Stablecoin issuer / redeemer in Vietnam
Issues a fiat-pegged stablecoin to the public, operates redemption, and holds reserves backing the float.
Stablecoin issuer is conditionally permitted in Vietnam with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- VASPs must apply AML/CTF obligations as part of licensing, including internal policies for AML/CFT, counter-proliferation financing, risk management, and market surveillance (fact: vn.licensing.the-framework-mandates-vasps-to)
- VASPs must conduct updated KYC for transactions equivalent to at least USD 1,000 (fact: vn.licensing.vasps-must-conduct-updated-kyc)
- Licensing demands detailed internal procedures for KYC, integrated into IT systems with audit trails (fact: vn.licensing.licensing-demands-detailed-internal-procedures)
- Platforms require programmed AML/KYC processes with anti-tampering logs, secure key management, and transaction monitoring for STR detection (fact: vn.licensing.platforms-require-programmed-amlkyc-processes)
- Systems must achieve Level 4 cybersecurity (highest standard), including encryption, intrusion detection, and continuous monitoring to support CDD (fact: vn.licensing.systems-must-achieve-level-4)
- VASPs must retain data on Vietnam servers for 10 years, including transaction history, originator/beneficiary details, IP/device logs, and account info (fact: vn.licensing.vasps-must-retain-data-on)
- No explicit STR filing mechanism detailed in pilot docs, but AML/CTF policies imply reporting via MPS/SBV coordination (fact: vn.licensing.no-explicit-str-filing-mechanism)
Key Restrictions
- Stablecoin issuance is not explicitly covered by any existing e-money or banking license category; the 2026 pilot framework treats VASPs akin to securities exchanges but does not specifically authorize fiat-pegged stablecoin issuance or define reserve/composition/segregation rules
- Foreign investors require a single VND account at a licensed local bank; all transactions must use VND (fact: vn.licensing.foreign-investors-require-a-single)
- The State Bank of Vietnam (SBV) ensures financial stability and prevents crypto use as payment — stablecoins functioning as payment instruments face SBV opposition (fact: vn.licensing.state-bank-of-vietnam-sbv)
- Data must be retained on Vietnam servers for 10 years (fact: vn.licensing.vasps-must-retain-data-on)
- No specific legal framework exists for reserve composition, segregation, audit, or redemption rights for stablecoin issuers
Key Risks
- No legislation explicitly authorizes stablecoin issuance — the pilot framework covers 'VASPs' broadly and may not encompass the specific act of issuing a fiat-pegged token to the public
- SBV actively prevents crypto use as payment — stablecoins used as means of payment face enforcement risk (fact: vn.licensing.state-bank-of-vietnam-sbv)
- Absence of any rules on reserve segregation, composition, custody, or audit creates significant legal uncertainty for stablecoin reserve management
- No redemption rights framework exists — holders have no statutory redemption guarantee under current law
- Foreign-issued stablecoins (e.g. USDT, USDC) are not affirmatively permitted for local use and may be treated as unauthorized payment instruments
- The regime is in pilot phase (5-year program starting ~2026); framework is evolving and may change
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
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.
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.
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.
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.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- low
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional and highly uncertain — stablecoin issuance is not explicitly covered by Vietnam's 2026 VASP pilot framework; a licensed VASP could potentially operate under the general regime, but no e-money/banking license path, reserve rules, or redemption rights exist, and SBV opposition to crypto as payment creates material legal risk.
Questions this verdict aims to answer
- What e-money or banking license is required to issue?
- What reserve composition, segregation, and audit rules apply?
- What redemption rights must be granted to holders?
- Are foreign-issued stablecoins permitted for use locally?