On-shore VASP in Vietnam

Ministry of Finance (MOF) — Lead authority

State Securities Commission (SSC) — Licensing review and compliance monitoring

State Bank of Vietnam (SBV) — Financial oversight

Ministry of Public Security (MPS) — Cybersecurity and financial integrity

The framework mandates VASPs to apply AML/CTF obligations as part of licensing, treating crypto exchanges as market infrastructure akin to securities exchanges. This includes internal policies for AML/CFT, counter-proliferation financing, risk management, and market surveillance.

Oversight involves MOF (lead), SSC (receiving applications), SBV (financial integrity), and MPS (AML, cybersecurity).

Prior to 2026, VASPs were not explicitly regulated under AML laws, but the pilot program (five-year duration) now enforces compliance to prevent illicit flows.

Key reference: Resolution No. 05/2025/NQ-CP (September 9, 2025) establishes the licensing regime with AML/CTF as a core objective; Decision No. 96/QD-BTC details procedures, including AML appraisals.

VASPs must conduct updated KYC for transactions equivalent to at least USD 1,000, verifying customer identities to mitigate fraud, money laundering, and terrorist financing.

Licensing demands detailed internal procedures for KYC, integrated into IT systems with audit trails, alongside personnel qualified in finance and IT.

Foreign investors require a single VND account at a licensed local bank; all transactions use VND.

Systems must achieve Level 4 cybersecurity (highest standard), including encryption, intrusion detection, and continuous monitoring to support CDD.

Proactive adoption of FATF VASP standards is recommended for compliance transition.

VASPs must retain data on Vietnam servers for 10 years, including transaction history, originator/beneficiary details (e.g., wallet addresses), IP/device logs, and account info.

Platforms require programmed AML/KYC processes with anti-tampering logs, secure key management, and transaction monitoring for STR detection.

No explicit STR filing mechanism is detailed in pilot docs, but AML/CTF policies imply reporting via MPS/SBV coordination during licensing appraisals and operations.

Custody and client protection rules reinforce STR through risk controls and complaint handling.

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

Vietnam falls under "Countries That Have Initiated the FATF’s Travel Rule Process", indicating ongoing development of crypto regulations but no finalized Travel Rule legislation or mandates requiring VASPs to comply during transactions.

No specific effective date, threshold amounts (e.g., FATF's recommended $1,000/€1,000), VASPs covered, technical implementation requirements (such as data collection/retention standards or interoperability protocols), or penalties for non-compliance are detailed for Vietnam in available sources.

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).

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.