Vietnam -- Sanctions Compliance Regulatory Overview

Vietnam implements UN Security Council sanctions via domestic instruments coordinated by the Ministry of Finance and State Bank of Vietnam (SBV), requiring reporting entities like Virtual Asset Service Providers (VASPs) to screen against UN lists, OFAC lists, and Vietnam's national sanctions list; a draft decree on crypto sanctions was released in November 2025 for the pilot crypto market under Resolution No. 05/2025/NQ-CP.[1][3]

OFAC, EU, and UN Sanctions Compliance for VASPs

Vietnam mandates VASPs and reporting entities to screen customers and counterparties against UN consolidated lists and OFAC lists as minimum requirements, with asset freezes for matches reported promptly to the Anti-Money Laundering Department (AMLD).[1] OFAC sanctions apply extraterritorially to non-U.S. entities like Vietnamese VASPs if they process transactions involving U.S. persons, dollars, or the U.S. financial system, or facilitate dealings with sanctioned jurisdictions (e.g., Iran, North Korea, Cuba, Syria, Crimea); violations carry strict liability with examples like Binance's $4.3B penalty in 2023 for sanctions evasion.[2][5][6] EU sanctions primarily bind EU-based operations, while UN sanctions aim for universal enforcement but see variable compliance globally.[4]

Sanctioned Entity Screening Obligations

Entities must screen against:

• UN consolidated lists.
• OFAC SDN List and other programs.
• Vietnam's national sanctions list published by the Ministry of Finance.[1][7]

Screening requires continuous monitoring, blocking sanctioned cryptoassets (e.g., wallets, exchanges), and reporting; records of outcomes must be maintained.[1][5]

Geographic Restrictions

VASPs must avoid transactions with comprehensively sanctioned jurisdictions under OFAC, such as Iran, North Korea, Cuba, Syria, Crimea region of Ukraine, and parts of Donbas, even if wallets are not individually listed; this applies regardless of user location.[2]

Penalties for Violations

Vietnam's Draft Decree (November 2025) imposes administrative sanctions by authorities like provincial People’s Committees, SBV, securities regulators, and public security for crypto violations, including AML and foreign investor fund transfers; it finalizes enforcement for the pilot market potentially in early 2026 per Resolution No. 05/2025/NQ-CP.[3] OFAC enforces globally with civil penalties (e.g., Bittrex $24M in 2022), criminal actions, and blacklisting (e.g., Tornado Cash); non-U.S. VASPs risk secondary sanctions.[2][5][6]

Country-Specific Sanctions Lists

Vietnam maintains its national sanctions list via the Ministry of Finance, alongside mandatory UN and OFAC screening; no unique crypto-specific list is noted beyond the Draft Decree's framework.[1][3]

Legal References (with URLs from sources):

• AML Law 2022 and SBV obligations: https://www.anqacompliance.com/vietnam-detailed-country-aml-information/[1]
• Draft Decree (Nov 2025) under Resolution No. 05/2025/NQ-CP: https://www.tilleke.com/insights/vietnams-draft-crypto-sanctions-decree-enforcement-comes-to-the-pilot-market/[3]
• OFAC SDN Search: https://sanctionssearch.ofac.treas.gov[7]
• OFAC Programs: https://ofac.treasury.gov/sanctions-programs-and-country-information[8]

Note: Information reflects 2025 sources; the Draft Decree may have finalized by 2026, and crypto pilot status could evolve.