Is Crypto Legal in Vietnam?

Ministry of Finance: Oversees broader financial regulations impacting AML efforts.

The New AML Law 2022 (PwC Report)

AML/CFT Compliance Guidelines for Vietnam

Key Compliance for Vietnam's Anti-Money Laundering Law

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

Who Needs a License: Virtual asset service providers, crypto exchanges, and other designated non-financial businesses and professions (DNFBPs) like real estate brokers, precious metals dealers, lawyers, and accountants.

Activities Requiring Licensing: Trading of virtual assets, custodial services, issuance of stablecoins, and providing payment intermediary services for crypto transactions.

Capital Requirements: Not explicitly stated in current legislation; expected to be part of the pilot program under Resolution No. 05/2025/NQ-CP.

Application Process: Submission to the SBV through a prescribed electronic platform, including compliance with risk assessment and CDD requirements.

Timeline & Structural Requirements: Pilot program commencement by early 2025; mandatory electronic submission of reports from January 1, 2026 (Circular 27/2025/TT-NHNN).

Entities Licensed to Date: None as of February 2026, but the pilot program is underway. AML/CFT Compliance Guidelines for Vietnam

Customer Due Diligence (CDD): Identity verification for both individuals and legal entities; understanding the nature and purpose of the business relationship.

Enhanced Due Diligence (EDD): Required for high-risk customers, including PEPs and those from jurisdictions with weak AML controls.

Beneficial Ownership: Identification up to a 25% ownership/control threshold.

PEP Screening: Mandatory screening against domestic and international PEP watchlists.

Transaction Monitoring: Continuous monitoring with automated alerts for suspicious activity.

Record Retention: Maintenance of all KYC, transaction, and reporting records for five years.

Suspicious Transaction Reports (STRs): Must be filed within three working days or one day after suspicion detection (Art. 37, Anti-Money Laundering Law 2022).

Large Value Transaction Reporting (LVTR): Transactions over VND 400 million must be reported to SBV. Vietnam AML Compliance Guide 2026 | Regulations, KYC & Reporting

Penalties: Administrative fines for violations, ranging from VND 500 million to 1 billion; potential criminal prosecution.

Recent Cases: No specific cases cited yet due to the nascent regulatory environment and pilot program status. However, failure to report suspicious transactions or maintain required records can lead to severe penalties.

Crypto Gains Taxation: As of February 2026, no explicit tax guidance for virtual assets exists in Vietnamese law.

Expected Developments: Likely integration into the Personal Income Tax Law and Corporate Income Tax Law through amendments by mid-2026. What is Anti-Money Laundering? AML... | BBCIncorp Vietnam

Regulatory Uncertainty: Lack of clear licensing frameworks and capital requirements for crypto-specific entities.

Implementation Gaps: Transition from grey list to full compliance requires substantial operational adjustments, especially in sectors like real estate and precious metals.

Practical Reality vs. Paper Law: Real-world enforcement may lag behind legislative mandates, particularly concerning the pilot program's rollout.

Vietnam AML & Sanctions Compliance · ANQA Compliance

AML/CFT Compliance Guidelines for Vietnam

Vietnam AML Compliance Guide 2026 | Regulations, KYC & Reporting

What is Anti-Money Laundering? AML... | BBCIncorp Vietnam

Agent Orange Link to AML in Vietnam Veteransʼ Children Remains Complex & Elusive

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/

The United States maintains comprehensive sanctions on Vietnam, targeting specific individuals, entities, and sectors, including those involved in cybersecurity and personal data protection violations.

Transactions subject to U.S. sanctions require a license from the Department of Treasury's Office of Foreign Assets Control (OFAC).

Financial institutions must implement robust anti-money laundering (AML) and know your customer (KYC) procedures to prevent illicit financing to sanctioned entities in Vietnam.

Violations of U.S. sanctions on Vietnam can result in civil penalties, including fines and imprisonment, as well as asset freezes against offending entities.

Income derived from sanctioned Vietnamese entities may be subject to additional U.S. tax reporting requirements and potential penalties.

Emerging regulations, such as Vietnam's draft crypto sanctions decree, pose new compliance challenges for businesses operating in the region.

Vietnam - Global Sanctions Guide

Vietnam AML & Sanctions Compliance Guide 2025

Vietnam's Draft Crypto Sanctions Decree

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.