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United States Sanctions Cambodian Officials for Corruption Related to China-Linked Naval Base  

The United States on November 10, 2021 imposed Global Magnitsky Sanctions on two Cambodian government officials, for corruption relating to the Ream Naval Base. In tandem, the State Department imposed visa restrictions on the sanctioned Cambodian officials and their immediate family members, under Section 7031(c) of the FY 2021 Department of State, Foreign Operations, and Related Programs Appropriations Act.

The sanctioned Cambodian officials are Chau Phirun, Director-General of the Ministry of National Defense Material and Technical Services Department, and Tea Vinh, the Royal Cambodian Navy Commander.  According to the Treasury Department, in 2020 and 2021, Chau “conspired to profit from activities regarding the construction and updating of Ream Naval Base facilities.”  Chau, with Tea and other Cambodian government officials, “likely conspired to inflate the cost of facilities at Ream Naval Base and personally benefit from the proceeds. Tea and Chau planned to share funds skimmed from the Ream Naval Base project.”

Chau and Tea are designated under Executive order 13818 of December 20, 2017, “Blocking the Property of Persons Involved in Serious Human Rights Abuse and Corruption.”  EO 13818 is significant, as it broadly defines “corruption” and therefore reaches a wide range of conduct, including the “misappropriation” of state assets and corruption related to government contracts.  See, e.g., MassPoint PLLC, Trump Administration Supercharged Global Magnitsky Corruption and Human Rights Sanctions, Apr. 3, 2018.[1]  As a result of the sanctions actions, Chau and Tea are now “blocked,” meaning, among other things, that U.S. persons – including U.S. banks – are prohibited from engaging in transactions with them, and their “property and interests in property” within the possession or control of U.S. persons or in the United States must be frozen.

According to one news outlet, Cambodia’s “main government spokesman” could not be reached for comment on the sanctions action.  However, China commented on the action through a Foreign Ministry spokesman who reportedly said that “the mutually beneficial cooperation between China and Cambodia brooks no external interference.”  China’s comment is notable, as the sanctions action targeting Chau and Tea, related to the Ream Naval Base, reflects U.S. concerns about China’s commercial and military activities in Cambodia. Earlier this month, the Center for Strategic and International Studies’ Maritime Transparency Initiative (CSIS) published satellite images that, according to CSIS, depict new construction and other activities at the Ream Naval Base. The United States has raised concerns that such construction, and China’s other activities in Cambodia, are intended to facilitate China’s military presence there.  As discussed in a September 2020 MassPoint update on the imposition of Global Magnitsky Sanctions on China state-owned Union Development Group Co., Ltd (UDG) related to UDG’s role in the Dara Sakor project in Cambodia – part of China’s Belt and Road Initiative (BRI)— U.S. sanctions actions targeting China- and BRI-linked parties and activities have geostrategic significance. The most recent action targeting Cambodian government officials for corruption related to the Ream Naval Base is among those actions.


[1]  For more Global Magnitsky Sanctions analysis, see MassPoint PLLC’s Global Magnitsky Sanctions publications at

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