Cybersecurity Law and Digital Payment Systems: Protecting Consumers in the FinTech Era — With Special Focus on Cambodia

Abstract

The explosive growth of financial technology and digital payment systems across Southeast Asia has generated unprecedented economic inclusion for millions of previously unbanked consumers while simultaneously creating a vast and insufficiently governed attack surface for cybercriminals, fraudsters, and state-affiliated threat actors. Nowhere is this paradox more acutely illustrated than in Cambodia, where a decade of aggressive digital financial infrastructure development — anchored by the National Bank of Cambodia's KHQR standardised QR payment system and the Bakong blockchain-based retail payment platform — has elevated financial access among the rural poor while coinciding with Cambodia's emergence as a global epicentre of cyber-enabled financial crime, money laundering through digital payment channels, and the exploitation of regulatory arbitrage by criminal enterprises operating in the country's governance-weak border zones. This article examines the cybersecurity legal framework governing digital payment systems, with Cambodia as its central analytical lens. Drawing on comparative regulatory analysis across the European Union, the United States, Singapore, Thailand, and the ASEAN region, the article assesses the adequacy of existing consumer protection law, payment system regulation, cybersecurity standards, and anti-money laundering frameworks to address the threats that digital payment systems face in the FinTech era. It analyses Cambodia's specific regulatory architecture — the Law on Financial Management, the Payment Systems Law, the National Bank of Cambodia's regulatory framework, and the nascent data protection and cybercrime legal instruments — against the backdrop of the country's dual role as a FinTech innovator and a centre of cyber-enabled financial crime. The article identifies the structural legal deficiencies that prevent effective consumer protection in Cambodia's digital payment ecosystem and advances a normative programme for legal reform that is attentive to Cambodia's development context, its regional integration obligations under ASEAN, and the urgent imperative of disrupting the criminal exploitation of its digital financial infrastructure.