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Money Laundering Regulations in Vietnam: What Foreign Firms Need to Know

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The State Bank of Vietnam (SBV) has issued Circular 09/2023/TT-NNH guiding the implementation of the Anti-Money Laundering Law. Here’s what foreign firms need to know.

Criteria for Assessing Money Laundering Risks

To assess the risk of money laundering in a transaction, firms should consider several key factors:

  • Business sector and country or territory where the transaction is taking place
  • Type of customer
  • Products or services being provided
  • How those services are being delivered

For example, a cryptocurrency transaction with limited information would likely be higher-risk than a credit card transaction.

Score-Based Methodology for Evaluating Money Laundering Risks

The Circular advocates for a scoring system ranging from one to five to evaluate the money laundering risk associated with a transaction. Firms should also provide training on anti-money laundering (AML) regulations to leaders and employees on an annual basis.

Reporting on Electronic Funds Transfers

Firms in Vietnam are required to report electronic funds transfers when:

  • All parties involved are located within Vietnam
  • The transfer value is 500 million VND (approximately US$21,000)
  • International transactions valued at US$1,000 or more

The reports should include information such as:

  • Financial institution’s business name and address
  • Account numbers
  • Transaction details
  • Any other information requested by the AML authority

When Reporting is Not Required

There are several circumstances in which reporting an electronic funds transfer is not required:

  • Transactions made by debit card, credit card, or prepaid card
  • Transactions involving only financial institutions

Implementation Timeline

Most clauses outlined in the Circular come into force on July 28, 2023. However, regulations on money laundering risk management, large transaction reporting, electronic funds transfer reporting, and suspicious transaction report forms will take effect from December 1, 2023.

For more information on investing in Vietnam or for assistance with AML compliance, please contact Dezan Shira & Associates at vietnam@dezshira.com.