Stopping Dirty Money in Australia and Cambodia: Combatting Dirty Money Through Partnership


Transparency International Australia (TIA) is part of a global coalition to fight corruption and promote transparency, integrity and accountability at all levels and across all sectors of society, including government and the private sector. Corruption undermines good government, distorts public policy, leads to the misallocation of resources, harms private and public sector development and particularly hurts people living in poverty.

With expertise in anti-money laundering reform, beneficial ownership, foreign bribery and anti-corruption legislation reform, TIA works alongside partners across the Asia-Pacific to shine a light on corruption and to hold those responsible to account.

1. Background and rationale

Globally, money laundering a major driver of poverty and inequality – the amount of money laundered every year is equivalent to 2%-5% of GDP. Money laundering erodes public trust, democracy and leads to less government revenue for essential services like health, education and infrastructure. It also creates economic instability, enables criminals to hide their abuses of power, and undermines the legitimate actors in the private sector.

Cambodia’s money laundering vulnerabilities include a weak AML regime; a cash-based, largely dollarized economy; porous borders; loose oversight of casinos; and the National Bank of Cambodia’s limited capacity to oversee the fast-growing financial and banking industries. A weak, deeply politicized judicial system and corruption also constrain effective enforcement.

The major sources of money laundering are widespread through human trafficking and exploitation, drug trafficking, and corruption. Cambodia is also seen as regional money laundering hub for Chinese, Myanmar and Thai interests.

Australia’s weak legal framework and regulations enables criminals and corrupt officials to launder their money into Australia’s real estate, casinos and broader economy. Much of this ‘dirty money’ is flowing across national borders including from Cambodia, and often flows out of poorer countries and into the economies of wealthy nations.

There is an urgent need to close the gaps in anti-money laundering laws so that real estate agents, lawyers, corporate service providers and accountants – professions that are more likely to encounter illicit money – do proper due diligence and report suspicious transactions.

2. Research objectives

This project will contribute to improved regulations to combat money laundering in Cambodia and Australia.

The consultant will undertake research, develop a report and a short presentation of main findings. This research undertaken will increase knowledge and evidence of the drivers of money laundering in both countries, particularly inflows from Cambodia into Australia’s real estate sector. This will help strengthen institutional regulations in both countries and support advocacy.

Further objectives include, but are not limited to:

  1. Defining the nature and scale of the problem, including recent examples, and identify the stakeholders involved in the issue.
  2. Identifying the required changes in regulations, law and institutions in both countries
  3. Exploring and defining the risks to efforts to strengthening governance frameworks
  4. Supporting advocacy that will hold decision-makers to account.

3. Audience and use

The intended audiences and uses for the research include, but are not limited to:

  • Civil society organisations working on anti-corruption and anti-money laundering efforts in Cambodia, Australia and across Asia-Pacific for use in advocacy efforts
  • Australian media to demonstrate scale and nature of the issue
  • National and regional anti-corruption researchers to further body of evidence relating to money laundering and for integration into other anti-money laundering evidence-gathering efforts
  • Government entities working on anti-money laundering reform to support evidence-based policy-making (where safe and appropriate to do so)

4. Term and outputs

Research will be conducted from May 2023-July 2023, with report publication in late September.

  Outputs Date Format
1 Deadline for application 30 April 2023 n/a
2 TOR and researcher contract finalised 10 May n/a
3 Literature and landscape review 20 May Word
4 Initial findings report 20 June Word
5 Draft report 10 August Word
6 Final report publication 30 September PDF


5. Responsibilities

The research and report development will be undertaken by the contracted consultant.

Oversight will be managed by TI Australia with support and inputs from TI Cambodia.

6. Application process

Please send a two-page CV, proposal and budget to by 9am Monday 8 May 2023.

Read more about Transparency International Australia’s work on anti-money laundering and addressing corruption risks.