Vietnam: 500M VND Digital Transfer Reporting Starts 2025
Vietnam's New Reporting Requirements for Large Electronic Fund Transfers: What You Need to Know
November 1, 2025, marks a significant milestone in Vietnam's financial regulatory landscape with the enforcement of Circular No. 27/2025/TT-NHNN by the State Bank of Vietnam (SBV). This new regulation mandates that electronic fund transfers within Vietnam valued at 500 million VND or more, and international electronic fund transfers of 1,000 USD (or equivalent foreign currency), must be reported to the SBV. This represents a robust step forward in enhancing the nation's anti-money laundering (AML) and counter-terrorist financing (CTF) capabilities.
This article will delve into the key aspects of the new regulation, covering its objectives, scope of application, and specific reporting requirements, to help individuals and organizations ensure compliance.
Important Note: The obligation to report large transactions falls on financial institutions (banks, payment intermediaries), not on individuals performing the transfers.
Purpose and Significance of the Regulation
The issuance of Circular 27/2025/TT-NHNN is not merely an administrative change but carries strategic importance for Vietnam's financial system:
Enhanced Financial Risk Management: It enables the SBV to monitor large money flows more closely, thereby detecting and preventing illegal financial activities in a timely manner, safeguarding system stability.
International Standards Compliance: Vietnam is committed to implementing the recommendations of the Financial Action Task Force (FATF) on AML/CTF. This new regulation helps complete the legal framework, enhancing the country's reputation on the international stage.
Increased Transparency: Fosters a more transparent, sound, and trustworthy financial environment, attracting investment and promoting sustainable economic development.
Data for Screening: Data from these reports will serve as a crucial tool for screening, analyzing, and detecting suspicious transactions, tracking signs related to money laundering and other illicit activities.
Who is Required to Report and What Types of Transactions are Targeted?
Circular 27 clearly defines the reporting entities and scope of application:
Reporting Entities: The responsibility for reporting lies with financial institutions such as commercial banks, foreign bank branches, and payment intermediary service providers in Vietnam.
Types of Transactions Subject to Reporting:
Domestic Electronic Fund Transfers: Transactions valued at 500,000,000 VND or more, or equivalent in foreign currency, where all participating financial institutions are located in Vietnam.
International Electronic Fund Transfers: Transactions valued at 1,000 USD or more, or equivalent in other foreign currencies, where at least one participating financial institution is located outside Vietnam.
Suspicious Transactions: Regardless of value, any transaction exhibiting unusual or suspicious signs related to money laundering or terrorist financing must be reported.
Minimum Reporting Content
Reports must be submitted electronically to the Anti-Money Laundering Department (SBV) and should include the following minimum information:
Information about the Financial Institution: Name, address, bank code (domestic) or SWIFT code (international), originating/beneficiary country.
Information about the Customer (Individual): Full name, date of birth, ID card/Passport/personal identification number, address, nationality.
Information about the Customer (Organization): Full and abbreviated trade name, head office address, establishment license number/business code/tax code, country of head office.
Transaction Information: Account number (if applicable), amount, currency type, amount converted to VND (if foreign currency), reason/purpose of transaction, transaction date, transaction ID.
Other information as required by regulatory authorities.
Exemptions from Reporting (International Transfers)
The regulation also specifies certain international transfer scenarios that are not subject to mandatory reporting:
The beneficiary in an international electronic fund transfer from Vietnam abroad.
The originator in an international electronic fund transfer from abroad to Vietnam.
Transactions using debit cards, credit cards, or prepaid cards for payment.
Implementation Roadmap and Transitional Provisions
Although Circular 27 comes into effect on November 1, 2025, the SBV has provided a clear roadmap for institutions to prepare:
Reporting entities will continue to apply existing internal regulations and risk management procedures until December 31, 2025.
From January 1, 2026, all institutions must complete the adjustment and update of their internal regulations, risk management processes, and especially their software systems to ensure full compliance with the Circular, including the ability to scan and filter transactions against blacklists and warning lists.
Historical Context and Other Related Regulations
The regulation of reporting thresholds for transactions has a long history in Vietnam, continuously adjusted to align with practical realities and international standards:
Decree 74/2005/ND-CP was the first legal document, followed by Decision 20/2007/QD-NHNN setting the threshold at 200 million VND.
The Anti-Money Laundering Law 2012, along with Decree 116/2013/ND-CP and Circular 35/2013/TT-NHNN, raised the threshold to 300 million VND.
More recently, Decision No. 11/2023/QD-TTg raised the large-value transaction reporting threshold to 400 million VND, and Circular 09/2023/TT-NHNN also included provisions for reporting electronic transactions of 500 million VND (domestic) and 1,000 USD (international) effective December 1, 2023. Circular 27/2025/TT-NHNN is the updated and superseding version of these regulations.
Additionally, Circular 27 also specifies requirements for individuals entering or exiting Vietnam to declare precious metals (excluding gold), precious stones valued at 400 million VND or more, or negotiable instruments valued at 400 million VND or more, at border customs. For cash foreign currency, VND cash, and gold, current SBV regulations on carrying these items when entering or exiting the country still apply.
Impact and Outlook
For Financial Institutions: It requires investment in technology, process upgrades, and staff training to meet reporting and risk management requirements. While this may increase operational costs, it will simultaneously enhance the capacity and credibility of the financial system.
For Customers: Individual and corporate customers will need to provide complete and accurate information when conducting large transactions to help financial institutions fulfill their reporting obligations. This regulation is not intended to create difficulties but is part of a collective effort to combat financial crime.
Outlook: With the implementation of Circular 27/2025/TT-NHNN, Vietnam expects to gain a more comprehensive overview of money flows in the economy, enhancing the effectiveness of detecting and investigating money laundering and terrorist financing activities, thereby contributing to building a safer and more transparent financial system.
Disclaimer: The content above reflects the author’s personal views and does not represent any official position of Cobic News. The information provided is for informational purposes only and should not be considered as investment advice from Cobic News