Vietnam: Robust AML Framework in the Digital Finance Era

Vietnam is strengthening its anti-money laundering vigilance as the rapid growth of digital assets and the emergence of new investment channels create increasingly complex risks for the financial system. These challenges come as Vietnam develops an international financial centre (IFC), aiming to boost financial innovation while requiring stronger, smarter safeguards against illicit flows.

Since the Anti-Money Laundering Law was enacted in 2022, Vietnam’s Anti-Money Laundering Department has received thousands of suspicious transaction reports (STRs) each year, with the volume of reports rising by around 30% annually.

From 2023 onwards, the department has intensified its analysis of these reports, collecting and assessing information before issuing nearly 600 documents related to more than 5,000 STRs.

The Economic Security Department under the Ministry of Public Security will further investigate these instances, underscoring the growing scale and complexity of financial crime risks.

The establishment of the IFC is a key driver of these developments. Designed as a testing ground for innovative financial models and products under risk-controlled mechanisms, the IFC is expected to diversify Vietnam’s financial markets, products and asset classes.

At the same time, insiders caution that the introduction of new investment channels and financial instruments will inevitably make anti-money laundering oversight more challenging, particularly as transactions become more sophisticated and increasingly cross-border in nature.

Economic experts emphasise that IFC banks must act as comprehensive service providers and gatekeepers, monitoring cash flows to combat transfer pricing, cross-border money laundering and ensure financial system confidence.

To reinforce this framework, the Government has issued Decree No. 329/2025/ND-CP, which regulates the licensing and operation of banks in the IFC, as well as foreign exchange management and requirements related to anti-money laundering, counter-terrorism financing and the prevention of financing for weapons of mass destruction.

The decree introduces stricter controls on capital movements, requiring foreign members and investors to clearly state the purpose of funds transferred into the IFC. Banks providing foreign exchange services must verify each transaction and maintain complete documentation, ensuring stronger oversight and that all funds are used in accordance with their declared purposes.

Industry representatives have emphasised that while the IFC offers a promising new platform for growth and innovation, it will operate under close supervision. Transactions are expected to be carefully monitored, with a clear message that there is no tolerance for fraud, money laundering, or uncontrolled capital outflows.

Despite these measures, authorities acknowledge that the legal framework primarily covers formal financial channels, leaving informal or “black market” transactions more difficult to detect and control.

This gap is particularly evident in the area of digital and crypto assets. With their anonymity and ease of cross-border transfer, these assets have been exploited to create underground markets, posing risks not only to financial integrity but also to national security and social order.

Vietnam’s concerns are amplified by the scale of crypto adoption. With an estimated 26 million crypto asset accounts held by Vietnamese users, the potential for misuse remains significant. Law enforcement officials have warned that money laundering through digital assets continues to be a serious issue, even as regulatory efforts intensify.

The State Bank of Vietnam issued Circular No. 27/2025/TT-NHNN to guide the implementation of certain provisions of the Anti-Money Laundering Law, further tightening controls within regulated institutions. Combined with the IFC-specific regulations, these measures reflect Vietnam’s determination to balance financial innovation with robust safeguards.

As Vietnam advances its ambition to become a regional financial hub, the challenge will be to ensure that new growth opportunities do not outpace the country’s ability to manage risk. Strengthening coordination between regulators, financial institutions and law enforcement will remain critical to preserving financial stability and trust in an increasingly digital and interconnected financial landscape.