General research for information only — not legal, tax, or investment advice. Cambodian law and markets change; figures are indicative, so verify current detail with a qualified local professional before you act.
Cambodia’s banking system is holding a smaller share of immediately accessible US dollar reserves at the central bank than at any point in more than a decade — and that fact has a direct, underappreciated read-through for anyone financing a property purchase, funding a development project, or holding transaction balances in the country.
The ASEAN+3 Macroeconomic Research Office (AMRO), the regional surveillance body, published its latest assessment on 28 July 2026. The headline finding is straightforward: Cambodian commercial banks’ dollar liquidity held at the National Bank of Cambodia (NBC) declined to an estimated 10.4% of total USD deposits as of March 2026, down from 12% at the end of 2025, and the lowest ratio in the AMRO dataset. What appears at first glance to be a narrow banking-sector metric becomes, on closer reading, a story about where capital is flowing, why, and what happens to credit availability when a cooling property market meets a banking system that is rationally pulling capital offshore.
The AMRO finding in context
The decline is not the result of a deposit run or a sudden funding crisis. Cambodian banks are not short of capital. What the AMRO report describes is a deliberate, commercially rational reallocation of assets. Banks increased their net foreign assets by approximately $10.5 billion during 2024 and 2025 — roughly three times the increase in Cambodia’s official foreign exchange reserves over the same period. They did this by expanding holdings of overseas assets while simultaneously reducing foreign liabilities, resulting in a significant net outflow of US dollar liquidity from the domestic banking system.
The logic is straightforward. Domestic lending demand has softened — credit grew just 4.6% year-on-year in H1 2026, with the construction and real estate sectors specifically flagged by the NBC as slow to recover. Meanwhile, credit quality is deteriorating: gross NPLs reached 9.6% as of June 2026, up from 8.4% at year-end 2025. Against that backdrop, banks facing rising risk and weak loan demand have rationally chosen to deploy capital offshore where risk-adjusted returns look more attractive.
AMRO’s language is measured but direct: the reallocation is “commercially rational for individual banks facing slowing credit demand and elevated risks in the domestic market.” But the report also flags the system-level vulnerability — if a period of financial stress were to emerge, “a larger share of banking sector liquidity would be held offshore rather than immediately available within Cambodia.”
What this means for property lending
For anyone tracking Cambodia’s property market through the lens of financing availability, the AMRO finding reinforces a pattern that has been building for months.
Domestic bank lending to the property sector was already tightening through 2025 and into 2026. The IMF’s July 2026 Article IV mission identified “the slow recovery of the construction and real estate sectors” as a key risk, and noted that the end of regulatory forbearance was making asset-quality pressures more visible. The NBC’s own H1 data shows 239,546 restructured loan accounts worth $4.8 billion still being normalised — 7.5% of the total loan portfolio.
The AMRO report adds a new dimension: it’s not just that banks are cautious about new property lending because of existing asset-quality concerns, but that the aggregate liquidity pool available for domestic lending is structurally smaller than it was two years ago. Every dollar a bank places in an overseas asset is a dollar not available for a domestic mortgage, a construction loan, or a developer working-capital facility.
This matters at two levels.
For the individual buyer financing a purchase, the practical consequence is that banks operating with tighter domestic liquidity buffers and rising NPLs tend, in aggregate, toward more conservative property valuations, tighter loan-to-value ratios, and more selective underwriting — not because any single borrower is a worse credit risk, but because the bank’s own balance-sheet management is more constraining. A buyer with strong documentation and a substantial down payment remains financeable; a marginal buyer — self-employed, reliant on non-standard income documentation, or purchasing in a weaker sub-market — faces a narrower set of options than would have been available in 2023 or 2024.
For the developer, the implication is more structural. The development pipeline depends on bank construction finance, and that finance is priced and allocated against the same liquidity pool that the AMRO report shows is shrinking in domestic allocation terms. A developer seeking to refinance a maturing construction loan, or to secure forward funding for a new phase of an existing project, is competing for domestic credit against a banking sector that has already signalled, through its asset allocation, that it prefers deploying capital offshore. This compounds the refinancing risk that the IMF flagged in July 2026 and that we analysed in detail in our earlier piece on bank forbearance and property financing risk.
Dollarization as the structural constraint
The AMRO report also surfaces a structural feature of Cambodia’s financial system that is easy to overlook in the day-to-day discussion of property financing: this is a highly dollarized economy in which the central bank cannot print dollars.
At the end of 2025, 83.4% of Cambodia’s broad money (M2) was denominated in US dollars. The NBC has introduced liquidity facilities to support the riel and has aligned reserve requirements between USD and riel deposits. But it cannot create dollars the way a conventional central bank can create domestic currency. This means that in a stress scenario, the NBC’s ability to act as a lender of last resort is fundamentally constrained for the dollar-denominated portion of the banking system — which is the vast majority.
This is not a hypothetical observation. The 24th AMRO Annual Consultation Report, published alongside the 28 July release, makes the point explicitly: “The limited ability of the NBC to perform lender-of-last-resort operations for the U.S. dollar segment of the banking system continues to expose the financial system to liquidity risks.”
For property transaction planning, this creates a specific risk that is rarely discussed in marketing materials or agent presentations: escrow and deposit balances held in Cambodian banks are not implicitly guaranteed by a central-bank backstop in the way they would be in a country with a conventional monetary system and deposit insurance. Cambodia has no deposit insurance scheme — an issue we explored in detail in our coverage of the Prince Bank, Panda Bank, and H-Pay liquidations. The AMRO report reinforces why that gap matters: in a system where the central bank’s dollar lender-of-last-resort capacity is limited, depositor protection depends more heavily on bank-level liquidity buffers, which the AMRO report shows are declining in domestic allocation.
The AMRO policy recommendations
The report puts forward several recommendations aimed at strengthening Cambodia’s liquidity resilience:
- Close monitoring of US dollar liquidity conditions, particularly as NPLs continue to rise, since deteriorating asset quality can reduce banks’ cash inflows and weaken depositor confidence
- Policy measures to encourage banks to repatriate a portion of their overseas holdings — AMRO’s modelling suggests that reallocating just one-quarter of banks’ net foreign assets into domestic liquidity buffers “would significantly improve the banking system’s coverage ratio and strengthen depositor confidence”
- Continued progress on developing a deposit insurance framework, which the NBC has been studying under a working group with the Ministry of Economy and Finance but which has not yet progressed to legislation
The key tension here is between individual bank rationality and system-level resilience. Every bank making the individual decision to deploy capital offshore is making a commercially sound choice given domestic credit conditions. But the aggregate effect is a system with thinner domestic liquidity buffers, and those buffers are what matter in a crisis.
What a buyer or investor should watch
The AMRO report is new — published 28 July 2026 — and its implications for property financing will unfold over the coming quarters rather than weeks. But it joins a growing body of signals that point in a consistent direction.
The IMF flagged it in July. The NBC’s own H1 data confirms it. And now AMRO has quantified the liquidity dimension. The message across all three is the same: Cambodia’s banking system is functioning but cautious, domestic credit allocation is tightening, and the capital that once flowed into property lending is being deployed elsewhere — including outside the country entirely.
For a buyer, the practical takeaway is not alarm, but due diligence. If you are financing, stress-test your approval against tighter conditions than today’s. If you are holding transaction funds in a Cambodian bank account, know which institution you are banking with and whether it is among the largest, systemically important players. If you are a developer, factor refinancing risk into your phase planning rather than assuming construction finance will roll over on the same terms.
The AMRO report is not a crisis warning. It is a warning that the margin of safety in Cambodia’s banking system — measured by the most basic metric of immediately accessible dollar liquidity — is thinner than it has been, and that it has been getting thinner for reasons that are unlikely to reverse quickly. For anyone with capital exposed to the Cambodian property market, that is information worth acting on.
Sources
- [S-1] Cambodia Investment Review — AMRO Warns Cambodia Banks’ Dollar Liquidity Buffers Have Fallen to Record Low in 2026 as Funds Shift Overseas (28 Jul 2026)
- [S-2] Khmer Times — NBC reports 4.6% credit growth for banking sector (28 Jul 2026)
- [S-3] AMRO 24th Annual Consultation Report on Cambodia (Jul 2026)
- [S-4] Cambodia Investment Review — IMF Completes Cambodia Article IV Mission, Cuts 2026 Growth Forecast to 3% (8 Jul 2026)
- [S-5] Research Cambodia — IMF July 2026: Bank Forbearance and Property Financing Risk
- [S-6] Research Cambodia — Three Linked Bank Failures and What They Reveal About Banking Risk
Frequently asked questions
What did the AMRO report actually find about Cambodia bank dollar liquidity?
The ASEAN+3 Macroeconomic Research Office found that Cambodian commercial banks held only 10.4% of total USD deposits as immediately accessible liquidity at the National Bank of Cambodia as of March 2026 — the lowest level on record under their measure, down from 12% at end-2025. Banks shifted roughly $10.5 billion into overseas assets during 2024–2025, seeking higher returns amid weak domestic lending demand and rising credit risk.
How does lower bank dollar liquidity affect property buyers and developers in Cambodia?
Capital flowing out of the domestic banking system means less liquidity for property lending — mortgages, construction finance, and developer working capital. Banks facing tighter liquidity buffers tend to be more selective about new credit exposure, particularly to real estate with elevated NPLs. For buyers, this can mean tighter loan-to-value ratios and longer approvals. For developers, it compounds the refinancing risk already flagged by the IMF.
Can banks repatriate their offshore funds quickly if needed?
AMRO reports that market participants believe much of the ~$10.5B in overseas assets consists of trade settlement funds and short-term deposits that remain relatively liquid and could theoretically be repatriated. However, the report also notes that if a period of financial stress were to emerge, a larger share of banking sector liquidity would be offshore rather than immediately available within Cambodia — creating a timing mismatch that matters most in a crisis scenario.
What is the NBC doing about the liquidity situation?
Governor Chea Serey describes the banking sector as "highly resilient," citing 4.6% credit growth and capital adequacy above regulatory minimums. However, AMRO notes that Cambodia's structural dollarization limits the central bank's ability to act as a traditional lender of last resort, since the NBC cannot create US dollars — making bank-level liquidity buffers more critical than in a conventional system.