Vietnam: 500M VND Crypto Transfers Report to SBV Nov 2025
New Regulation: Electronic Fund Transfers of VND 500 Million or More Must Be Reported to the State Bank from November 1, 2025
Starting from November 1, 2025, electronic fund transfers with a value of VND 500 million or more in Vietnam will be subject to stricter supervision and reporting requirements under Circular No. 27/2025/TT-NHNN issued by the State Bank of Vietnam (SBV). This is a crucial step to enhance financial transparency, combat money laundering and terrorist financing, and fulfill Vietnam's international commitments.
Legal Basis and Effective Date
Circular No. 27/2025/TT-NHNN, signed and promulgated by the SBV Governor on September 15, 2025, officially takes effect from November 1, 2025. This document inherits and supplements regulations from Circular No. 09/2023/TT-NHNN to address practical issues and meet international integration requirements.
Main Objectives of the New Regulation
This regulation is issued with several important strategic objectives:
• Combating money laundering (AML) and terrorist financing (CFT), and financing the proliferation of weapons of mass destruction.
• Fulfilling Vietnam's international commitments with the Financial Action Task Force on Money Laundering (FATF), especially Action No. 5 of the National Action Plan Appendix.
• Enhancing transparency within the financial and banking system.
• Protecting national financial security by detecting and preventing risks.
• Contributing to strengthening Vietnam's international reputation in financial cooperation.
Circular 27/2025/TT-NHNN marks a significant step forward in Vietnam's efforts to build a more transparent and secure financial system, in line with global standards.
Scope And Applicable Entities
This regulation applies to financial institutions operating in Vietnam. Reporting responsibility falls on:
• Commercial banks.
• Intermediary payment service providers.
• E-wallets.
• Financial exchanges.
It is important to note that the reporting responsibility lies with these financial institutions, not individuals or organizations conducting the transfers. However, individuals and businesses will need to provide more comprehensive information for large-value transactions.
Types Of Transactions Subject To Reporting
Circular 27/2025/TT-NHNN clearly specifies three types of electronic fund transfers for which financial institutions must collect information and report to the Anti-Money Laundering Department using electronic data:
• Domestic electronic fund transfers: Transactions valued at VND 500,000,000 or more (or equivalent foreign currency) where all participating financial institutions are located in Vietnam.
• International electronic fund transfers: Transactions valued at USD 1,000 or more (or equivalent foreign currency) where at least one participating financial institution is located outside Vietnam.
• Suspicious transactions: Any transaction with suspicious indicators, regardless of value.
Minimum Reporting Content
Each report must contain the following basic information:
• Information about the originating and beneficiary financial institutions.
• Detailed information about individual customers (full name, date of birth, ID/Citizen ID card, address, nationality).
• Detailed information about institutional customers (trading name, address, enterprise code, tax code, country).
• Information about the transaction itself (account number, amount, currency type, reason, purpose, transaction date, reference code).
• Providing complete and accurate personal and institutional information is a key factor for complying with this new regulation.
Exemptions From Reporting
Some transaction cases will not be subject to reporting, including:
• Fund transfers resulting from the use of debit, credit, or prepaid cards for goods and services payments.
• Fund transfers and payments between financial institutions where both the originator and beneficiary are financial institutions acting on their own behalf.
Implementation Roadmap and Requirements for Financial Institutions
Circular 27 takes effect from November 1, 2025, but there is a transitional period for reporting entities to prepare:
• Until December 31, 2025: Financial institutions will continue to implement their current internal regulations and risk management procedures.
• From January 1, 2026: Financial institutions must complete the adjustment and update of internal regulations, risk management procedures, and build appropriate information technology systems. This system needs to be capable of electronic data reporting, screening against blacklists, watchlists, politically exposed persons (PEPs) lists, and monitoring transactions for suspicious indicators.
Circular 27 also emphasizes the principle of risk-based management, requiring institutions to periodically assess money laundering risks and establish strict customer identification and verification procedures.
Impact And Significance
• For individuals and businesses: Although not directly responsible for reporting, large financial transactions will require more detailed information. This may affect the transaction experience but simultaneously enhances safety for legitimate users.
• For the financial system: Strengthens the ability to supervise, detect, and prevent money laundering and terrorist financing activities, contributing to building a healthy and sustainable financial environment.
• Compliance with international standards: Helps Vietnam meet FATF requirements, enhancing the nation's position and reputation on the international stage.
Other Related Regulations Effective Concurrently
Along with Circular 27/2025/TT-NHNN, November 2025 will also see several other new policies come into effect, further strengthening the legal framework for financial activities:
• Circular 30/2025/TT-NHNN (effective from November 18, 2025) amends personal identification documents required for cashless payment services.
• Circular 33/2025/TT-NHNN (effective from November 15, 2025) regulates the classification, packaging, and delivery of precious metals and gemstones, allowing credit institutions to receive gold bars from customers.
These regulations demonstrate the State Bank's overall effort to complete the legal framework, ensuring safety and transparency for Vietnam's financial market amidst integration and the rapid development of electronic payment methods.
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