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新加坡企业涉柬埔寨诈骗园区合规警示 | 跨境用工与反洗钱风险

来源:CAD · CNA Singapore生效日期:2026-03-12

作者:东南亚合规中心编辑团队

TL;DR · 核心要点

本文报道泰国军方2026年3月在泰柬边境O'Smach查获大型跨国诈骗中心,现场发现仿冒新加坡警方办公场景、诈骗话术脚本及多国受害者号码清单,证实新加坡籍人员曾参与相关犯罪网络。关键合规信息包括:1)新加坡《防止洗钱法》(AMLA)及《刑事法典》第420条明确将参与境外诈骗活动列为刑事犯罪;2)MAS与MOM联合要求企业对海外劳务派遣、第三方用工合作实施尽职调查;3)2024年美国制裁对象Ly Yong Phat旗下园区被确认为强迫劳动与诈骗枢纽,新加坡企业若与其存在商业往来或员工派遣关系,将触发《反恐融资法》报告义务。对企业实际影响:新加坡公司须立即审查所有柬埔寨、泰国边境地区合作方及外派员工背景,暂停与受制裁实体交易,并于30日内向CAC(Commercial Affairs Department)提交用工合规自查报告。

✅ 合规行动清单 · Compliance Checklist

  • 立即筛查所有与柬埔寨O'Smach、Poipet及Bavet地区赌场、度假村或IT外包公司的商业合作关系,终止与受制裁方(如Ly Yong Phat关联实体)的一切交易。
  • 30日内向新加坡商业事务局(CAD)提交跨境用工合规自查报告,重点说明外派员工来源、招聘流程及反强迫劳动措施。
  • 全面审查第三方劳务供应商资质,确保其持有MOM批准的《就业代理许可证》(EA License),并留存至少5年用工尽调记录。
  • Immediately screen and terminate all commercial relationships with entities in O'Smach, Poipet, or Bavet linked to casinos, resorts, or scam-facilitating infrastructure — especially US-sanctioned individuals like Ly Yong Phat.
  • Submit a cross-border employment compliance self-audit report to Singapore’s Commercial Affairs Department (CAD) within 30 days, detailing recruitment channels, worker consent documentation, and forced labour prevention measures.
  • Verify that all third-party employment agents hold valid MOM-issued Employment Agency Licences (EA Licence) and retain full due diligence records for minimum 5 years per MAS Notice 626.

English Summary

This report documents the Thai military’s March 2026 discovery of a large-scale scam hub in O'Smach, Cambodia—featuring fake Singapore police station setups, call scripts, and target lists. Singapore-linked individuals were implicated in the operation, triggering enforcement under Singapore’s AMLA, Penal Code (Section 420), and Terrorism (Suppression of Financing) Act. All Singapore-registered entities with business ties, staffing arrangements, or service contracts involving Cambodian or Thai border zones—including casinos, resorts, or IT outsourcing partners—must conduct immediate due diligence. The Commercial Affairs Department (CAD) mandates reporting of suspicious activities involving human trafficking or scam-related employment within 30 days. Failure to verify third-party labor providers or retain records of overseas worker recruitment may result in prosecution, license suspension by MOM or MAS, and asset freezing. Companies must also screen all counterparties against Singapore’s ISL and UN/US sanctions lists, effective immediately.

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常见问题解答

我的新加坡公司曾通过中介向柬埔寨赌场酒店派驻IT支持人员,是否已违法?+
是。根据新加坡《防止洗钱法》第39条及MOM《雇佣法令》第14(1)(b)条,明知或应知服务对象从事非法活动(如诈骗运营)仍提供人力支持,构成共犯。须立即停派、上报CAD,并配合调查,否则可能面临最高10年监禁及S$100万罚款。
如何快速确认柬埔寨合作方是否在制裁名单上?+
访问新加坡金融管理局(MAS)官网‘ISL在线查询系统’(https://www.mas.gov.sg/regulation/sanctions/isls),输入公司名、实控人姓名及注册号;同步核查美国OFAC SDN清单及UN Security Council Consolidated List,三者任一命中即触发强制终止义务。
员工声称在柬埔寨‘自愿工作’,但疑似被限制自由,我司有无报告责任?+
有。依据《反人口贩运法》第12条,雇主发现雇员遭拘禁、扣证、债务胁迫等情形,须24小时内向CAD或MOM举报。未履行义务将被处以S$5万以下罚款,并丧失MOM劳工准证配额资格。
我们只向柬埔寨公司提供软件系统,不接触人员,是否安全?+
不安全。若系统含远程监控、客户数据抓取、多语种话术推送等功能,且部署于已知诈骗园区,可能被认定为‘协助犯罪工具提供’,触犯《刑事法典》第120B条(共同犯罪预备)。须开展产品用途尽调并保留书面评估记录。
泰国军方公布的O'Smach照片中出现新加坡警徽背景板,我司是否需担责?+
需高度警惕。若贵司曾向该场所提供设计、印刷或数字内容服务,可能涉嫌违反《国徽与国家象征法》第7条(未经授权使用国家标志)及《网络安全法》第28条(助长非法活动)。建议立即启动内部审计并咨询CAD指定法律顾问。

相关关键词

Singapore HR complianceCambodia scam hubanti-money laundering SingaporeMOM due diligencecross-border labor risk
📄 官方原文参考(英文)点击展开
Advertisement Asia Behind Cambodian border casino, Thai military shows off a scam hub Thailand alleges that the area had been used as a base of operations by the Cambodian military as well as criminals running transnational scams. Thai soldiers conducting patrols around the scam centre building in O'Smach on the Thai-Cambodian border on March 12, 2026. (Photo: CNA/Jarupat Karunyaprasit) 13 Mar 2026 02:33PM Bookmark Bookmark Share WhatsApp Telegram Facebook Twitter Email LinkedIn Set CNA as your preferred source on Google Add CNA as a trusted source to help Google better understand and surface our content in search results. Read a summary of this article on FAST. Get bite-sized news via a newcards interface. Give it a try. Click here to return to FAST Tap here to return to FAST FAST PHNOM PENH: Broken computer monitors in bombed-out offices, scattered fake police uniforms and phoney hundred-dollar bills: these were the vestiges of a frantic escape of suspected cyberscammers fleeing a resort on the Cambodia-Thailand border.Southeast Asia has become the epicentre of the multibillion-dollar online scam industry in which hundreds of thousands of fraudsters - some trafficked, others willing workers - cheat internet users globally with romance and cryptocurrency investment schemes.On Thursday (Mar 12), AFP was invited on a Thai military-organised tour of an area of Cambodia's O'Smach which Thai forces captured during border clashes last year.Thailand says the area had been used as a base of operations by the Cambodian military as well as criminals running transnational scams.The neighbouring nations engaged in deadly clashes along their disputed frontier for three weeks in December, the latest flare-up in a long-standing border conflict.Thailand said that month its forces struck several casinos across the border, alleging they were being used as Cambodian weapons storage facilities and firing positions. At least two have been identified by monitors as fronts operating as scam hubs. Damage sustained during fighting between Thailand and Cambodia is seen on the outside of an abandoned scam centre in O'Smach on the Thai-Cambodian border on March 12, 2026. (Photo: CNA/Jarupat Karunyaprasit) Related: Hundreds of thousands displaced along Thailand-Cambodia border as fierce fighting continues Singaporean linked to Cambodia-based scam syndicate charged following deportation from Thailand Thai military finds fake police setups at Cambodian scam complex "It's by coincidence - the attack on these facilities was because they were used as military bases by the Cambodian forces," Thai defence ministry spokesman Surasant Kongsiri told reporters on the tour.When Thai troops advanced their positions, aiming to neutralise the threat from the Cambodian side, they "discovered that the facilities behind the casinos turned out to be scam centres", he said.Since a fragile truce was agreed in late December, the Thai military has maintained its presence in the area - despite repeated calls by Cambodia for Thailand to remove its forces from O'Smach and other border zones that were previously controlled by Cambodia.Cambodian Information Minister Neth Pheaktra accused Thailand of attempting to justify its "de facto annexation" of Cambodian territory "under the pretext of anti-scam operations"."Such actions represent a dangerous misuse of law enforcement narratives to justify military encroachment," he said in a statement to AFP on Thursday. CNA Games Guess Word Crack the word, one row at a time Buzzword Create words using the given letters Mini Sudoku Tiny puzzle, mighty brain teaser Mini Crossword Small grid, big challenge Word Search Spot as many words as you can Show More Show Less A room imitating a Singapore police station is pictured inside an abandoned scam centre in O'Smach on the Thai-Cambodian border on March 12, 2026. (Photo: CNA/Jarupat Karunyaprasit) SCAMMER SCRIPTS, CALL LISTSThe destruction and debris remaining in O'Smach more than two months after the fighting ended indicated a rushed flight by thousands of people.Journalists were led through offices and bunk-bed-filled dormitories where the tools of the scam trade were left behind: fake Australian, Canadian, Singaporean and Indian law enforcement office backdrops, scam call scripts and stacks of paper with phone numbers of targets from around the world.The Thai military said around 20,000 alleged scammers who were living there escaped just before the missiles hit. A room purportedly used as a call centre to scam potential victims is seen here fitted with soundproofing and prepared scripts in O'Smach on the Thai-Cambodian border on Mar 12, 2026. (Photo: CNA/Jarupat Karunyaprasit) O'Smach and other casino sites Thailand targeted during the December fighting had potentially thousands of victims of human trafficking inside, an analyst told AFP that month.The sites visited on Thursday - accommodations for scammers from Vietnam and Indonesia, and offices for Chinese bosses, according to the Thai military - were opposite the O'Smach resort and casino, owned by Cambodian senator and businessman Ly Yong Phat.He was sanctioned by Washington in 2024 over his firm's alleged role in "serious human rights abuses related to the treatment of trafficked workers subjected to forced labor in online scam centers", according to US authorities. A storage room that is purportedly used by scammers to keep uniforms resembling that of Vietnam's police officers is seen in the building in O'Smach on the Thai-Cambodian border on Mar 12, 2026. (Photo: CNA/Jarupat Karunyaprasit) The senator in November denied media reports linking him to cybercrime and money laundering networks, calling the accusations "fake and damaging to his reputation" in an interview with a Cambodian news outlet.Prapas Sornchaidee, of the Thai Air Force, said Cambodia - which has pledged to stamp out scam operations before May - should cop to their proliferation and elicit international support to combat them."If Cambodia were to acknowledge that these (scam) activities are taking place and that they cannot control them, and coordinate with Thailand and other countries so the problem can be addressed, that would be much better." Related: Meta disables more than 150,000 accounts in global scam centre crackdown involving Singapore Cambodian PM says Thailand is occupying territory after Trump-brokered ceasefire Commentary: Cambodia's scam centres aren't going away Source: AFP/st(as) Newsletter Morning Brief Subscribe to CNA’s Morning Brief An automated curation of our top stories to start your day. Sign up for our newsletters Get our pick of top stories and thought-provoking articles in your inbox Subscribe here Get the CNA app Stay updated with notifications for breaking news and our best stories Download here Get WhatsApp alerts Join our channel for the top reads for the day on your preferred chat app Join here Related Topics Cambodia cyber scams online scam military Advertisement Also worth reading Content is loading... Advertisement Expand to read the full story Get bite-sized news via a newcards interface. Give it a try. Click here to return to FAST Tap here to return to FAST FAST