The Vietnamese National Assembly proposes adding cryptocurrency asset services that must file AML reports

Authorized by the Prime Minister, Governor of the State Bank of Vietnam Pham Duc An submitted to the National Assembly the draft law amending the Law on the State Bank of Vietnam, the Law on Anti-Money Laundering, and the Law on Credit Institutions.

8/24/20264 min read

Cryptocurrency asset service providers

The central proposal of the draft law is to formally classify entities providing cryptocurrency asset services, including organizations engaged in the exchange, custody, transfer, issuance, and management of cryptocurrency assets, as subject to reporting requirements under the Law on Anti-Money Laundering. Accordingly, these entities would bear the same legal obligations as commercial banks, insurance companies, stock exchanges, and other traditional financial institutions currently complying with Vietnam's anti-money laundering regulations.

The draft also outlines indicators for identifying suspicious transactions specifically for cryptocurrency asset activities, based on the understanding that suspicious transaction patterns in the blockchain environment possess distinct technical characteristics compared to traditional financial transactions, which current indicators cannot fully encompass. The Ministry of Finance is tasked with leading the implementation of anti-money laundering measures in the cryptocurrency asset sector, conducting inspections and audits as directed by the Government, and overseeing units required to report on their activities in this field.

From the Gray Zone to a Structured Legal Framework

This proposal did not arise from a lack of a legal framework. Vietnam has undergone a remarkable journey in developing regulations on digital assets over the past several years. In 2022, the Prime Minister directed the development of regulations for managing cryptocurrencies. In 2023, the Law on Anti-Money Laundering came into effect, requiring payment service providers to implement Know Your Customer (KYC) measures. In June 2025, the National Assembly passed the Law on Digital Technology Industry, officially recognizing crypto assets as assets and creating a legal basis for digital assets. In January 2026, the Law on Digital Technology Industry will come into effect, classifying digital assets into "virtual assets" and "crypto assets," and empowering the Government to issue detailed regulations on the implementation of the law. Also in January 2026, Resolution No. 05/2025/NQ-CP established a controlled testing mechanism (sandbox), allowing licensed businesses to provide cryptocurrency custody services.

On July 24, 2026, Resolution No. 66.23/2026/NQ-CP urgently amended the 2022 Law on Anti-Money Laundering, adding provisions on beneficial owners, client due diligence, and risk classification; this resolution is effective until February 28, 2027. The August 2026 draft is essentially the next systemic step: integrating crypto asset services into the formal anti-money laundering framework instead of only applying temporary measures.

The strategy of withdrawing from the FATF's grey list.

The goal of being removed from the FATF's grey list is the direct impetus behind many of the decisions in this proposed amendment to the law. Vietnam is not a member of the FATF but is a member of the Asia-Pacific Group on Money Laundering (APG). Being placed on the FATF's grey list increases compliance costs in cross-border transactions, restricts access to the international financial system, and creates barriers for foreign organizations wishing to invest in or partner with entities in Vietnam.

The FATF specifically emphasizes the requirement for countries to include virtual asset service providers within their national anti-money laundering (AML) frameworks, in accordance with FATF Recommendation 15. By officially classifying cryptocurrency asset services as subject to reporting requirements (effective from December 1, 2026), Vietnam will meet one of the most important requirements that the FATF is monitoring for removal from the gray list.

Assessment and Conclusion

Vietnam consistently ranks among the countries with the highest cryptocurrency usage rates globally, maintaining a top position in Chainalysis's Global Cryptocurrency Adoption Index. A large portion of this transaction volume has been and continues to be conducted through foreign exchanges not regulated by any Vietnamese authorities, creating an underground economy that the new anti-money laundering (AML) framework aims to bring under regulation.

The effectiveness of the new AML framework will depend on the ability to enforce regulations against foreign exchanges without a legal presence in Vietnam, a similar challenge faced by many countries in managing crypto assets. Therefore, both Resolution 66.23 (July 2026) and the August draft emphasize the importance of international coordination and adherence to FATF standards; thereby creating a legal basis for requiring cooperation from foreign partners in addressing cross-border money laundering activities related to crypto assets.

The designation of the Ministry of Finance as the primary AML supervisory authority for cryptocurrencies also raises a practical issue: how can Vietnam harmonize AML reporting obligations with the overall licensing and operational framework for crypto asset service providers (which is still being finalized under the implementing regulations of the DTI Law)? This is particularly important because compliance obligations will come into effect before a comprehensive licensing infrastructure for the sector is fully established.

Disclaimer: The content in this article is for informational, research, data analysis, and reference purposes only regarding the cryptocurrency market. All opinions, assessments, forecasts, or opinions reflect the author's perspective at the time of publication and do not constitute investment advice, solicitations for buying or selling, trading recommendations, advertising, marketing, or promotion of any financial products, services, or cryptocurrencies. Mentions of projects, tokens, protocols, exchanges, wallets, or cryptocurrency service providers (CASPs) are for research, analysis, or informational purposes only and should not be construed as endorsements, recommendations, or guarantees in any way. HCCVenture does not broker, advertise, market, promote, or connect users in Vietnam with any cryptocurrency services from CASPs. HCCVenture does not accept asset custody, investment mandates, manage assets, or execute transactions on behalf of clients. All investment decisions are made entirely through the reader's own research (DYOR), evaluation, and responsibility; HCCVenture is not liable for any losses or damages arising from the use of or reliance on the information presented in this article.

Compiled and analyzed by HCCVenture

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