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Vietnam’s Anti-Money Laundering Regulations: What Foreign Firms Need to Know
The State Bank of Vietnam (SBV) has issued Circular 09/2023/TT-NHNN, outlining guidelines for implementing the country’s Anti-Money Laundering Law. The new regulations aim to strengthen efforts to combat money laundering and terrorist financing in Vietnam.
Criteria for Assessing Money Laundering Risks
The Circular sets out several key criteria that firms must use to assess the risk of money laundering in any given transaction:
- Business sector
- Country or territory
- Type of customer
- Products or services provided
- Internal policies and regulations
Firms are advised to develop their own scoring system to evaluate the money-laundering risk associated with a transaction, using a score ranging from one to five. A lower score indicates a reduced likelihood of money laundering risk.
Developing AML Procedures
The Circular requires firms to establish step-by-step procedures for managing AML risks. These procedures must include:
- Objectives and scope
- Customer risk ratings
- Handling of high-risk customers
- Procedures for identifying suspicious transactions
Customer Assessment
Firms are required to assess customers based on their level of risk:
- Low-risk customers may be subject to a simplified due diligence process
- High-risk customers require enhanced due diligence measures
Additional AML Compliance Requirements
The Circular sets out several additional requirements that firms must adhere to:
- Providing annual AML training for leaders and employees
- Updating internal regulations
- Reporting suspicious transactions
- Registering AML compliance officers with the relevant authorities
Reporting on Electronic Funds Transfers
Firms in Vietnam are required to report electronic funds transfers when the transfer value is 500,000,000 VND (US$21,000) or more, or if at least one party in the transaction is outside of Vietnam and the transfer value is US$1,000 or more. The reports must include:
- Financial institution’s business name, address, and account numbers
- Transaction details and purpose
Effective Date
Most clauses outlined in the Circular come into force from July 28, 2023, while regulations on money laundering risk management, reporting of large transactions, and reporting of electronic funds transfers come into effect from December 1, 2023.