with them frombribing, March 2011, p.10, http://www.justice.gov.uk/downloads/legislation/bribery-act2010-guidance.pdf (last accessed 3rd June 2016)172 UK Ministry of Justice, The Bribery Act 2010: Guidance about procedures which relevant
commercial organisations can put into place to prevent persons associated with them frombribing, March 2011, pp.15-16, http://www.justice.gov.uk/downloads/legislation/bribery-act2010-guidance.pdf (last accessed 3rd June 2016)
173 Australian government, Foreign Bribery: Fact Sheet 2, undated, pp.1-2, https://www.
ag.gov.au/CrimeAndCorruption/Foreignbribery/Documents/Factsheet-Theforeignbriberyoffence.pdf (last accessed 3rd June 2016)
174 Australian government, Foreign Bribery: Fact Sheet 2, undated, p.1, https://www.ag.gov.
au/CrimeAndCorruption/Foreignbribery/Documents/Factsheet-Theforeignbriberyoffence.
pdf (last accessed 3rd June 2016)
175 Organisation for Economic Co-operation and Development (OECD), OECD Convention

48

on Combating Bribery of Foreign Public Officials in International Business Transactions:Ratification Status as of 21 May 2014, http://www.oecd.org/daf/anti-bribery/WGBRatificationStatus.pdf (last accessed 3rd June 2016)
176 Organisation for Economic Co-operation and Development (OECD) website, OECD
Convention on Combating Bribery of Foreign Public Officials in International BusinessTransactions, undated, http://www.oecd.org/corruption/oecdantibriberyconvention.htm(last accessed 3rd June 2016)
177 Organisation for Economic Co-operation and Development (OECD), Convention on
combating bribery of foreign public officials in international business transactions andrelated documents, Article 4.2, 2011, http://www.oecd.org/daf/anti-bribery/ConvCombatBribery_ENG.pdf (last accessed 3rd June 2016); Council for the Development of Cambodia,
Cambodian Investment Board and Cambodian Special Economic Zone Board website,
Investment Trend, http://www.cambodiainvestment.gov.kh/investment-enviroment/investment-trend.html (last accessed 2nd June 2016)
178 BBC website, Australia stock exchange boss resigns amid bribery probe, 21st March
2016, http://www.bbc.co.uk/news/business-35859738 (last accessed 3rd June 2016); Sydney
Morning Herald, ASX chief Elmer Funke Kupper quits in face of investigation, 21st March
2016, http://www.smh.com.au/business/markets/asx-chief-elmer-funke-kupper-quits-inface-of-investigation-20160321-gnn1m3.html (last accessed 3rd June 2016); The Guardian,
21st March 2016, Australian Securities Exchange chief quits over Tabcorp investigation,
http://www.theguardian.com/australia-news/2016/mar/21/australian-securities-exchange-chief-quits-over-tabcorp-investigation (last accessed 3rd June 2016)
179 Global Witness, Country for Sale, 2009, pp.22-23, How Cambodia’s elite has captured thecountry’s extractive industries, https://www.globalwitness.org/documents/14502/country_
for_sale_high_res_english.pdf; Sydney Morning Herald, Strongman’s hand in BHP deal, 26th
March 2016, http://www.smh.com.au/national/strongmans-hand-in-bhp-deal-201303252gqae.html / (last accessed 3rd June 2016)
180 BHP Billiton company website, BHP Billiton Announces End of US Investigations,
20th May 2015, http://www.bhpbilliton.com/investors/news/BHP-Billiton-Announces-End-of-US-Investigations (last accessed 3rd June 2016); US Securities and Exchange
Commission website, Press Release - SEC Charges BHP Billiton With Violating FCPA at
Olympic Games, 10th May 2015, https://www.sec.gov/news/pressrelease/2015-93.html (lastaccessed 15th June 2016)
181 US Department of State, 2013 Investment Climate Statement – Cambodia, March 2013,
http://www.state.gov/e/eb/rls/othr/ics/2013/204614.htm (last accessed 3rd June 2016)
182 Council for the Development of Cambodia, Cambodian Investment Board and Cambodian Special Economic Zone Board website, Who we are – Organization structure of CDC,
http://www.cambodiainvestment.gov.kh/about-us/who-we-are.html (last accessed 3rd June2016); Cambodian Chamber of Commerce website, Message from the President, http://www.
ccc.org.kh/about-us.php?id=3 (last accessed 3rd June 2016); Khmer Times, Tycoon Kith Meng
weds in style, 21st March 2015, http://www.khmertimeskh.com/news/9846/tycoon-kithmeng-weds-in-style/ (last accessed 3rd June 2016)
183 Human Rights Watch, “Tell Them That I Want to Kill Them”- Two Decades of Impunity in
Hun Sen’s Cambodia, 13th November 2012, p.2, https://www.hrw.org/report/2012/11/13/
tell-them-i-want-kill-them/two-decades-impunity-hun-sens-cambodia (last accessed 3rdJune 2016)
184 Human Rights Watch, 30 Years of Hun Sen - Violence, Repression, and Corruption in
Cambodia, January 2015, pp.3, 29, 61, https://www.hrw.org/sites/default/files/reports/cambodia0115_ForUpload.pdf (last accessed 3rd June 2016); UN Human Rights Council, Reportof the Special Rapporteur on the situation of human rights in Cambodia, Surya P. Subedi,
5th August 2013, http://cambodia.ohchr.org/WebDOCs/DocReports/3-SG-RA-Reports/AHRC-24-36_en_SR_report_2013_ENG.pdf, pp.5, & 7 (last accessed 3rd June 2016); Licadho
website, Human Rights Legal Office , https://www.licadho-cambodia.org/programs/legaloffice.php (last accessed 3rd June 2016)
185 Global Witness, Family Trees, June 2007, pp.19 & 56 https://www.globalwitness.org/
documents/15600/cambodias_family_trees_med.pdf; Sydney Morning Herald, Drugs: ourman in Cambodia, 26th March 2012, http://www.smh.com.au/national/investigations/drugsour-man-in-cambodia-20120325-1vsiz.html (last accessed 3rd June 2016); Cambodia Daily,
Hun Sen’s nephew suspected in shooting in capital, 1st November 2003, https://www.cambodiadaily.com/archives/hun-sens-nephew-suspected-in-shooting-in-capital-43703/ (lastaccessed 3rd June 2016); Phnom Penh Post, Hun Sen’s relative admits to hit-and-run, 13th
August 2008, http://www.phnompenhpost.com/national/hun-sens-relative-admits-hit-andrun (last accessed 3rd June 2016); Phnom Penh Post, Nephew of Hun Sen is made one-star
general, 11th December 2014, http://www.phnompenhpost.com/national/nephew-hun-senmade-one-star-general (last accessed 3rd June 2016); Phnom Penh Post, End impunity for
PM’s cousin, lawyer insists, 14th October 2014, http://www.phnompenhpost.com/national/
end-impunity-pm%E2%80%99s-cousin-lawyer-insists (last accessed 3rd June 2016)
186 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible on
Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=id
s&id=A209,A2313,A6130,A6156; Development and Partnership in Action (DPA), Artisanal
Small-scale Gold Mining (ASGM) in Battambang and Preah Vihear Provinces Investigation
Report 2012, December 2012, pp.18-19, http://library.opendevelopmentcambodia.net:8080/
newgenlibctxt/CatalogueRecords/Artisanal%20Small%20Scale%20Gold%20Mining%20
December-2012.pdf (last accessed 3rd June 2016); Official government data from theCambodian Ministry of Commerce’s online corporate registry - extracted in December
2014 and February 2016 by Global Witness. Accessible on Cambodia Corporates at https://
cambodiacorporates.globalwitness.org/search?type=ids&id=R18831,A1009,A2247; Phnom
Penh Post, Fight gets venomous, 31st October 2013, http://www.phnompenhpost.com/
national/fight-gets-venomous (last accessed 3rd June 2016); Phnom Penh Post, First snakes,

now ‘arson’, 18th March 2014, http://www.phnompenhpost.com/national/first-snakesnow-%E2%80%98arson%E2%80%99 (last accessed 3rd June 2016); Official government
data from the Cambodian Ministry of Commerce’s online corporate registry - extracted in
December 2014 and February 2016 by Global Witness. Accessible on Cambodia Corporates
at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R25207; Licadho,
Human rights 2012: the year in review, February 2013, p.11, http://www.licadho-cambodia.
org/reports/files/176LICADHOReportHumanRightsReview2012English.pdf (last accessed
3rd June 2016); Soma Construction & Development company website, Phnom Penh
International Airport Extension, http://www.smcd-construction.com.kh/projects/post/489/(last accessed 3rd June 2016); Office of the Compliance Advisor Ombudsman (CAO) of the International Finance Corporation (IFC), CAO cases, Cambodia / Cambodia Airports-01/Phnom
Penh, filed 7th June 2014, http://www.cao-ombudsman.org/cases/case_detail.aspx?id=205(last accessed 3rd June 2016)
187 Licadho website, Human Rights Legal Office , https://www.licadho-cambodia.org/
programs/legaloffice.php (last accessed 3rd June 2016)
188 International Republican Institute and USAID, Survey of Cambodian Public Opinion, 12th
January – 2nd February 2013, Slide 6, http://www.iri.org/sites/default/files/Cambodian%20
Poll%209%20Final%20PUBLIC.pdf (last accessed 3rd June 2016)
189 Sebastian Strangio, Hun Sen’s Cambodia, 2014, pp. 139-140, https://books.google.co.uk/
books?id=xRY2BQAAQBAJ&pg=PA133&dq=hun+sen+and+kampuchea+tela&hl=en&sa=X&ved=0ahUKEwiPpantlonNAhVqJMAKHSrGC_IQ6AEIJTAA#v=onepage&q=hun%20
sen%20and%20kampuchea%20tela&f=false (last accessed 3rd June 2016); Transparency
International, Cambodian Political parties call for an end to nepotism, abuse of public power
and neglect of rule of law, 12th June 2013, http://www.transparency.org/news/pressrelease/
political_parties_call_for_an_end_to_nepotism_abuse_of_public_power_and_neg (lastaccessed 3rd June 2016); Freedom House, Freedom of the Press 2015, Cambodia page on
website, https://freedomhouse.org/report/freedom-press/2015/cambodia (last accessed 1stJune 2016); Andrew Marshall, Sunday Times, 15th February 2010, http://andrewmarshall.
com/articles/making-a-killing-in-cambodia-2/ (last accessed 3rd June 2016)
190 Criminal Code of the Kingdom of Cambodia, 2009, Article 595 (Defines of Influential Deal)
and Article 599 (Definition of Favouritism), https://www.unodc.org/res/cld/document/khm/
criminal_code_of_the_kingdom_of_cambodia_html/Cambodia_Criminal-Code-of-the-Kingdom-of-Cambodia-30-Nov-2009-Eng.pdf (last accessed 3rd June 2016); Anti-Corruption Lawof the Kingdom of Cambodia, 2010, Article 32 (Corruption offenses stipulated in the Criminal
Code), Article 33 (Bribe taking by Foreign Public Officials or Officials of Public International
Organizations), Article 34 (Bribes offered to Foreign Public Officials or Officials of Public
International Organization) and Article 35 (Abuse of Power), http://www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 3rd June 2015); For more
information on Cambodia’s Criminal Code and Anti-Corruption Law see Annex 3.
191 To see the links between the Hun family and mining companies go to Cambodia Corporates (https://cambodiacorporates.globalwitness.org) and search for the following records:
registration 16097 (The VC Group – Dy Vichea), registration 16769 (Metal Mining Cambodia Co– Hun Seng Ny), amendment 8006 (Metal Mining Cambodia PLC – Hun Seng Ny), amendment
5415 (Worldwide Investment Incorporation - Hun Kimleng), amendment 1570 Phu Yang
Cambodia – Yim Chhay Lin) and amendment 1214 (Sovannaphum Mine Exploration & Development – Yim Chhay Linn); For information on the mining licenses held by these companies
see the following sources of information:• Worldwide Investment Incorporation company website, Mining page, http://www.worldwidegroup.com.kh/portfolio/mining/ (last accessed 1st June 2016). Company Worldwide
Investment Group - concession in Oddar Meanchey province.
• Phnom Penh Securities PLC, Mining Sector in Cambodia, June 2011, p.4, http://www.pps.
com.kh/PPSWEB/PPSUploadFiles/iv/161_en-us.pdf (last accessed 1st June 2016). Company
Phu Yang – concessions in Battambang and Pailin provinces.
• Ministry of Industry, Mines and Energy Exploration License No 532, August 4, 2008, http://
www.opendevelopmentcambodia.net/references/Exploration_License_Titan_Mineral_Group__04.08.2008.pdf (last accessed 1st June 2016). Company VC Group – concessions
in Stung Treng and Preah Vihear.
Worldwide Investment Group company website, Mining, http://www.worldwidegroup.
com.kh/portfolio/mining/ (last accessed 3rd June 2016); To see the links between the Hunfamily and five agricultural companies go to Cambodia Corporates (https://cambodiacorporates.globalwitness.org) and search for the following records: registration 2728 (Rithmony
Samnang Leap – Seang Keang), registration 1435 (Soma Ever Green – Sok Puthyvuth),amendment 6710 (Kam Chin International Cooperation Group – Hun Kimleng), amendment
8441 (Khmer Latex – Pich Chanmony) and amendment 2247 (Khun Sea Import Export –Yim Leang); In addition, Hun Seng Ny has repeatedly been reported to have links to HLH
Agriculture - Cambodia Daily, Hun Sen’s sister tied to company in Boeung Kak land sale,
25th June 2014, https://www.cambodiadaily.com/archives/hun-sens-sister-tied-to-company-in-boeng-kak-land-sale-62344/ (last accessed 3rd June 2016); Phnom Penh Post, Court
summons Omlaing trio, 19th July 2010, http://www.phnompenhpost.com/national/courtsummons-omlaing-trio (last accessed 3rd June 2016); Phnom Penh Post Petition delivered:Villagers demand land be returned , 11th November 2014, http://www.phnompenhpost.
com/national/petition-delivered-villagers-demand-land-be-returned / (last accessed 3rdJune 2016); Phnom Penh Post, Chainsaws stayed busy in past year , 26th December 2013,
http://www.phnompenhpost.com/national/chainsaws-stayed-busy-past-year (last accessed
3rd June 2016); For information on Economic Land Concessions held by these companies see
the following sources of information:• Based on official Cambodian government data collated and displayed on the Open Development Mekong website, http://www.opendevelopmentcambodia.net/company-profiles/
profile/?id=221&map_code=elc_gdp_167&map=elc&data_class=government_data_partial (last accessed 23rd June 2016). Company Rithmony Samnang Leap – concession in
Kampong Thom.

HOSTILE TAKEOVER JULY 2016 49• Surya P. Subedi, A human rights analysis of economic and other land concessions in Cambodia, 24th September 2012, p82, http://www.ohchr.org/Documents/HRBodies/HRCouncil/
RegularSession/Session21/A-HRC-21-63-Add1_en.pdf (last accessed 2nd June 2016),
Company HLH Agriculture – concession in Kampong Speu.
• Based on official Cambodian government data collated and displayed on the Open Development Mekong website, http://www.opendevelopmentcambodia.net/company-profiles/
profile/?id=152&map_code=elc_gdp_60&map=elc&data_class=government_data_partial(last accessed 3rd June 2016), Company Kun Sea Import Export – concession in Oddar
Meanchey. Concession revoked in 2014.
192 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R25207; Soma Construction & Development company website, Phnom Penh
International Airport Extension, http://www.smcd-construction.com.kh/projects/post/489/& State of Secretariat of Civil Aviation http://www.smcd-construction.com.kh/projects/
post/509/ (last accessed 3rd June 2016) / Cambodia Daily, $100-million airport expansion
project begins, 24th February 2014, https://www.cambodiadaily.com/archives/100-million-airport-expansion-project-begins-53006/ (last accessed 3rd June 2016)
193 Analysis conducted by Global Witness based on official Cambodian government datacollated and displayed on the Open Development Mekong website, https://cambodia.
opendevelopmentmekong.net/profiles/special-economic-zones/ (last accessed 1st June2016); For the 2 SEZs allocated to members of the family see the following data sourcesOfficial government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A939,R20441; Official Cambodian government data collated and displayed on
the Open Development Mekong website, https://cambodia.opendevelopmentmekong.net/
profiles/special-economic-zones/?map_id=6 & https://cambodia.opendevelopmentmekong.
net/profiles/special-economic-zones/?map_id=22 (last accessed 1st June 2016)
194 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A6979,A7920; Electric Authority of Cambodia, Decision on first revision of thelicense document no.132LD dated May 31 , 2006 for (Cambodia) Electricity Private Co., Ltd.
for providing electric power generation service at Phnom Penh city for revising ownershipof licensee, 27th November 2013. Document obtained by Global Witness investigators in
October 2015; Electric Authority of Cambodia, Report on power sector of the Kingdom of
Cambodia, 2013 edition, annex 3, p.77, http://eac.gov.kh/wp-content/uploads/2014/07/
report-2012en.pdf (last accessed 2nd June 2016); Electric Authority of Cambodia, Report on
power sector of the Kingdom of Cambodia, 2015 edition, annex 3, p.88 http://eac.gov.kh/
wp-content/uploads/2015/07/report-2014en.pdf (last accessed 2nd June 2016)
195 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A5068; Tourist Transport Association for Siem Reap Airport website, Le Macau
Co Ltd, http://www.siemreap-airporttaxi.com/accommodation/svay-rieng-province/le-macau-co-ltd.html (last accessed 3rd June 2016)
196 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A5839; Vital Premium Water website, History, http://vital.com.kh/site/en/company/history.html & Support, http://www.vital.com.kh/site/en/qualification/supports.html(both pages last accessed 3rd June 2016)197 Vital Premium Water website, Support, http://www.vital.com.kh/site/en/qualification/
supports.html (last accessed 3rd June 2016)
198 Note that the company is listed as ‘HML Consulting Co Ltd’ by the Ministry of Commerce.
Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R25187; HML Law Firm & Consultants company website, Our Team, http://hmllawfirm.com/our-team/ http://hmllawfirm.com/our-team/ & Services, http://hmllawfirm.
com/category/services/#Lobbying (both pages last accessed 3rd June 2016);
199 HML Law Firm & Consultants company website, Services, http://hmllawfirm.com/
category/services/#Lobbying (last accessed 3rd June 2016); Council for the Development of
Cambodia, Cambodian Investment Board and Cambodian Special Economic Zone Board
website, http://www.cambodiainvestment.gov.kh/about-us/who-we-are.html (last accessed
1st June 2016)
200 General Electric company fact sheet, date unknown, p.2 http://www.ge.com/cb/
docs/1443625388354_FACT_SHEET_CB_Sept_15.pdf (last accessed 2nd June 2016); Soma
Energy company website, http://www.somaenergy.com.kh/project.php#.VmXCYTEnwqM(last accessed 2nd June 2016)
201 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible on
Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&i
d=A209,A2313,A6130,A6156; Based on official Cambodian government data collated and displayed on the Open Development Mekong website, http://www.opendevelopmentcambodia.net/company-profiles/profile/?id=127&map_code=135&map=mining&data_class=secondary_source_data (last accessed 4th June 2016)202 Berlin is 984 km2 or 98,400 hectares. City Mayors website, The largest cities in the world
by land area, population and density, http://www.citymayors.com/statistics/largest-cities-ar-

ea-125.html (last accessed 4th June 2016); Phnom Penh Securities PLC, Mining Sector in
Cambodia, June 2011, p.3, http://www.pps.com.kh/PPSWEB/PPSUploadFiles/iv/161_en-us.
pdf (last accessed 1st June 2016); Development and Partnership in Action (DPA), Artisanal
Small-scale Gold Mining (ASGM) in Battambang and Preah Vihear Provinces Investigation
Report 2012, December 2012, pp.18-19, http://library.opendevelopmentcambodia.net:8080/
newgenlibctxt/CatalogueRecords/Artisanal%20Small%20Scale%20Gold%20Mining%20
December-2012.pdf (last accessed 3rd June 2016)
203 Development and Partnership in Action (DPA), Artisanal Small-scale Gold Mining (ASGM)
in Battambang and Preah Vihear Provinces Investigation Report 2012, December 2012, pp.1819, http://library.opendevelopmentcambodia.net:8080/newgenlibctxt/CatalogueRecords/
Artisanal%20Small%20Scale%20Gold%20Mining%20December-2012.pdf (last accessed 3rdJune 2016)
204 Development and Partnership in Action (DPA), Artisanal Small-scale Gold Mining (ASGM)
in Battambang and Preah Vihear Provinces Investigation Report 2012, December 2012, p19,
http://library.opendevelopmentcambodia.net:8080/newgenlibctxt/CatalogueRecords/
Artisanal%20Small%20Scale%20Gold%20Mining%20December-2012.pdf (last accessed 3rdJune 2016); Interview with well-placed source conducted by Global Witness, 12th November
2015.
205 Development and Partnership in Action (DPA), Artisanal Small-scale Gold Mining (ASGM)
in Battambang and Preah Vihear Provinces Investigation Report 2012, December 2012, p19,
http://library.opendevelopmentcambodia.net:8080/newgenlibctxt/CatalogueRecords/
Artisanal%20Small%20Scale%20Gold%20Mining%20December-2012.pdf (last accessed 3rdJune 2016); This contravenes Article 21 of the 2001 Law on Mineral Resource Managementand Exploitation which requires mining licence holders to protect the environment http://
www.cambodiainvestment.gov.kh/law-on-mineral-resource-management-and-exploitation_010713.html (A21)
206 Development and Partnership in Action (DPA), Artisanal Small-scale Gold Mining (ASGM)
in Batta mbang and Preah Vihear Provinces Investigation Report 2012, December 2012, p19,
http://library.opendevelopmentcambodia.net:8080/newgenlibctxt/CatalogueRecords/
Artisanal%20Small%20Scale%20Gold%20Mining%20December-2012.pdf (last accessed
3rd June 2016); This potentially contravenes Article 18 of the 1993 Law on Investment
which states that investors can only hire foreign workers if they can prove that the expertise
required is not available among Cambodians. Law on Investment (1994) and Law on the
Amendment to the Law on Investment (2003) of the Kingdom of Cambodia, 2003, Article 18,
http://www.cambodiainvestment.gov.kh/law-on-investment-august-05-1994-and-law-onthe-amendment-to-the-law-on-investment_030324.html (last accessed 4th June 2016)
207 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A2313; Email from well-placed source to Global Witness, 9th June 2016; Conversation between well-placed source and Global Witness investigator, 9th June 2016.
208 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A1009,A2247
209 Phnom Penh Post, For communities, threats routine, 8th May 2014, http://www.phnompenhpost.com/national/communities-threats-routine (last accessed 4th June 2016)
210 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A2247
211 Based on official Cambodian government data collated and displayed on the Open
Development Mekong website, http://www.opendevelopmentcambodia.net/company-profiles/profile/?id=152&map_code=elc_gdp_60&map=elc&data_class=government_data_partial (last accessed 4th June 2016); Official government data from the Cambodian Ministryof Commerce’s online corporate registry - extracted in December 2014 and February 2016
by Global Witness. Accessible on Cambodia Corporates at https://cambodiacorporates.
globalwitness.org/search?type=ids&id=A1009
212 UN Human Rights Council, Report of the Special Rapporteur on the situation of humanrights in Cambodia, Surya P. Subedi, A human rights analysis of economic and other land
concessions in Cambodia, 24th September 2012, p1, http://www.ohchr.org/Documents/
HRBodies/HRCouncil/RegularSession/Session21/A-HRC-21-63-Add1_en.pdf (last accessed
2nd June 2016)
213 Phnom Penh Post, Fight gets venomous, 31st October 2013, http://www.phnompenhpost.com/national/fight-gets-venomous (last accessed 3rd June 2016); Phnom Penh Post,
First snakes, now ‘arson’, 18th March 2014, http://www.phnompenhpost.com/national/firstsnakes-now-%E2%80%98arson%E2%80%99 (last accessed 3rd June 2016); Phnom Penh
Post, For communities, threats routine, 8th May 2014, http://www.phnompenhpost.com/
national/communities-threats-routine (last accessed 4th June 2016)
214 Communication Under Article 15 of the Rome Statute of the International Criminal
Court, The Commission of Crimes Against Humanity in Cambodia July 2002 to Present, 2014,
p59. Currently not publicly available due to ongoing proceedings.
215 Communication Under Article 15 of the Rome Statute of the International Criminal Court,
The Commission of Crimes Against Humanity in Cambodia July 2002 to Present, 2014. Currently not publicly available due to ongoing proceedings; Global Diligence, Richard Rogers of
Global Diligence LLP files an Article 15 Communication at the International Criminal Court,
7th October 2014, http://www.globaldiligence.com/2014/10/07/global-diligence-file-article-15-communication-international-criminal-court/ (last accessed 4th June 2016)
216 Phnom Penh Post, Fight gets venomous, 31st October 2013, http://www.phnompen-

50

hpost.com/national/fight-gets-venomous (last accessed 3rd June 2016)
217 1998 General Statute of Military Personnel of the Royal Cambodian Armed Forces, Article
25, p.4, https://www.ilo.org/dyn/natlex/docs/ELECTRONIC/93508/109344/F811412622/
KHM93508%20Eng.pdf (last accessed 2nd June 2016)
218 Soma Group company website, Soma Team, http://www.somagroup.com.kh/index.php/
about-soma/our-teams/ (last accessed 4th June 2016)
219 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R25207; Soma Construction & Development company website, Phnom Penh
International Airport Extension, http://www.smcd-construction.com.kh/projects/post/489/(last accessed 3rd June 2016); Cambodia Daily, $100-million airport expansion project begins, 24th February 2014, https://www.cambodiadaily.com/archives/100-million-airport-expansion-project-begins-53006/ (last accessed 3rd June 2016)
220 Licadho, Human rights 2012: the year in review, February 2013, p.11, http://www.
licadho-cambodia.org/reports/files/176LICADHOReportHumanRightsReview2012English.
pdf (last accessed 3rd June 2016); Article 30 of Cambodia’s 2001 Land Law states that anyone
who has ‘enjoyed, peaceful, uncontested posession’ to land that can be privately owned
has the right to request a land title. Land Law of the Kingdom of Cambodia, 2001, Article 30,
http://www.cambodiainvestment.gov.kh/land-law_010430.html (last accessed 4th June
2016)
221 Licadho, Human rights 2012: the year in review, February 2013, p.11, http://www.licadho-cambodia.org/reports/files/176LICADHOReportHumanRightsReview2012English.pdf(last accessed 3rd June 2016); Coalition of 6 Cambodian non-governmental organisations,
Press release - Free Detained Community Members from Thmor Kol Village and Stop Police
Crackdown ahead of ASEAN Summits, 15th November 2012, http://www.licadho-cambodia.
org/pressrelease.php?perm=295 (last accessed 4th June 2016); Radio Free Asia, Eight Heldfor SOS to Obama , 15th November 2012, http://www.rfa.org/english/news/cambodia/sos11152012184033.html (last accessed 4th June 2016)
222 Office of the Compliance Advisor Ombudsman (CAO) of the International FinanceCorporation (IFC), CAO cases, Cambodia / Cambodia Airports-01/Phnom Penh, filed 7th June
2014, http://www.cao-ombudsman.org/cases/case_detail.aspx?id=205 (last accessed 3rdJune 2016)
223 Email from well-paced source to Global Witness on 16th May 2016.
224 Phnom Penh Post, Families ask for clarity on airport plan,11th May 2016, http://www.
phnompenhpost.com/national/families-ask-clarity-airport-plan (last accessed 4th June
2016)
225 Global Witness, Family Trees, June 2007, p6, https://www.globalwitness.org/documents/15600/cambodias_family_trees_med.pdf
226 Global Witness Rubber Barons, May 2013, pp. 27 & 29, https://www.globalwitness.org/
documents/10525/rubber_barons_lores_0_1.pdf
227 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R15426,R2728,R20726
228 Cambodia Daily, Hun Sen’s sister tied to company in Boeung Kak land sale, 25th June
2014, https://www.cambodiadaily.com/archives/hun-sens-sister-tied-to-company-in-boengkak-land-sale-62344/ (last accessed 3rd June 2016); Phnom Pneh Post, Court summonsOmlaing trio, 19th July 2010, http://www.phnompenhpost.com/national/court-summonsomlaing-trio (last accessed 3rd June 2016); Phnom Penh Post Petition delivered: Villagers
demand land be returned, 11th November 2014, http://www.phnompenhpost.com/
national/petition-delivered-villagers-demand-land-be-returned / (last accessed 3rd June2016); Phnom Penh Post, Chainsaws stayed busy in past year , 26th December 2013, http://
www.phnompenhpost.com/national/chainsaws-stayed-busy-past-year (last accessed 3rdJune 2016)
229 On 31st December 2015, Global Witness wrote to the company HLH Agriculture
requesting the company’s comment. The HLH Group responded in a letter dated 7th
January, thereby confirming that HLH Agriculture is part of the HLH Group; Phnom Penh
Post, Sihanoukville’s first and largest shopping mall to open within D’Seaview’s vicinity , 10th
March 2016, http://www.phnompenhpost.com/post-property/sihanoukvilles-first-and-largest-shopping-mall-open-within-dseaviews-vicinity (last accessed 4th June 2016); Singapore
Business Review, HLH Group splurges US$10m on agricultural food processing park in
Cambodia, 18th April 2016, http://sbr.com.sg/agribusiness/more-news/hlh-group-splurges-us10m-agricultural-food-processing-park-in-cambodia (last accessed 4th June 2016)
230 Cambodia Daily, Suy land still at risk, villagers, rights workers say, 25th February 2010,https://www.cambodiadaily.com/archives/suoy-land-still-at-risk-villagers-rights-workerssay-97697/ (last accessed 10th June 2016)
231 Cambodia Daily, Hun Sen’s sister tied to company in Boeung Kak land sale, 25th June
2014, https://www.cambodiadaily.com/archives/hun-sens-sister-tied-to-company-in-boengkak-land-sale-62344/ (last accessed 3rd June 2016); Phnom Penh Post, Court summonsOmlaing trio, 19th July 2010, http://www.phnompenhpost.com/national/court-summonsomlaing-trio (last accessed 3rd June 2016); Phnom Penh Post Petition delivered: Villagers
demand land be returned, 11th November 2014, http://www.phnompenhpost.com/
national/petition-delivered-villagers-demand-land-be-returned / (last accessed 3rd June2016); Phnom Penh Post, Chainsaws stayed busy in past year , 26th December 2013, http://
www.phnompenhpost.com/national/chainsaws-stayed-busy-past-year (last accessed 3rdJune 2016); UN Human Rights Council, Report of the Special Rapporteur on the situation ofhuman rights in Cambodia, Surya P. Subedi, A human rights analysis of economic and otherland concessions in Cambodia, 24th September 2012, p.55, http://www.ohchr.org/Documents/HRBodies/HRCouncil/RegularSession/Session21/A-HRC-21-63-Add1_en.pdf (lastaccessed 2nd June 2016)
232 UN Human Rights Council, Report of the Special Rapporteur on the situation of humanrights in Cambodia, Surya P. Subedi, A human rights analysis of economic and other land
concessions in Cambodia, 24th September 2012, p.55, http://www.ohchr.org/Documents/
HRBodies/HRCouncil/RegularSession/Session21/A-HRC-21-63-Add1_en.pdf (last accessed
2nd June 2016)
233 Confirmed in a letter from the HLH Group to Global Witness dated 7th January 2016;
Article 57 of Cambodia’s 2001 Land Law states that ‘Conceded land cannot be transferredthrough alienation’. In this context ‘alienation’ means the transfer of the ownership of property rights. Land Law of the Kingdom of Cambodia, 2001, Article 57, http://www.cambodiainvestment.gov.kh/land-law_010430.html (last accessed 4th June 2016) 2016)
234 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A4997,A390,A2264,A10055; World Bank Inspection Panel, Investigation Report,
Cambodia - Land Management and Administration Project (Credit No. 3650 - KH), 23rd
November 2010, p.27, point 92 and p.31, point 102, http://ewebapps.worldbank.org/apps/
ip/PanelCases/60-Investigation%20Report%20(English).pdf (last accessed 4th June 2016);
Inclusive Development International, Cambodia: Boeung Kak Lake evictions, http://www.
inclusivedevelopment.net/bkl/ (last accessed 4th June 2016)
235 Letter from 42 Cambodian and International non-governmental organisations to theWorld Bank’s Cambodia Country Director, Ulrich Zachau, 7th August 2015, http://www.
inclusivedevelopment.net/wp-content/uploads/2015/08/Letter-to-WB-re-Cambodia-Reengagement-.pdf (last accessed 4th June 2015); Inclusive Development International website,
Cambodia - Boeung Kak Lake evictions, http://www.inclusivedevelopment.net/bkl/ (lastaccessed 7th June 2016); World Bank, Press Release - New Country Engagement Plan for
Cambodia Outlines More World Bank Group Support to Help Reduce Poverty, 19th May 2016,
http://www.worldbank.org/en/news/press-release/2016/05/19/new-country-engagementplan-for-cambodia-outlines-more-world-bank-group-support-to-help-reduce-poverty (lastaccessed 4th June 2016)
236 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R22816; Cambodia Daily, Hun Sen’s sister linked to private security firm at SL
factory, 14th November 2013, https://www.cambodiadaily.com/archives/hun-sens-sisterlinked-to-private-security-firm-at-sl-factory-46946/ (last accessed 4th June 2016)
237 Cambodia Daily, Hun Sen’s sister linked to private security firm at SL factory, 14th November 2013, https://www.cambodiadaily.com/archives/hun-sens-sister-linked-to-privatesecurity-firm-at-sl-factory-46946/ (last accessed 4th June 2016)238 Vice News, Tracking illegally logged wood to a factory used by top fashion brands in
Cambodia, 12th April 2016, https://news.vice.com/article/tracking-illegally-logged-wood-toa-factory-used-by-top-fashion-brands-in-cambodia (last accessed 4th June 2016)
239 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A4769
240 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible on
Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=individual&individual=Lim+Chhiev+Ho; Global Witness, Family Trees, June 2007, pp.82 & 86,
https://www.globalwitness.org/documents/15600/cambodias_family_trees_med.pdf
241 Phnom Penh Post, Authorities accuse investment group of illegal sand-dredging, 7th July
2009, http://www.phnompenhpost.com/national/authorities-accuse-investment-group-illegal-sand-dredging (last accessed 4th June 2016)
242 Interview by Global Witness investigator with a confidential source, 2006; Personal communication from a human rights worker to Global Witness, 2006; Published previously - Global Witness, Family Trees, June 2007, p.19, https://www.globalwitness.org/documents/15600/
cambodias_family_trees_med.pdf
243 Published previously - Global Witness, Family Trees, June 2007, pp.19 & 56, https://www.
globalwitness.org/documents/15600/cambodias_family_trees_med.pdf
244 Sydney Morning Herald, Drugs: our man in Cambodia, 26th March 2012, http://www.
smh.com.au/national/investigations/drugs-our-man-in-cambodia-20120325-1vsiz.html(last accessed 3rd June 2016); Phnom Penh Post, Drug connection denied, 27th March 2012,
http://www.phnompenhpost.com/national/drug-connection-denied (last accessed 4th June2016); Cambodia Daily, Hun To hits back at allegations of drug smuggling, 19th March 2012,https://www.cambodiadaily.com/archives/hun-to-hits-back-at-allegations-of-drug-smuggling-1576/ (last accessed 4th June 2016); Voice of America Khmer, Hun Sen Nephew Denies
Australian Report of Drug Trafficking, 26th March 2012, http://www.voacambodia.com/a/hun-sen-nephew-denies-australian-report-of-drug-trafficking-144286045/1353234.html (lastaccessed 4th June 2016)
245 Sydney Morning Herald, Drugs: our man in Cambodia, 26th March 2012, http://www.
smh.com.au/national/investigations/drugs-our-man-in-cambodia-20120325-1vsiz.html (lastaccessed 3rd June 2016);
246 Cambodia Daily, Sports car owners let engines do the talking, 30th December 2008,https://www.cambodiadaily.com/archives/sports-car-owners-let-engines-do-the-talking-59642/ (last accessed 4th June 2016); Khmerization blog, Hun Sen’s notorious nephew,

HOSTILE TAKEOVER JULY 2016 51

Hun To, bought a car worth more than one million dollars, http://khmerization.blogspot.
co.uk/2015/06/hun-sens-notorious-nephew-hun-to-bought.html (last accessed 4th June2016); Photo showing at least 4 sports cars in Hun To’s garage, obtained from his Facebook
page by Global Witness investigators in February 2016; The Car Guide website, McLaren P1,
http://www.guideautoweb.com/en/specifications/mclaren/p1/coupe/2015/ (last accessed
4th June 2016).
247 Information obtained by Global Witness from confidential sources, June to November
2015; Official government data from the Cambodian Ministry of Commerce’s online corporate registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R25100,R14878,R3066,A6749,R2001; Links to online listings of LHR petrol stations
include:• Yellow Pages Cambodia, http://yp.com.kh/listings/kh53592-lhr-gas-station-2• Facebook, https://www.facebook.com/pages/Lhr-Gas-Station/183972255024182• Four Square, https://foursquare.com/v/lhr-petrol-station/4f407e00e4b020398cac8bc2• Glopoi, https://glopoi.com/cambodia/places/lhr-gas-station-petrol-pump-mphey-osakphea-svay-pao-batd%C3%A2mb%C3%A2ng• Trip Advisor, https://www.tripadvisor.co.uk/ShowUserReviews-g1893367-d4206543-r37650
0416-Adventure_Rider_Asia_Motorcycle_Private_Tours-Sen_Monorom_Mondulkiri_Province.html• Vacations map, http://www.vacationsmap.com/en/cambodia/poi/fuel/lhr-map (all sources
last accessed on 2nd June 2016)
248 Phnom Penh Post, End impunity for PM’s cousin, lawyer insists, 14th October 2014,
http://www.phnompenhpost.com/national/end-impunity-pm%E2%80%99s-cousin-lawyer-insists (last accessed 4th June 2016)
249 Phnom Penh Post, Coveted okhna title for PM’s convicted cousin, 19th August 2013,
http://www.phnompenhpost.com/national/coveted-okhna-title-pm%E2%80%99s-convicted-cousin (last accessed 4th June 2016)
250 Asian Tigers, African Lions: Comparing the Development Performance of Southeast
Asia and Africa,2013, p465, https://books.google.co.uk/books?id=JcneAQAAQBAJ&pg=PA465&lpg=PA465&dq=title+oknha+given+for+100,000+donation&source=bl&ots=4avfowyNNm&sig=REwdakzkVOScb21mjuPwze2rHHg&hl=en&sa=X&ved=0ahUKEwiSz6eRypPMAhUHVxoKHZMkAXgQ6AEIQDAF#v=onepage&q=title%20oknha%20given%20for%20
100%2C000%20donation&f=false (last accessed 4th June 2016)
251 Khmer Times, Prime Minister’s Cousin Tried for Bribery, Land Theft, 17th February 2016,
http://www.khmertimeskh.com/news/21545/prime-minister---s-cousin-tried-for-bribery-land-theft/ (last accessed 4th June 2016)
252 Cambodia Daily, Hun Sen’s nephew suspected in shooting in capital, 1st November 2003
https://www.cambodiadaily.com/archives/hun-sens-nephew-suspected-in-shooting-in-capital-43703/ (last accessed 3rd June 2016)

2016, http://www.rfa.org/english/news/cambodia/nepotism-01132016165315.html (lastaccessed 4th June 2016)
261 Reuters, Cambodia’s ruling party promotes PM’s sons, top allies, 2nd February 2015,
http://www.reuters.com/article/us-cambodia-politics-idUSKBN0L611S20150202#Iz3OoIohm1AOOuHZ.97 (last accessed 4th June 2016); Cambodia Daily, Hun Sen’s second son
in meteoric rise through rcaf ranks, 30th January 2012, https://www.cambodiadaily.com/
archives/hun-sens-second-son-in-meteoric-rise-through-rcaf-ranks-1560/ (last accessed
4th June 2016); Voice of America, Hun Manet Defends His Father’s Record , 20th April 2016,
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253 Cambodia Daily, Shots fired at Hun To, Hun Sen’s nephew, 18th December 2001, https://www.cambodiadaily.com/archives/shots-fired-at-hun-to-hun-sens-nephew-28126/ (lastaccessed 4th June 2016)

257 Official government data from the Cambodian Ministry of Commerce’s online corporate
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plusd/cables/07PHNOMPENH1034_a.html (last accessed 4th June 2016)
260 Radio Free Asia, Cambodia’s Hun Sen Warns on Nepotism, Promotes Sons, 13th January

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52sens-daughter-to-marry-hok-lundys-son-59583/ (last accessed 4th June 2016); Cambodian
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280 Bertil Lintner, Asia Times, One big happy family, 20th March 2007, http://www.atimes.
com/atimes/Southeast_Asia/IC20Ae03.html (last accessed 4th June 2016); Cambodia Daily,
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4th June 2016); Cambodian Human Rights Taskforce, Hun Sen and Bun Rany’s children, 19th
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281 Cambodia Daily, Marriages abound among the political elite, 6th January 2004, https://www.cambodiadaily.com/archives/marriages-abound-among-the-political-elite-37308/ (lastaccessed 4th June 2014); Cambodia Daily, Wedding party of PM’s son gets tight security, 3rdJanuary 2004, https://www.cambodiadaily.com/archives/wedding-party-of-pms-son-getstight-security-37283/ (last accessed 4th June 2016)
282 Bertil Lintner, Asia Times, One big happy family, 20th March 2007, http://www.atimes.
com/atimes/Southeast_Asia/IC20Ae03.html (last accessed 4th June 2016); Cambodian Human Rights Taskforce, Hun Sen and Bun Rany’s children, 19th December 2015, http://www.
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286 Radio Free Asia, Hun Sen’s son sets sights on Cambodia’s top office, 30th December 2015,
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287 Radio Free Asia, Hun Sen’s son sets sights on Cambodia’s top office, 30th December 2015,
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File&recordOId=7763368&fileOId=7763369 (last accessed 5th June 2016); US government cable from Cambodia Phnom Penh to US government Department of Commerce, Departmentof the Treasury, Secretary of State, The Association of Southeast Asian Nations, Cambodia’s
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290 Cambodian Red Cross website, Samdech Kittipritthbindit Bun Rany HUNSEN, Presidentof the Cambodian Red Cross led delegation of the CRC to the Royal Palace, 16th June 2015,
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Strangio, Hun Sen’s Cambodia, p. 135, https://books.google.co.uk/books?id=xRY2BQAAQBAJ&pg=PA135&lpg=PA135&dq=bun+rany+red+cross&source=bl&ots=ecRFpp3mle&sig=psj9bRUm-bm0Z0z_YP73vZDixTI&hl=en&sa=X&ved=0ahUKEwjI8aXDnMLJAhVMVRQKHZCvDtg4ChDoAQguMAE#v=onepage&q=bun%20rany%20red%20cross&f=true (last accessed 4thJune 2016); Cambodia Daily, Neutrality of Red Cross in question after Bun Rany’s speech,
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292 Cambodian Red Cross 60th Anniversary Newsletter, 8th May 2015, pp.30-33, obtained by
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293 Cambodia Daily, Neutrality of Red Cross in question after Bun Rany’s speech, 2nd November 2013, https://www.cambodiadaily.com/archives/neutrality-of-red-cross-in-questionafter-bun-ranys-speech-46497/ (last accessed 4th June 2016)
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org.kh/admin/assets/documents/downloads/CRC_Magazine_02_En.pdf (last accessed
4th July 2016). This document lists donations of $68,000 from Hun Sen and $281,000 from
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owned by CPP-Senator Lao Meng Khin and his wife Choeung Sopheap. It also shows donations of $633,154 from ‘Att Wood Fd. Raising’ linked to the company Attwood Investment
Group which counts Hun Seng Ny as a shareholder and is chaired by oknha and businesstycoon Lim Chhiv Ho. A quarter of the total $20 million in domestic donations is listed as‘Spontan. Private Don’ and is therefore untraceable.
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org.kh/admin/assets/documents/downloads/CRC_Magazine_02_En.pdf (last accessed 4th
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October 2015, https://www.cambodiadaily.com/news/thugs-beat-cnrp-lawmakers-at-cppprotest-98375/ (last accessed 4th June 2014); Phnom Penh Post, PM’s son threatens lawsuits
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pms-son-threatens-lawsuits-over-attack-allegations (last accessed 4th June 2016)
301 Agence Kampuchea Presse (AKP), Techo Volunteer Youth Doctor Association Provides
Free Medical Treatment for People in Siem Reap Province , 2nd Februray 2015, http://
www.akp.gov.kh/?p=57597 (last accessed 4th June 2016); Phnom Penh Post, SaintJohn expands humanitarian services through Phnom Penh Corps, 7th August 2015,

HOSTILE TAKEOVER JULY 2016 53

http://www.phnompenhpost.com/post-plus/saint-john-expands-humanitarian-services-through-phnom-penh-corps (last accessed 4th June 2016)
302 Interviews with well-placed sources in Cambodia conducted by Global Witness, January
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Corps,, 7th August 2015, http://www.phnompenhpost.com/post-plus/saint-john-expands-humanitarian-services-through-phnom-penh-corps (last accessed 4th June 2016)304 Bloomberg, Looking Beyond the Killing Fields in Cambodia, 25th July, 2013, http://www.
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Hun Sen losing his tight grip on power, 29th July, 2013, https://blogs.deakin.edu.au/deakin-speaking/2013/07/29/cambodian-election-hun-sen-losing-his-tight-grip-on-power/ (lastaccessed 4th June 2016); The Cambodia Daily, As Next CPP President, Hun Sen’s Power toIncrease, 15th October, 2013, https://www.cambodiadaily.com/archives/as-next-cpp-president-hun-sens-power-to-increase-45081/ (last accessed 4th June 2016)
305 New York Times, Cambodian Strongman and Karaoke King, 18th January 2013, http://
latitude.blogs.nytimes.com/2013/01/18/song-and-dance-hun-sens-other-power-play/?_r=0(last accessed 4th June 2016)
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to Impunity in Cambodia on the International Day to End Impunity for Crimes Against Journalists, 2nd November 2015, http://www.licadho-cambodia.org/pressrelease.php?perm=295(last accessed 7th June 2016); Human Rights Watch, 30 Years of Hun Sen - Violence, Repression, and Corruption in Cambodia, January 2015, pp.2, 47 & 55, https://www.hrw.org/sites/
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Owns the Media? Media Ownership Monitor (MOM) project website, data from 2015, http://mom-kh.com/en/pages/affiliations & http://mom-kh.com/en/owners (both last accessed 1stJune 2016)
310 Reporters Without Borders and the Cambodian Centre for Independent Media, Who
Owns the Media? Media Ownership Monitor (MOM) project website, data from 2015, http://mom-kh.com/en/pages/owner (last accessed 2nd June 2016)
311 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A7110 Reporters Without Borders and the Cambodian Centre for Independent
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Owns the Media? Media Ownership Monitor (MOM) project website, data from 2015, http://mom-kh.com/en/tv_media/11 (last accessed 4th June 2016)
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Owns the Media? Media Ownership Monitor (MOM) project website, data from 2015, http://mom-kh.com/en/radio_media/21 (last accessed 4th June 2016)
314 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=R6193,A473; Reporters Without Borders and the Cambodian Centre for
Independent Media, Who Owns the Media? Media Ownership Monitor (MOM) project website,data from 2015, http://mom-kh.com/en/print_media/27 (last accessed 1st June 2016)
315 Cambodian Centre for Independent Media (CCIM), Challenges for Independent Media
2014, 2015, pp.6-7, http://www.ccimcambodia.org/images/Challenges_for_Independent_
Media_2014.pdf (last accessed 5th June 32016)
316 Reporters Without Borders, Hostile Climate for Environmental Journalists, undated,
pp.4-5, 6 & 7, https://rsf.org/sites/default/files/rapport_environnement_en.pdf (last accessed
4th June 2016)317 Hun Sen’s official Facebook page, https://www.facebook.com/hunsencambodia/?fref=ts(last accessed 4th June 2016)
318 BBC News, 18th March 2016, Cambodian PM Hun Sen denies buying Facebook likes,
http://www.bbc.co.uk/news/world-asia-35839701 (last accessed 4th June 2016); ABC,
Cambodian PM Hun Sen accused of using click farms to gain Facebook friends, 10th March
2016, http://www.abc.net.au/news/2016-03-10/cambodian-pm-accused-of-buying-facebook-friends/7235322 (last accessed 4th June 2016)
319 iTunes website, Samdech HUN SEN App, https://itunes.apple.com/kh/app/samdechhun-sen/id1072637384?mt=8 (last accessed 4th June 2016)
320 Asian Correspondent, Cambodia asks Interpol to help nab Facebook user for insulting
PM’s wife, 20th January 2016, https://asiancorrespondent.com/2016/01/cambodia-asksinterpol-to-help-nab-facebook-user-for-insulting-pms-wife/ (last accessed 4th June 2016);
Cambodia Daily, Hun Manet launches lawsuit over Facebook post, 23rd January 2016,

https://www.cambodiadaily.com/news/hun-manet-launches-lawsuit-over-facebookpost-106215/ (last accessed 4th June 2016); Cambodia Daily, Police arrest free woman in latest facebook case, 26th January 2016, https://www.cambodiadaily.com/news/police-arrestfree-woman-in-latest-facebook-case-106377/ (last accessed 4th June 2016); Associated Press(AP), Cambodian to appeal jail sentence for Facebook comment, 16th March 2016, http://
bigstory.ap.org/article/db63270ac5d849d3bb673b66c279fc44/cambodian-appeal-jail-sentence-facebook-comment (last accessed 4th June 2016)
321 New Straits Times, Man arrested over Facebook threat to Cambodian premier , 8thJanuary 2016, http://www.nst.com.my/news/2016/01/121226/man-arrested-over-facebook-threat-cambodian-premier (last accessed 4th June 2016); Phnom Penh Post, Hun Sen
warns Facebook users he’s watching, 29th December 2015, http://www.phnompenhpost.
com/national/hun-sen-warns-facebook-users-hes-watching (last accessed 4th June 2016)
322 Reuters, Got a problem? Try Cambodia PM’s ministry of Facebook, 4th March 2016,
http://www.reuters.com/article/us-cambodia-politics-idUSKCN0W60C5 (last accessed 4thJune 2016)
323 Phnom Penh Post, In the name of the father, 16th March 2016, http://www.phnompenhpost.com/national/name-father (last accessed 4th June 2016); Khmer Times, PM
dispatches sons to handle land dispute arrests, 15th March 2016, http://www.khmertimeskh.
com/news/22816/pm-dispatches-sons-to-handle-land-dispute-arrests/ (last accessed 4thJune 2016)
324 Council for the Development of Cambodia, Cambodian Investment Board and Cambodian Special Economic Zone Board website, http://www.cambodiainvestment.gov.kh/
about-us/who-we-are.html (last accessed 5th June 2016)
325 Royal Embassy of Cambodia to UK, Denmark, Finland, Ireland, Norway, Sweden, Ethiopia and African Union, Investing Cambodia, 2013-2014, http://www.cambodianembassy.
org.uk/publications/PDF/Tourism/Investing%20in%20Cambodia%202013-2014.pdf (lastaccessed 5th June 2016); Khmer Times, Cambodia is open for business, PM tells Americas,
15th February 2016, http://www.khmertimeskh.com/news/21410/cambodia-is-open-for-investment--pm-tells-america/ (last accessed 5th June 2016); Khmer Times, Cambodia wants
more investment from EU, 17th March 2016, http://www.khmertimeskh.com/news/22924/
cambodia-wants-more-investment-from-eu/ (last accessed 5th June 2016); Daily Express,
28th April 2016, Cambodia offers golden opportunity for business, http://www.dailyexpress.
com.my/news.cfm?NewsID=109207 (last accessed 5th June 2016)
326 Based on the most recent figures available (2010), the Cambodian government’s
spending on education is the lowest in the Mekong region at 2.6 percent of GDP. UNESCO,
Institute of Statistics, http://data.uis.unesco.org/?queryid=181 (last accessed 5th June 2015);
Based on figures for 2014, Cambodia’s public health expenditure is 1.3 percent of GDP, thetwelfth lowest in the world. World Bank, Health expenditure, public (% of GDP), http://data.
worldbank.org/indicator/SH.XPD.PUBL.ZS (last accessed 5th June 2016)
327 Markus Petersson, Politics, Patronage and the Persistence of the Ruling Elite in post-UNTAC Cambodia, 2015, pp.16 & 19-20, http://lup.lub.lu.se/luur/download?func=downloadFile&recordOId=7763368&fileOId=7763369 (last accessed 5th June 2016)
328 Amnesty International, Cambodia 2015/2016, https://www.amnesty.org/en/countries/
asia-and-the-pacific/cambodia/report-cambodia/ (last accessed 5th June 2016)329 Human Rights Watch, 30 Years of Hun Sen - Violence, Repression, and Corruption in
Cambodia, January 2015, p.4, https://www.hrw.org/sites/default/files/reports/cambodia0115_ForUpload.pdf (last accessed 5th June 2016);
330 Southeast Asia Globe, Has Cambodia’s opposition CNRP lost its way?, 10th March 2016,
http://sea-globe.com/has-cambodias-opposition-cnrp-lost-its-way/ (last accessed 5th June2016); Voice of America, Opposition Leader Claims He Was Right to Choose Exile, 5th May
2016, http://www.voacambodia.com/a/opposition-leader-claims-he-was-right-to-choose-exile/3315539.html (last accessed 5th June 2016); Radio Free Asia, Interview: Sam Rainsy Says
CNRP ‘Will Not Fall Into Their Trap’, 5th May 2016, http://www.rfa.org/english/news/cambodia/cambodia-samrainsy-05052016173026.html (last accessed 5th June 2016);
331 Download the 4 raw data spreadsheets of company registrations and amendments from
Cambodia Corporates at https://cambodiacorporates.globalwitness.org/.
332 Licadho, press release, LICADHO Calls for Restoration of Open Access to Companies Register, 25th June 2015, http://www.licadho-cambodia.org/pressrelease.php?perm=387 (lastaccessed 5th June 2015; Royal Government of Cambodia Ministry of Commerce company
registration database, http://www.moc.gov.kh/en-us/company-registration (last accessed
April 2016). Note that the website is often unavailable.
333 Anti Corruption Law of the Kingdom of Cambodia, 2010, http://www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)
334 Anti Corruption Law of the Kingdom of Cambodia, 2010, Articles 11 & 13, http://www.
cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)
335 Anti Corruption Law of the Kingdom of Cambodia, 2010, Article 11, http://www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)336 Anti Corruption Law of the Kingdom of Cambodia, 2010, Articles 11 & 16, http://www.
cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)
337 Anti Corruption Law of the Kingdom of Cambodia, 2010, Article 16, http://www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)
338 Transparency International, Corruption Perception Index, 2015, http://www.transparency.org/cpi2015#results-table (last accessed 5th June 2016)
339 Licadho, joint statement from 27 Cambodian NGOs, CSOs call upon authorities toimmediately cease harassment of human rights defenders, 29th April 2016, https://www.
licadho-cambodia.org/pressrelease.php?perm=402 (last accessed 6th June 2016)

54

340 Anti Corruption Law of the Kingdom of Cambodia, 2010, Article 13, http://www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)
341 Anti Corruption Law of the Kingdom of Cambodia, 2010, Articles 17 & 18, http://www.
cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)
342 For details on members of the Hun family who hold positions in public office or state
security forces see Chapter 5 on pages 26-27.
343 Anti Corruption Law of the Kingdom of Cambodia, 2010, Article 20, http://www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)

361 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A6979,A7920; Electric Authority of Cambodia, Decision on first revision of thelicense document no.132LD dated May 31 , 2006 for (Cambodia) Electricity Private Co., Ltd.
for providing electric power generation service at Phnom Penh city for revising ownershipof licensee, 27th November 2013. Document obtained by Global Witness investigators in
October 2015.

344 Anti Corruption Law of the Kingdom of Cambodia, 2010, Article 38, http://www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)

362 Official government data from the Cambodian Ministry of Commerce’s online corporate
registry - extracted in December 2014 and February 2016 by Global Witness. Accessible
on Cambodia Corporates at https://cambodiacorporates.globalwitness.org/search?type=ids&id=A1009,A2247

345 Anti Corruption Law of the Kingdom of Cambodia, 2010, Article 17, http://www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)

363 Phnom Penh Post, Fight gets venomous, 31st October 2013, http://www.phnompenhpost.com/national/fight-gets-venomous (last accessed 3rd June 2016);

346 Anti Corruption Law of the Kingdom of Cambodia, 2010, Article 36, http://www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)

364 Phnom Penh Post, Fight gets venomous, 31st October 2013, http://www.phnompenhpost.com/national/fight-gets-venomous (last accessed 3rd June 2016); Phnom Penh Post,
First snakes, now ‘arson’, 18th March 2014, http://www.phnompenhpost.com/national/firstsnakes-now-%E2%80%98arson%E2%80%99 (last accessed 3rd June 2016); Phnom Penh
Post, For communities, threats routine, 8th May 2014, http://www.phnompenhpost.com/
national/communities-threats-routine (last accessed 4th June 2016);

347 Radio Free Asia, Hun Sen declares assets, 1st April 2011, http://www.rfa.org/english/
news/cambodia/assets-04012011163501.html (last accessed 5th June 2016)348 Heinrich Boell Foundation, Indigenous Peoples And Land Titling In Cambodia: A StudyOf Six Villages, 2013, p.3, https://www.boell.de/sites/default/files/indigenous-peoples-andland-titling-in-cambodia_a-study-of-six-villages.pdf (last accessed 6th June 2016); RNWMedia, Controversy over Cambodia PMs land titling plan, undated, https://www.rnw.org/
archive/controversy-over-cambodia-pms-land-titling-plan (last accessed 6th June 2016);
ABC News, Concerns over Cambodia’s use of students in land titling scheme, 8th October
2012, http://www.abc.net.au/news/2012-10-08/an-controversy-over-pm27s-plan-to-involvestudents-in-land-tit/4300714 (last accessed 6th June 2016)
349 Cambodia Daily, Hun Sen Says CPP Largess Will End if Election Is Lost, 7th March 2013,https://www.cambodiadaily.com/elections/hun-sen-says-cpp-largess-will-end-if-election-islost-12645/ (last accessed 4th June 2016);
350 Anti Corruption Law of the Kingdom of Cambodia, 2010, Article 38, http://www.cambodiainvestment.gov.kh/anti-corruption-law_100417.html (last accessed 6th June 2016)
351 Criminal Code of the Kingdom of Cambodia, 2009, Article 595 (Defines of Influential Deal)
and Article 599 (Definition of Favouritism), https://www.unodc.org/res/cld/document/khm/
criminal_code_of_the_kingdom_of_cambodia_html/Cambodia_Criminal-Code-of-theKingdom-of-Cambodia-30-Nov-2009-Eng.pdf (last accessed 6th June 2016); Anti Corruption
Law of the Kingdom of Cambodia, 2010, Article 32, http://www.cambodiainvestment.gov.kh/
anti-corruption-law_100417.html (last accessed 6th June 2016)
352 Criminal Code of the Kingdom of Cambodia, 2009 , Article 595, https://www.unodc.
org/res/cld/document/khm/criminal_code_of_the_kingdom_of_cambodia_html/Cambodia_Criminal-Code-of-the-Kingdom-of-Cambodia-30-Nov-2009-Eng.pdf (last accessed 6thJune 2016)
353 Criminal Code of the Kingdom of Cambodia, 2009 , Article 599, https://www.unodc.
org/res/cld/document/khm/criminal_code_of_the_kingdom_of_cambodia_html/Cambodia_Criminal-Code-of-the-Kingdom-of-Cambodia-30-Nov-2009-Eng.pdf (last accessed 6thJune 2016)
354 Financial Action Taskforce (FATF), International Standards On Combating Money Laundering And The Financing Of Terrorism & Proliferation, February 2012, pp.119-120, http://
www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recommendations.
pdf (last accessed 6th June 2016)
355 Financial Action Taskforce (FATF), International Standards On Combating Money
Laundering And The Financing Of Terrorism & Proliferation, February 2012, p.16, http://www.
fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recommendations.pdf(last accessed 6th June 2016)
356 Law On Anti-Money Laundering And Combating The Financing Of Terrorism of theKingdom of Cambodia, Unofficial translation, 2007, Article 10.1(f) & 10.2, http://www.
cambodiainvestment.gov.kh/content/uploads/2011/09/Law-on-Money-Laundering-Terrorist-Financing_Full-Text_070624.pdf (last accessed 6th June 2016)
357 World Bank, Detailed Assessment Report Anti-Money Laundering And Combating The
Financing Of Terrorism – Kingdom of Cambodia, 25th July 2007, point 318, p.59, http://
www-wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/2012/06/25/00042
6104_20120625152021/Rendered/PDF/701180ESW0P1140rld0Bank0DAR0July007.pdf (lastaccessed 6th June 2016)
358 World Bank, Detailed Assessment Report Anti-Money Laundering And Combating The
Financing Of Terrorism – Kingdom of Cambodia, 25th July 2007, p.63, http://www-wds.
worldbank.org/external/default/WDSContentServer/WDSP/IB/2012/06/25/000426104_201
20625152021/Rendered/PDF/701180ESW0P1140rld0Bank0DAR0July007.pdf (last accessed
6th June 2016)359 Pudo website, An open database of persons and entities of interest, http://pudo.org/
material/opennames/. Full list of persons and entities of interest accessible at http://archive.
pudo.org/opennames/latest/full.xlsx (last accessed 6th January 2016)
360 1998 General Statute of Military Personnel of the Royal Cambodian Armed Forces, Article
25, p.4, https://www.ilo.org/dyn/natlex/docs/ELECTRONIC/93508/109344/F811412622/
KHM93508%20Eng.pdf (last accessed 2nd June 2016)

365 Kingdom of Cambodia Law on Commercial Enterprises, 2005, Articles 7 & 290, http://
www.cambodiainvestment.gov.kh/content/uploads/2012/03/Law-on-Commercial-Enterprises_English_050517.pdf (last accessed 6th June 2016)
366 Kingdom of Cambodia Law on Commercial Enterprises, 2005, Articles 230, http://www.
cambodiainvestment.gov.kh/content/uploads/2012/03/Law-on-Commercial-Enterprises_English_050517.pdf (last accessed 6th June 2016)367 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry, data extracted in December 2014 and February 2016 by Global
Witness. All data accessible at https://cambodiacorporates.globalwitness.org/. For information on company type download the raw data spreadsheets of company registrations; A
breakdown of this figure can also be found in Annex 4.
368 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry, data extracted in December 2014 and February 2016 by Global
Witness. All data accessible at https://cambodiacorporates.globalwitness.org/. For a full listof the Hun family’s holdings see the infographic on page X or Annex 1.
369 Analysis based on official government data from the Cambodian Ministry of Commerce’s
online corporate registry, data extracted in December 2014 and February 2016 by Global Witness. All data accessible at https://cambodiacorporates.globalwitness.org/. For informationon company type download the raw data spreadsheets of company registrations. For a fulllist of the Hun family’s holdings see the infographic on page 16 or Annex 1 on page 33.

Unless otherwise stated, all photos in this report are credited to the Phnom Penh Post.
They remain the copyright and property of Post Media Co.

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