Vietnam Compliance Report

Generated 2026-09-22

Prohibited

Regulatory Overview

Regulatory Status: Outright ban on crypto ownership, trading, or mining
Key Regulator(s): Ministry of Finance, Bank of Vietnam, State Securities Commission, Ministry of Public Security
Primary Legislation: The New AML Law 2022 (PwC Report), Key Compliance for Vietnam's Anti-Money Laundering Law, Law on Digital Technology Industry (No. 71/2025/QH15): Passed June 14, 2025; eff
Travel Rule: Adopted — Threshold: $1,000

Key Facts

aml State Bank of Vietnam (SBV): Oversees AML/CFT compliance. Anti-Money Laundering Department (AMLD) under SBV: Functions as the Financial Intelligence Unit. Law on Anti-Money Laundering 2022 (Law No. 14/2022/QH15): Effective March 1, 2023. Decree 19/2023/ND-CP: Details implementation of the 2022 AML Law. Circular 09/2023/TT-NHNN: Guides financial reporting entities. Decision No. 11/2023/QD-TTg: Raises large-value transaction reporting threshold to VND 400 million. Vietnam is under increased monitoring by the FATF (grey list as of February 2026). The 2022 AML Law aims to align with FATF standards. Vietnam AML & Sanctions Compliance · ANQA Compliance
enforcement Regulator: Ministry of Public Security (MoPS). Entity Targeted: ONUS cryptocurrency platform (including tokens VNDC, ONUS, and HNG), operated by Vương Lê Vĩnh Nhân (Eric Lê/Vuong Le Vinh Nhan) and associates. Violation Type: Fraud via token price manipulation, deceptive marketing, misleading promotions, artificial trading to control supply/demand, property appropriation, and money laundering using platform infrastructure. Penalty Amount: Not yet finalized; investigation targets billions of dollars in mobilized funds and investor losses (preliminary estimates in billions of USD). Date: Criminal proceedings launched March 23, 2026; investigation ongoing with raids across Hanoi, Ho Chi Minh City, Da Nang, and Can Tho. Outcome: At least 7–9 arrests (including Vương Lê Vĩnh Nhân and 6–8 accomplices); over 140 individuals summoned; platform operations dismantled; charges filed for fraud and money laundering.
general Originator and beneficiary details (including wallet addresses) Minimum charter capital requirement of 10 trillion Vietnamese dong (~$400 million) Foreign ownership capped at 49%, with 65% minimum institutional ownership required Mandatory anti-money laundering and cybersecurity compliance Strict governance standards and information disclosure requirements Purpose: Strengthen Vietnam’s AML/CFT regime to prevent illicit financial activities. Mandates customer due diligence (CDD) for all reporting entities. Requires risk-based assessments and ongoing monitoring of transactions.
licensing State Securities Commission (SSC) — Licensing review and compliance monitoring Ministry of Finance (MOF) – Lead regulatory authority responsible for developing the legal framework and issuing licensing procedures State Securities Commission (SSC) – Co-regulatory body reviewing licensing applications State Bank of Vietnam (SBV) – Central bank ensuring financial stability and preventing crypto use as payment Ministry of Public Security (MPS) – Safeguarding cybersecurity and financial integrity Ministry of Justice (MOJ) – Providing legal analysis and policy recommendations The framework mandates VASPs to apply AML/CTF obligations as part of licensing, treating crypto exchanges as market infrastructure akin to securities exchanges. This includes internal policies for AML/CFT, counter-proliferation financing, risk management, and market surveillance. Oversight involves MOF (lead), SSC (receiving applications), SBV (financial integrity), and MPS (AML, cybersecurity).
sanctions UN consolidated lists. OFAC SDN List and other programs. Vietnam's national sanctions list published by the Ministry of Finance. AML Law 2022 and SBV obligations: https://www.anqacompliance.com/vietnam-detailed-country-aml-information/ Draft Decree (Nov 2025) under Resolution No. 05/2025/NQ-CP: https://www.tilleke.com/insights/vietnams-draft-crypto-sanctions-decree-enforcement-comes-to-the-pilot-market/ OFAC SDN Search: https://sanctionssearch.ofac.treas.gov OFAC Programs: https://ofac.treasury.gov/sanctions-programs-and-country-information The United States maintains comprehensive sanctions on Vietnam, targeting specific individuals, entities, and sectors, including those involved in cybersecurity and personal data protection violations.
securities State Securities Commission (SSC): Responsible for overseeing securities markets and issuing regulations such as Circular 01/2015/TT-BTC on guiding foreign investment activities. Ministry of Finance (MoF): Defines functions, tasks, and powers related to financial regulation and oversees the implementation of securities-related decrees. Law on Securities (2015): Governs securities trading and issuance; cited in Circular 01/2015/TT-BTC. Government Decree No. 58/2012/ND-CP: Details implementation of the Law on Securities. Government Decree No. 64/2007/ND-CP: Applies information technology to state agency operations, indirectly affecting digital asset transparency. Entities Requiring License: Foreign investors directly purchasing or selling securities must register with the Vietnam Securities Depository through depository members. Capital Requirements: No explicit monetary thresholds are stipulated in Circular 01/2015/TT-BTC; compliance is based on registration rather than capital adequacy. Foreign investors submit a complete dossier to a depository member (Appendices 1 or 2 of the Circular).
status Ministry of Finance (MOF): Leads development of the legal framework, virtual asset regulations, licensing oversight, and AML/CFT integration. State Bank of Vietnam (SBV): Ensures financial stability, develops regulations, and enforces the ban on crypto as payment (per historical directives like Official Letter No. 5747/NHNN in 2017). State Securities Commission (SSC): Coordinates on licensing, compliance, and sandbox initiatives (e.g., with exchanges like Bybit). National Assembly: Passed key legislation; highest legislative authority. Ministry of Justice (MOJ): Provides legal analysis and policy recommendations. Ministry of Public Security (MPS): Oversees cybersecurity and financial integrity in licensing. Law on Digital Technology Industry (No. 71/2025/QH15): Passed June 14, 2025; effective January 1, 2026. Establishes definitions, business conditions, state management (e.g., technical standards, monitoring exchanges/custody), and AML/cybersecurity requirements. Resolution No. 05/2025/NQ-CP (Resolution 5): Issued September 9, 2025. Launches a five-year pilot for cryptocurrency exchange licensing with strict capital, ownership, and compliance rules.
travel rule Vietnam falls under "Countries That Have Initiated the FATF’s Travel Rule Process", indicating ongoing development of crypto regulations but no finalized Travel Rule legislation or mandates requiring VASPs to comply during transactions. Globally, 85% of surveyed jurisdictions (covering ~98% of VASP activity) have enacted or are enacting the Travel Rule, but Vietnam is not confirmed in the "in place" category. No specific effective date, threshold amounts (e.g., FATF's recommended $1,000/€1,000), VASPs covered, technical implementation requirements (such as data collection/retention standards or interoperability protocols), or penalties for non-compliance are detailed for Vietnam in available sources. These details remain unavailable due to Vietnam's pre-implementation status; FATF's Recommendation 15 (R.15) updates track progress but do not specify Vietnam's timeline or provisions. No Vietnam-specific legislation (e.g., laws or decrees mandating Travel Rule compliance) is referenced; sources highlight general FATF progress without local URLs or documents for Vietnam. For context, FATF's jurisdictional table (revised post-March 2024) assesses R.15/INR.15 across 67 jurisdictions but excludes Vietnam-specific outcomes here. The official FATF implementation status table directly from FATF's website Vietnam's financial regulator (State Bank of Vietnam) guidance on Travel Rule compliance

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-21. View full profile