for local and international organisations, including “releasing a statement or doing any activities with the aim of supporting or showing bias towards or against a political party or candidate.” There is no similar provision for government employees. Therefore, any activity could be seen as a violation of the law even if it is not intended to support a party. For instance, Article 84 of the LEMNA could be interpreted by the authorities to mean that monitoring groups commenting on elections violate the requirements of impartiality and neutrality. Article 85 prohibits foreigners from “carrying out direct or indirect activities in the election campaign to support or oppose a political party.” This restricts the activities that foreigners can be involved with around the election period and restricts their freedom of expression regarding political parties or candidates. Once again, the vagueness of this provision could lead to abuses. Terms like “indirect” or “foreigners” are indeed not defined. Articles 140 to 161 state the penalties for the various violations of the LEMNA. A violation of Article 84 leads to the removal of the responsible person from the voter lists for five years (Article 147). A violation of Article 85 leads to the deportation of the foreigner who expressed his/her opinion (Article 149). Article 152 outlines high penalties (five million to 10 million riels – USD 1,200 to USD 2,400) for “any person who […] publicly insults a political party or a candidate running in the election.” This is another example of how the law may be abused to sanction legitimate criticism of a party, policy or candidate. Law on Political Parties (LPP) The LPP contains multiple undue restrictions on freedom of expression, many of which appear to apply in the online sphere. Article 6 of the LPP prohibits political parties from “caus[ing] secession that leads to the destruction of national unity and territorial integrity”, “subvert[ing] the liberal multiparty democracy and the constitutional monarchy”, “affect[ing] the security of the state”, “recruit[ing] armed forces” and “incitement that would lead to national disintegration.”40 Terms such as “subversion”, “incitement”, “destruction”, “integrity” and “disintegration” are undefined. They are vague, unquantifiable and subjective and therefore leave the provisions open to arbitrary interpretation. 40 CCHR. (2017). Legal analysis of the July 2017 proposed amendment to the LPP. cchrcambodia.org/admin/media/analysis/analysis/ english/2017-07-19-CSO-ssubmit-Legal-Analysis-of-ProposedAmendment-to-LPP-to-CC_ENG.pdf In March and July 2017, the National Assembly passed two separate amendments to the LPP. Both these amendments received widespread criticism from human rights organisations due to their severe and unjustifiable restrictions on freedom of expression and other fundamental freedoms. Many of the amended provisions apply to the online space, as they regulate the types of images and symbols which can be used by political parties, and they further invoke severe sanctions – including suspension and dissolution – for political parties that communicate with any individual who has committed any misdemeanour or felony at any point in their lives. The first amendments to Article 6 of the LPP state that political parties should not: (6) Use […] voices, messages, images, written documents or activities of a person convicted of felony or misdemeanor for political gains/interests of its party. (7) Openly or tacitly agree or conspire with a person convicted of felony or misdemeanor to carry out any activities for political gains/interests of its party. (8) Support or develop any plans or conspire with any individuals who carry out activities aiming at opposing the interest of the Kingdom of Cambodia. These amendments drastically expand the scope of Article 6 and further burden the right to freedom of expression. The provisions are excessively broad and unpredictable. They exacerbate the ambiguous nature of Article 6. For example, Article 6(7), by prohibiting the “tacit” agreement of a political party with the supportive statement of any convicted person, could entail the dissolution of a political party unless it dissociates itself from every convicted person who expresses support for the party online, every time such support is expressed. This would likely be practically impossible to enforce; and in fact, many observers have commented that the two amendments were introduced purely to target former opposition leader Sam Rainsy. The amended LPP also introduced new articles, including Articles 11 and 45. Article 11 (3) states that “[t]he symbol/logo of a political party should not be copied or taken from a national symbol or picture representing a religion, Angkor Wat temple or pictures of sculptures of all Khmer Kings or the picture of a physical person.” The prohibition on the use of “the picture of a physical person” constitutes an excessive and unjustifiable restriction on freedom of expression. Banning all images of all individuals from political CAMBODIA / 41