--- title: "Vietnam (VN) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/vietnam/ source_html: /jurisdictions/vietnam/index.html description: "Financial integrity intelligence for Vietnam (VN): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 9f4f15620afe1b0749046804a274a00d02b04c86721ea4df32410efff20eac3e generator: "fe-fleet/md-twin@1.0" --- # Vietnam (VN) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Vietnam VN Domains covered 8 of 8 Sources 155 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Grey-List Tier: B Risk direction: Stable Enablement vs enforcement: Mixed AML Law 2022 (effective March 2023) replaced the 2012 law; implementing Decree 19/2023 sets CDD/STR thresholds. More State Bank of Vietnam's AML Division supervises FIs; DNFBP/TCSP supervision remains undesignated. Virtual assets were unregulated until a September 2025 five-year VND-only trading pilot. Vietnam has been under FATF increased monitoring since June 2023, with 16 Recommendations rated C/LC, 21 PC and 3 NC, and action-plan deadlines that expired May 2025. Key deficiencies - Beneficial ownership transparency for legal persons (R.24) remains Partially Compliant - NPO/TF risk-based supervision and targeted financial sanctions frameworks (R.29) remain Partially Compliant - No designated AML supervisor for TCSPs under Decree 19/2023 - Negligible risk-based supervision of DNFBPs (real estate, casinos, virtual asset service providers) - Long porous land borders with China, Laos and Cambodia enabling currency, gold and goods smuggling Recent developments (18m) - FATF follow-up reports (Feb 2025, Jun 2025, Oct 2025, Feb 2026, Jun 2026) record only limited progress; all action-plan deadlines expired May 2025 - Truong My Lan/Van Thinh Phat appeal reduced life sentence to 30 years (April 2025); asset-recovery rulings on luxury assets continued into January 2026 - Revised Law on Credit Institutions passed June 2025 strengthening SBV bank-resolution powers - Five-year VND-denominated crypto asset trading pilot approved September 2025 - Gold market reform (September 2025) aimed at curbing smuggling and stabilising the dong - PM-ordered task force (May 2025) to combat trade fraud, transhipment and counterfeit-goods exports amid US tariff negotiations Brief ## Lead signal #### Lead Signal Vietnam was retained on the Financial Action Task Force increased-monitoring list at the plenary held 30 October 2026, with the body expressing significant concern over the pace of progress against its action plan. All of Vietnam's agreed deadlines under that plan expired in May 2025, so the retention is read against a long run of unmet commitments rather than a fresh deficiency. The language used this round is understood to be sharper than in prior cycles, though Vietnam was not escalated to the call-for-action list, meaning the designation remains in the increased-monitoring band rather than moving toward comprehensive restriction. The structural reading is that supervisory effectiveness and beneficial-ownership transparency remain the standing cited gaps, and the October statement signals patience wearing thin rather than a change in category. Read full brief #### Lead Signal Vietnam was retained on the Financial Action Task Force increased-monitoring list at the plenary held 30 October 2026, with the body expressing significant concern over the pace of progress against its action plan. All of Vietnam's agreed deadlines under that plan expired in May 2025, so the retention is read against a long run of unmet commitments rather than a fresh deficiency. The language used this round is understood to be sharper than in prior cycles, though Vietnam was not escalated to the call-for-action list, meaning the designation remains in the increased-monitoring band rather than moving toward comprehensive restriction. The structural reading is that supervisory effectiveness and beneficial-ownership transparency remain the standing cited gaps, and the October statement signals patience wearing thin rather than a change in category. Secondary commentary on the same plenary statement draws a line between the open action-plan items and virtual-asset regulation, and flags a potential overlap with Vietnam's own unlicensed crypto-exchange pilot under Resolution 05/2025. This connection is carried at a lower confidence than the core grey-list finding, since it rests on a single commentary source rather than the Task Force's own statement text, but it is consistent with the broader pattern of countries on the list facing scrutiny over nascent virtual-asset oversight alongside legacy anti-money-laundering gaps. #### Other Developments Virtual-asset oversight gap persists alongside pilot scheme. The unlicensed status of the Resolution 05/2025 crypto-exchange pilot continues without resolution, and the secondary reporting on the October plenary statement ties this specifically to one of Vietnam's outstanding action-plan items. No independent corroboration against the Task Force's own statement text was available this cycle, so the link between the pilot and the grey-list item is carried as an open question rather than a settled finding. #### Cross-Monitor Connections The virtual-asset dimension of this cycle's finding sits at the boundary between standing anti-money-laundering supervision and the digital-asset oversight questions tracked separately for crypto-sector developments; readers following that separate thread should treat the Resolution 05/2025 licensing gap as a shared reference point. No conflict-finance, state-capture, or commodity-flow connection was present in the material reviewed this cycle. #### Outlook With all Vietnam's action-plan deadlines having expired as long ago as May 2025, the near-term question is whether the sharpened concern voiced at the October 2026 plenary translates into a call-for-action designation at a subsequent plenary if visible progress does not materialise, or whether incremental steps are judged sufficient to avoid escalation. The unresolved status of the Resolution 05/2025 pilot is a specific marker worth tracking: formal licensing action, or continued absence of it, would bear on how the virtual-asset strand of the action plan is read going into the next review cycle. Primary confirmation of the plenary statement's text, rather than secondary summaries, would sharpen confidence in both the core grey-list finding and the virtual-asset linkage. Earlier periodic briefs (7) 4 Nov 2026 · fim-2026-11-04 #### Lead Signal Vietnam was retained on the Financial Action Task Force increased-monitoring list at the plenary held 30 October 2026, with the body expressing significant concern over the pace of progress against its action plan. All of Vietnam's agreed deadlines under that plan expired in May 2025, so the retention is read against a long run of unmet commitments rather than a fresh deficiency. The language used this round is understood to be sharper than in prior cycles, though Vietnam was not escalated to the call-for-action list, meaning the designation remains in the increased-monitoring band rather than moving toward comprehensive restriction. The structural reading is that supervisory effectiveness and beneficial-ownership transparency remain the standing cited gaps, and the October statement signals patience wearing thin rather than a change in category. Secondary commentary on the same plenary statement draws a line between the open action-plan items and virtual-asset regulation, and flags a potential overlap with Vietnam's own unlicensed crypto-exchange pilot under Resolution 05/2025. This connection is carried at a lower confidence than the core grey-list finding, since it rests on a single commentary source rather than the Task Force's own statement text, but it is consistent with the broader pattern of countries on the list facing scrutiny over nascent virtual-asset oversight alongside legacy anti-money-laundering gaps. #### Other Developments Virtual-asset oversight gap persists alongside pilot scheme. The unlicensed status of the Resolution 05/2025 crypto-exchange pilot continues without resolution, and the secondary reporting on the October plenary statement ties this specifically to one of Vietnam's outstanding action-plan items. No independent corroboration against the Task Force's own statement text was available, so the link between the pilot and the grey-list item is carried as an open question rather than a settled finding. #### Cross-Monitor Connections The virtual-asset dimension of the finding sits at the boundary between standing anti-money-laundering supervision and the digital-asset oversight questions tracked separately for crypto-sector developments; readers following that separate thread should treat the Resolution 05/2025 licensing gap as a shared reference point. No conflict-finance, state-capture, or commodity-flow connection was present in the material reviewed. #### Outlook With all Vietnam's action-plan deadlines having expired as long ago as May 2025, the near-term question is whether the sharpened concern voiced at the October 2026 plenary translates into a call-for-action designation at a subsequent plenary if visible progress does not materialise, or whether incremental steps are judged sufficient to avoid escalation. The unresolved status of the Resolution 05/2025 pilot is a specific marker worth tracking: formal licensing action, or continued absence of it, would bear on how the virtual-asset strand of the action plan is read going into the next review cycle. Primary confirmation of the plenary statement's text, rather than secondary summaries, would sharpen confidence in both the core grey-list finding and the virtual-asset linkage. 3 Nov 2026 · fim-2026-11-01 #### Lead Signal Vietnam was retained on the Financial Action Task Force grey list at the plenary held on 30 October 2026, with the task force recording significant concern over the pace of progress against an action plan whose deadlines expired in May 2025. The sharpened tone matters more than the retention itself: a jurisdiction that has already missed every deadline in its own remediation plan, and is now told explicitly that progress is too slow, has moved from a monitoring posture to one where the next review is likely to test patience rather than process. Under current designation conventions, this standing sits as increased monitoring rather than a call for countermeasures, and it is not a comprehensive or sectoral sanctions measure; it is a graduated supervisory signal, but one whose grading has just moved in the wrong direction. The available reporting for this finding traces to secondary compliance-news summarisation of the plenary outcome rather than to the task force's own statement text, which was not independently retrieved. The finding is accordingly carried at a probable rather than confirmed standing, and the pinpoint citation to the task force's own published statement remains outstanding. #### Other Developments No further architecture-level findings reached the bar. Sanctions exposure, beneficial-ownership transparency, enabler-jurisdiction dynamics, conflict-finance indicators, compliance-technology posture, and commercial-activity findings specific to Vietnam were not substantiated to a standard warranting prose; their standing prior assessments are unchanged and are not repeated here. #### Cross-Monitor Connections The grey-list posture intersects with Vietnam's unresolved framework for licensing virtual-asset service activity, a connection drawn by secondary commentary rather than confirmed against the task force's own text. Where an AML/CTF regime finding of this kind touches an unlicensed digital-asset pilot, the overlap is best read as a reminder that grey-list remediation items rarely sit inside a single typology lane: a deficiency logged against the regime pillar can simultaneously constitute an open action item against virtual-asset regulation specifically. No independent corroboration of that linkage was available beyond the single commentary source carrying it. #### Outlook With deadlines already lapsed since May 2025 and the task force's language hardening rather than softening at the October 2026 plenary, the material question going into the next review cycle is whether Vietnam produces visible legislative or supervisory movement before the task force's typical semi-annual cadence brings the file back for reassessment. Absent that movement, the grey-list standing is likely to persist, and the tone of the task force's commentary gives no indication that patience is being extended. This is read as a structural signal about the trajectory of a remediation process, not as a prediction of removal or escalation timing. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Vietnam's National Assembly passed Law 23/2026/QH16 on 24 August 2026 with 94.6% approval, amending the Law on the State Bank of Vietnam, the Law on Anti-Money Laundering and the Law on Credit Institutions, with the amendments taking effect 1 December 2026. The most structurally significant feature is the extension of AML reporting-entity status to virtual-asset and crypto-asset service providers for the first time, bringing customer due diligence, transaction monitoring and suspicious-transaction-reporting obligations to a sector that previously operated without a formal AML programme requirement. The same statute strengthens beneficial-ownership identification duties, extending coverage to indirect ownership and legal arrangements and introducing new transparency and recordkeeping duties, though no standalone public beneficial-ownership register has been identified. A companion statute, Law 13/2026/QH16 on the prevention and combat of financing of the proliferation of weapons of mass destruction, was enacted alongside it, rounding out Vietnam's AML/CFT/CPF statutory architecture ahead of the FATF review cycle. #### Other Developments Grey-list status unchanged. Vietnam remains under FATF increased monitoring per the 19 June 2026 statement, which cites continuing strategic deficiencies including the need to increase risk understanding; no October 2026 plenary update specific to Vietnam has been located, leaving the grey-list trajectory unconfirmed beyond the June position. Crypto-exchange pilot remains pre-launch. Under the Resolution 05/2025/NQ-CP pilot framework, no final operating licence has been issued to any crypto-asset exchange as of 21 October 2026; five applicants have passed only an initial document-completeness review. This means the new AML reporting-entity obligations under Law 23/2026/QH16 will attach to a licensed-VASP population that does not yet exist in practice, creating a lag between statutory obligation and supervised population. Standing AML/CTF regime of record. The 2022 AML Law, as now amended by Law 23/2026/QH16, remains the regime of record, supervised by the State Bank of Vietnam's AML Department acting as the financial intelligence unit. #### Cross-Monitor Connections The extension of AML reporting-entity status to virtual-asset service providers is a digital-asset-market-structure development as much as a financial-crime one: the same Law 23/2026/QH16 provision that creates new compliance obligations for crypto platforms also defines the perimeter within which Vietnam's crypto-exchange pilot licensing regime will eventually have to operate once licences are actually issued. The beneficial-ownership strengthening in the same statute is read here for its illicit-finance significance, namely closing gaps around indirect ownership and legal arrangements, rather than for any corporate-transparency-compliance burden on ordinary firms, which is a different lens entirely. The proliferation-financing statute enacted alongside the AML amendments connects to sanctions-architecture monitoring generally, since CPF obligations typically track the same screening infrastructure used for sanctions compliance, though no Vietnam-specific sanctions-list development was identified. #### Outlook The near-term marker is 1 December 2026, when Law 23/2026/QH16's amendments take effect and virtual-asset service providers formally become AML reporting entities. Whether that obligation has practical teeth will depend on how quickly the Resolution 05 pilot moves applicants past the document-completeness stage to an actual licence; until a licence issues, the reporting-entity obligation applies to a population that is not yet operating under supervision. The absence of a confirmed October 2026 FATF plenary outcome for Vietnam leaves open whether the new statutory package registers as material progress toward exiting increased monitoring, or whether FATF's assessment of practical implementation lags the legislative text, as the June 2026 statement's reference to risk-understanding deficiencies suggests examiners are already alert to. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Vietnam's beneficial-ownership regime underwent a structural overhaul this period. Decree 296/2026/ND-CP and Resolution 66.23/2026/NQ-CP, both active from late July 2026, replace a looser identification standard with a three-tier test built around a 25% ownership threshold, family and contractual-group aggregation, and an indirect-ownership look-through. The amended CDD and BO-verification provisions are framed as an alignment step with international tax-information-exchange commitments, which reads as structural rather than incident-driven: Vietnam is rebuilding the plumbing that lets a regulator see through a corporate structure, not responding to a single case. No primary gazette text was reached this cycle, which caps confidence at probable rather than confirmed, but two independent professional-services sources corroborate the mechanics. Alongside the BO reform, Vietnam's crypto-asset pilot remains in an unusual holding pattern. Thirteen months after the enabling resolution took effect, five applicants have cleared initial Ministry of Finance review, yet none has received a final exchange licence. Decree 284/2026/ND-CP, effective 1 September 2026, now backs that gap with a penalty regime: fines of VND180-200 million for operating or advertising an unlicensed exchange. The combination is analytically interesting precisely because enforcement capacity has arrived before the licensing gate has opened — a permissive-by-delay posture with a punitive floor underneath it. #### Other Developments A bank-and-broker capital race ahead of the licensing gate. Vietnam's crypto exchange sector saw a wave of commercial positioning this period as firms raced to meet the VND10 trillion pilot capital threshold. OKX Ventures and HashKey Capital agreed to invest in the VPBank-ecosystem exchange CAEX, announced in April 2026, while South Korea's Bithumb signed a memorandum of understanding with SSI Digital in May 2026 to explore a licensed exchange. Neither deal has disclosed financial terms. The pattern — international crypto-native capital partnering with incumbent Vietnamese banks and securities houses — suggests market participants are pre-positioning capital structures against a licensing outcome that has not yet arrived, which is itself a signal about expected sequencing. The standing AML/CTF architecture remains the backdrop. Vietnam's Law on Anti-Money Laundering No. 14/2022/QH15 continues to designate financial institutions, payment-intermediary providers and a defined set of DNFBPs — including prize-winning video games, casino, lottery and betting operators — as reporting entities, with a VND400,000,000 reporting threshold and suspicious-transaction-report deadlines of three working days from a transaction or one working day from detection. This regime of record is unchanged this cycle but sits underneath both the BO reform and the crypto licensing question as the enforcement backbone either development would eventually run through. FATF grey-list status persists pending the next Plenary. Vietnam remains on FATF's list of Jurisdictions under Increased Monitoring per the 19 June 2026 Plenary; the October 2026 Plenary outcome had not been published as of this cycle. No sanctions, enabler-jurisdiction, or conflict-finance signal specific to Vietnam was identified this period, and compliance-technology developments were similarly absent from the researched window. #### Cross-Monitor Connections The crypto-exchange capital wave and the BO-identification reform intersect directly with crypto and world-payments monitoring: the same CAEX and SSI Digital transactions appear in the crypto monitor's commercial-activity tracking, and the underlying licensing gate is the same Resolution 05/2025/NQ-CP architecture the crypto monitor tracks independently. The beneficial-ownership reform's aggregation and indirect-ownership tests are directly relevant to any onward crypto or payments-sector ownership screening, since a 25% threshold with family and contractual aggregation changes what counts as a reportable controlling interest for firms in either sector. Vietnam's FATF grey-list status is a standing constraint that touches correspondent-banking and cross-border-payments access considerations tracked elsewhere in the fleet, though no new designation or corridor-specific finding emerged this cycle to connect them concretely. #### Outlook The near-term marker to watch is the October 2026 FATF Plenary outcome on Vietnam's action plan, which was not yet published as of this cycle and will determine whether grey-list status is maintained, intensified, or eased. On the crypto side, the question is whether any of the five reviewed applicants converts initial Ministry of Finance clearance into an actual licence; until one does, the penalty regime under Decree 284/2026/ND-CP functions as a backstop against informal market activity rather than evidence of a functioning licensing market. On beneficial ownership, the absence of primary gazette text for Decree 296/2026/ND-CP and Resolution 66.23/2026/NQ-CP is a sourcing gap worth closing before the reform's practical bite — particularly around aggregation mechanics — can be assessed with confidence above probable. 29 Sep 2026 · fim-2026-09-28 #### Lead Signal Vietnam advanced substantive beneficial-ownership and anti-money-laundering reforms this cycle even as it remains on FATF's list of jurisdictions under increased monitoring, with all action-plan deadlines having expired in May 2025. Decree No. 296/2026/ND-CP, effective 23 July 2026, introduces a mandatory three-tier cascading beneficial-ownership look-through test that replaces the prior discretionary 'if any' declaration approach, tracing corporate ownership to the ultimate natural person and recognising control as an independent basis for beneficial-ownership status. The reform directly targets one of the structural deficiencies that has kept Vietnam under FATF's increased-monitoring regime, but formal removal from that list requires an on-site FATF assessment, and the reform alone does not resolve the expired action-plan timeline. #### Other Developments Reporting thresholds tightened in parallel with the ownership reforms. SBV Circular No. 27/2025/TT-NHNN, effective 1 November 2025, requires domestic transfers of VND 500 million (approximately US$19,000) or more, and cross-border transactions of US$1,000 or more, to be reported to the State Bank of Vietnam's AML Department, replacing the prior Circular 09/2023 threshold regime. A companion penalty-raising decree reinforces the new BO regime. Decree No. 288/2026/ND-CP raises non-compliance penalties in parallel with Decree 296's look-through test, while Resolution 66.23/2026/NQ-CP, issued 24 July 2026, amends the 2022 AML Law's beneficial-ownership and customer-due-diligence provisions, expanding required beneficial-ownership information and clarifying risk classification and legal-arrangement disclosure duties for reporting entities. Cross-border scam displacement is compounding Vietnam's domestic illicit-finance exposure independent of its own regulatory posture. Reporting indicates a possible overflow of Vietnamese- and Chinese-run scam and laundering operations from Cambodia into Vietnam's border provinces, coinciding with Cambodia's own intensified crackdown on scam compounds. In a documented domestic case, three individuals were arrested for laundering approximately US$1.8 million in proceeds from an online-lottery-fraud scheme, cycling funds through Vietnamese bank accounts before converting the proceeds into the cryptocurrency USDT -- a confirmed instance of digital-asset layering appearing in a domestic laundering prosecution rather than a purely theoretical exposure. #### Cross-Monitor Connections The USDT-layering mechanic documented in Vietnam's domestic lottery-fraud case connects directly to the crypto monitor's tracking of Vietnam's parallel move to a licensed crypto-trading pilot framework, where AML and Travel Rule controls are now a formal condition of platform licensing under Resolution 05/2025/NQ-CP; whether the newly-licensed platforms, once operational, close off the informal USDT-conversion channel observed in this case is a question that sits at the seam between the two regimes. The tightened SBV reporting thresholds under Circular 27 also intersect with world-payments' coverage of Vietnam's e-wallet and payment-services tightening this cycle, where biometric verification and single-trade-name rules under Circular 41/2025/TT-NHNN reflect the same broader SBV push toward consolidated financial-sector oversight. #### Outlook The substantive reforms this cycle -- Decree 296's BO look-through test, Decree 288's penalty increases, Resolution 66.23's AML Law amendments, and Circular 27's reporting-threshold tightening -- collectively address several of the deficiencies FATF has flagged, but the action-plan deadlines remain expired and formal grey-list removal requires an on-site assessment that has not yet been scheduled or reported. Separately, whether Cambodia's scam-compound crackdown continues to displace illicit-finance activity into Vietnam's border provinces, and whether that displacement generates further confirmed cases of crypto-layering in domestic laundering prosecutions, are the two developments most likely to shape Vietnam's risk trajectory over the coming reporting periods. 22 Sep 2026 · fim-2026-08-21 #### Lead Signal Vietnam's standing anti-money-laundering instrument stack was refreshed this cycle at the implementing-instrument level, even as the underlying assessment of the country's 2023 FATF action plan remains unchanged. SBV Circular 27/2025/TT-NHNN, effective 1 November 2025, replaced Circular 09/2023/TT-NHNN as the operative AML Law implementing guidance, reaffirming targeted-financial-sanctions screening expectations and designated-non-financial-business-and-profession scope covering lawyers, accountants, property agents and precious-metal dealers. Decree 340/2025/ND-CP, effective 9 February 2026, separately replaced Decree 88/2019/ND-CP as the administrative-sanctions instrument for currency and banking violations. A third, explicitly temporary instrument, Resolution 66.23/2026/NQ-CP, effective 24 July 2026, patches urgent beneficial-ownership, customer-due-diligence and legal-arrangement gaps in the 2022 AML Law pending a fuller legislative revision, and is due to sunset on 28 February 2027 or upon adoption of permanent amendments, whichever comes first. This is an architecture story rather than an incident story: Vietnam is rebuilding its implementing layer at high tempo. Set against that tempo, the FATF's June 2026 plenary statement continues to describe only "limited progress" against the 2023 action plan, with all original deadlines having expired in May 2025, leaving Vietnam on the grey list. The juxtaposition is analytically significant in its own right: rapid domestic rule-tightening is not, on the FATF's own assessment, yet translating into the substantive progress that would support removal from increased monitoring. #### Other Developments Beneficial ownership moved from declaratory to mandatory. Decree 296/2026/ND-CP, effective 23 July 2026, replaces the prior "if any" declaratory approach to beneficial-ownership identification with a mandatory three-tier cascading test, direct or indirect ownership of 25 percent or more, followed by a control-rights test, and introduces a new family-aggregation rule. This finding rests on corroboration across four or more independent Tier-3 legal-commentary sources, though no Tier-1 gazette text was retrieved directly this cycle. A related but only single-sourced development, Decree 288/2026/ND-CP, issued 21 July 2026, is reported to significantly raise administrative penalties for failing to declare, update, maintain or provide beneficial-ownership information, a shift read as moving enforcement emphasis from formal registration toward substantive compliance, particularly for foreign-direct-investment and multi-layer-ownership enterprises; this claim is treated as possible pending corroboration. Vietnam's crypto-asset pilot became operational. Ministry of Finance Decision No. 96/QD-BTC formally launched licensing for crypto-asset trading platforms under Resolution 05/2025/NQ-CP's five-year pilot, a step responsive to the FATF's outstanding action-plan item on regulating virtual assets and virtual-asset service providers, though that item remains listed as outstanding as of the June 2026 plenary. The regional backdrop against which this sits is stark: FATF's July 2026 targeted virtual-asset update named a single Cambodia-based financial-services conglomerate as having laundered at least USD 4 billion in illicit proceeds between 2021 and 2025, serving both organised-crime-linked fraud schemes and DPRK-related cyber theft through shared casino- and scam-centre-linked infrastructure. Lao PDR's action-plan deficiencies, including weak risk-based supervision of casinos, banks and reporting entities in Special Economic Zones, were separately reaffirmed at the same June 2026 plenary. Read together, the three findings describe a regional pattern in which Vietnam's own domestic tightening exists alongside continuing large-scale enablement next door. #### Cross-Monitor Connections The Cambodia-based conglomerate finding sits at the intersection of casino and scam-centre infrastructure, organised-crime fraud typologies, and DPRK-linked cyber-theft laundering, a combination that is architecturally relevant to how adjacent monitors track state-linked illicit finance and information-operations-adjacent obscuration of flows; that overlap is noted here rather than re-analysed, consistent with the architecture-over-incident framing this monitor applies throughout. Vietnam's own instrument-stack refresh and its APG-evaluation preparation are primarily a domestic AML/CTF architecture story rather than a cross-border enablement story, and are tracked here rather than routed elsewhere this cycle. The absence, this cycle, of a VN-specific sanctions-evasion or conflict-finance signal is itself worth noting rather than passing over silently: it reflects a research-budget prioritisation toward the VN-bound dispatch rather than a substantive finding that Vietnam carries no exposure on those pillars. #### Outlook Decision 707/QD-TTg's 2026-2030 national action plan is explicitly framed as preparation for the APG's third mutual evaluation of Vietnam, expected in 2027, and the temporary Resolution 66.23/2026/NQ-CP is due to sunset by 28 February 2027 or upon adoption of permanent AML Law amendments. The trajectory to watch is whether Vietnam's high-tempo domestic rule-tightening translates into a FATF assessment upgrade beyond "limited progress" before the next plenary cycle, and whether the crypto-asset pilot's VASP licensing regime is judged sufficient to close the FATF's outstanding action-plan item on virtual assets. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal Vietnam's parallel build-out of domestic anti-money-laundering architecture has not yet moved the needle on its FATF status. The Plenary held 19 June 2026 reaffirmed Vietnam's place on the increased-monitoring list, with all action-plan deadlines having expired since May 2025. This persistence sits against a backdrop of visible domestic activity: Vietnam's Ministry of Public Security charged and detained seven individuals connected to the ONUS platform for property appropriation via electronic means and money laundering tied to a fabricated-token scheme sold since 2018, whose parent, Vemanti Group, is listed on the US over-the-counter market. Separately, Decision 707/QD-TTg, a national action plan for anti-money-laundering, counter-terrorist-financing and counter-proliferation-financing covering 2026 through 2030, was signed ahead of the Asia/Pacific Group's third mutual evaluation of Vietnam, and Decree 284/2026/ND-CP introduces Vietnam's first administrative penalties, up to 50 million Vietnamese dong, for unlicensed domestic crypto trading, effective 1 September 2026. The gap between domestic regulatory density and FATF's continued grey-list assessment is this cycle's most structurally significant signal: build-out alone has not yet been sufficient for delisting. #### Other Developments Cambodia is visibly racing to avert a third FATF grey-listing. National Bank of Cambodia Governor Chea Serey warned publicly of this risk, and a coordinated crackdown was launched against illegal online casinos and scam rings across several provinces. Laos's Golden Triangle Special Economic Zone remains an entrenched, unresolved laundering enclave. The zone, leased for ninety-nine years to Kings Romans Group, whose principal Zhao Wei was designated by OFAC in 2018, continues to operate largely outside standard Lao jurisdiction, with no new enforcement action changing that trajectory this cycle. Sanctions architecture escalated on two fronts. The US Financial Crimes Enforcement Network issued a supplemental alert on fiscal fuel-smuggling and tax-evasion schemes alongside an Office of Foreign Assets Control sanctions action against two Mexican nationals and nine entities linked to the Cartel de Jalisco Nueva Generacion. A separate, lower-confidence report describes escalating measures against Mexican casinos and financial institutions as trade-based money-laundering placement vehicles, sourced only to a single Tier 4 outlet and not independently corroborated this cycle. Colombia received an unprecedented designation. The FY2026 Foreign Relations Authorization Act determination named Colombia among five countries that failed demonstrably to meet counternarcotics obligations, the first such finding for Colombia in nearly thirty years, citing record coca cultivation; sanctions were waived on national-interest grounds. The EU's Anti-Money Laundering Authority completed a structurally significant transition. AMLA officially took over all AML/CFT mandates from the European Banking Authority on 1 January 2026 and launched a reporting package to identify provisionally eligible obliged entities ahead of its first direct-supervision selection cycle, with a provisional list expected by the end of September 2026 and direct supervision beginning January 2028. #### Cross-Monitor Connections Vietnam's crypto-enforcement and licensing build-out this cycle — the ONUS prosecution and Decree 284/2026's penalty regime — intersects directly with payments-market-infrastructure developments tracked elsewhere, since the same instrument set that penalises unlicensed trading is simultaneously part of Vietnam's first regulated digital-asset on-ramp build-out. The Cambodia-Laos enabler-jurisdiction picture connects to conflict-finance and gambling-sector monitoring: the scam-compound and illegal-casino ecosystem straddling the Cambodia-Vietnam border is a structural driver also referenced in gambling-regulatory tracking of Vietnam's own cross-border enforcement posture this cycle. Colombia's FRAA designation and record coca cultivation connect to conflict-finance and extractive-industry-integrity monitoring of narco-trafficking-linked financial flows in the wider Andean region. This is a cross-monitor observation only; illicit-finance use of any payments rail is a financial-integrity finding, not a conclusion for other monitors to draw independently. #### Outlook Watch for whether Cambodia's enforcement rhetoric translates into structural reform sufficient to avert a third grey-listing, or whether it remains a single enforcement sweep; the two outcomes carry materially different implications for regional enabler-jurisdiction risk. Watch Vietnam's next FATF assessment for whether the parallel build-out — Decision 707/QD-TTg, the ONUS prosecution, and Decree 284/2026 — begins to register against the currently expired action-plan deadlines. On the EU side, AMLA's provisional list of directly-supervised entities is due by the end of September 2026, with national-supervisor data due 15 August 2026, and will be the first concrete marker of how the hybrid EU-level supervisory perimeter is drawn. Each of these threads reflects the same underlying tension this cycle: regulatory and enforcement architecture is visibly being built out across Vietnam, Cambodia, Mexico, Colombia and the EU, while assessed risk status in several of these jurisdictions has not yet moved in step with that build-out. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Viewed through a sanctions-architecture lens, the most consequential Vietnam-related finding this cycle is not any single enforcement action but the sheer duration of the presence of Vietnam on the Financial Action Task Force Increased Monitoring list. Vietnam has been continuously listed since 23 June 2023 and was reconfirmed at the June 2026 plenary, even though the action-plan deadlines originally attached to that listing expired in May 2025. The plenary statement escalated its urging language without indicating either delisting or an escalation path toward the black list, which under the architecture-over-incident principle reads as evidence of a stalled remediation process rather than an acute new deficiency. Three years of monitoring without resolution is itself the signal: it points toward institutional capacity constraints inside the supervisory apparatus of Vietnam rather than toward a single unaddressed case. Continue reading That domestic stall interacts with a genuinely jurisdiction-agnostic finding about how downstream sanctions-adjacent regimes respond to Financial Action Task Force list status. Following its post-2024 Money Laundering Regulations reform, the United Kingdom now ties high-risk third-country status automatically to the live Financial Action Task Force grey and black lists under Regulation 33. The continued grey-listing of Vietnam therefore keeps it classified as a UK high-risk third country requiring enhanced due diligence, with further amendment regulations laid before Parliament in March 2026 to keep the schedule current. The European Union reaches the same substantive destination by a structurally slower route: the European Commission adopted Delegated Regulations (EU) 2026/46 and (EU) 2026/83 in December 2025, updating its own high-risk third-country list following the Financial Action Task Force June and October 2025 plenaries and reaffirming the continued listing of Vietnam, while Bolivia and the British Virgin Islands were added and six African states were delisted. The one-to-two-quarter lag built into the European Union delegated-act and non-objection process, compared with the automatic United Kingdom linkage, reads as a durable regime-design divergence rather than a one-off administrative delay, and it is precisely the kind of structural finding a sanctions-architecture assessment is designed to surface. A third and more acute divergence signal emerged from enforcement rather than listing mechanics. The October 2025 coordinated action by the Office of Foreign Assets Control and the Office of Financial Sanctions Implementation against the Cambodia-based Prince Group transnational criminal organisation and its associated Huione payment infrastructure designated 146 linked targets, named Huione a primary money-laundering concern and forfeited more than fifteen billion dollars in bitcoin, while the Office of Financial Sanctions Implementation separately sanctioned Byex Exchange; the two regimes produced non-identical target lists despite the nominally coordinated framing. Applying a three-level reading, the scheme is stablecoin-based scam-laundering infrastructure with a documented Vietnamese nexus among trafficked operators and victims; the architecture is the combination of Huione payment rails, regional exchange cash-out points and a Cambodia-based criminal organisation; and the strategic consequence is a live demonstration that even closely coordinated multilateral sanctions actions can produce fragmented designation scopes, leaving compliance functions to reconcile two overlapping but non-identical lists rather than a single harmonised one. The counter-terrorist-financing pillar rounds out the sanctions-architecture picture and is often under-weighted relative to anti-money-laundering findings generated by higher enforcement volume. Recommendation 29, covering risk-based non-profit-organisation supervision and targeted financial sanctions implementation for terrorist and proliferation financing, remains rated Partially Compliant for Vietnam through the 2025 to 2026 follow-up cycle. Current assessed terrorist-financing risk for Vietnam is low, but an underdeveloped targeted-financial-sanctions implementation mechanism is a structural early-warning gap rather than a present emergency, and it sits in the same institutional-capacity category as the anti-money-laundering findings above rather than in a separate risk universe. #### Outlook The next scheduled test of this architecture is the October 2026 Financial Action Task Force plenary, which will assess whether progress by Vietnam on beneficial-ownership transparency, virtual asset service provider regulation and targeted financial sanctions frameworks warrants delisting consideration or continued and intensified monitoring. No jurisdiction-specific firm instruction is implied by the review process itself, and general industry posture of continued enhanced due diligence toward Vietnam should be expected to persist regardless of the plenary outcome given the separate United Kingdom and European Union listing mechanisms already in place. The structural divergence between the automatic United Kingdom mechanism and the lagged European Union delegated-act process is assessed, at High confidence, as a durable feature of the sanctions landscape rather than a temporary artefact, and the Prince Group and Huione designation-scope divergence is likely to recur in future coordinated actions unless the underlying list-reconciliation processes between the two regimes are formally aligned, an outcome not indicated by any evidence available this cycle. Judgment: No VN-specific sanctions development this cycle. Probable #### Beneficial Ownership and Corporate Transparency Vietnam's beneficial-ownership picture sits entirely outside the EU AML Package perimeter, so the relevant development here is domestic: Law 23/2026/QH16, passed by the National Assembly on 24 August 2026 with 94.6% approval and taking effect 1 December 2026, strengthens beneficial-ownership identification duties, extending coverage to indirect ownership and legal arrangements and introducing new transparency and recordkeeping duties. No standalone public beneficial-ownership register for Vietnam has been identified in connection with this amendment; the strengthening sits within the AML statute's customer due-diligence and recordkeeping framework rather than in a separate disclosure register. The standing AML/CTF regime of record, the 2022 AML Law as now amended, is supervised by the State Bank of Vietnam's AML Department, acting as the national financial intelligence unit, which is the body that will receive and act on the enhanced beneficial-ownership identification data once the amendment takes effect. Continue reading Globally, the EU AML Package sets the structural direction for beneficial-ownership regulation: the AML Regulation (Reg (EU) 2024/1624) is directly applicable across the bloc, the sixth AML Directive is transposed per Member State, and the AMLA Regulation (Reg (EU) 2024/1620) establishes the Anti-Money Laundering Authority with a direct and indirect supervision perimeter that shifts obliged-entity oversight from purely national authorities toward a hybrid EU-level regime. This is durable structural backdrop rather than a Vietnam-specific development; no AMLA horizon anchor touched Vietnam this cycle, and Vietnam's own beneficial-ownership reform proceeds on an entirely separate domestic statutory track. The parallel point of comparison is useful only to note that Vietnam is tightening beneficial-ownership identification duties through ordinary legislative amendment rather than through any supranational supervisory mechanism. #### Outlook The beneficial-ownership strengthening takes effect 1 December 2026 alongside the rest of Law 23/2026/QH16's amendments. Whether the new indirect-ownership and legal-arrangement coverage closes practical gaps will depend on implementing guidance from the State Bank of Vietnam that has not yet been located; no Tier-1 Official Gazette text of the amendment has been retrieved, and current sourcing rests on secondary commentary. That gap is worth tracking ahead of the effective date. Judgment: No new VN beneficial-ownership development; FATF deficiency remains standing. Uncertain #### Enabler Jurisdictions and Professional Facilitators Applying the four-dimension enabler-jurisdiction assessment, legal framework, enforcement reality, capacity deficit versus deliberate choice, and systemic significance, to Vietnam this cycle surfaces a jurisdiction whose gaps read as capacity-driven rather than as a deliberate permissive choice, but whose systemic significance is nonetheless elevated. The existing customs and anti-money-laundering law framework in Vietnam is nominally adequate on paper. Enforcement reality falls well short of that framework: risk-based supervision of designated non-financial businesses and professions, specifically real estate agents, casinos and virtual asset service providers, remains negligible despite the 2022 mutual evaluation findings and the 2025 launch of the crypto trading pilot. No anti-money-laundering supervisor has been designated for trust and company service providers under Decree 19/2023, leaving a professional-intermediary gatekeeper channel effectively unsupervised. Continue reading A second enabler dimension runs through the long, porous land borders that Vietnam shares with China, Laos and Cambodia, which sustain currency, gold and general goods smuggling and a trade-based laundering corridor built on systematic over- and under-invoicing of cross-border trade. The government has produced episodic responses layered atop this structural exposure rather than a systemic fix: a September 2025 gold-market reform sought to curb smuggling and stabilise the currency, and a May 2025 Prime-Minister-ordered task force targets illegal transshipment and counterfeit-goods fraud, the latter motivated in part by concerns raised in United States tariff negotiations. Both responses are best read as targeted interventions rather than as evidence that the underlying border-geography and capacity constraints have been resolved. Systemic significance is elevated for two connected reasons: currency-stability exposure through the gold and trade channels, and the direct link between counterfeit-goods transshipment and an active United States trade-policy negotiation. Both give the enabler-jurisdiction gap a materiality beyond its immediate anti-money-laundering dimension, feeding into broader economic and diplomatic exposure that a narrowly enforcement-focused assessment would understate. This same corridor also intersects with the correspondent-banking enhanced due diligence obligations already engaged by the high-risk-third-country classification of Vietnam described elsewhere in this cycle, since trade-finance and correspondent relationships touching the Mekong border corridor sit inside the same enhanced-due-diligence perimeter. The evidence base itself reflects this same enforcement-reality gap: no direct evidence of designated non-financial business and profession or virtual asset service provider supervisory statistics or enforcement actions was located this cycle, meaning Vietnam-specific detail is substantiated primarily through Financial Action Task Force and Asia-Pacific Group mutual-evaluation documentation rather than through primary domestic supervisory data. This is itself a form of enablement signal under the enabler-jurisdiction framework: the absence of visible supervisory activity, in a jurisdiction with a nominally adequate legal framework, is as analytically significant as an observed enforcement gap, because it leaves open whether limited supervision reflects genuine capacity constraint or an unexamined tolerance for gatekeeper-channel opacity. This Vietnam-specific picture sits within the broader standing enabler-jurisdiction coverage of this monitor, which separately tracks UK professional-enabler ecosystems, Gulf and Singapore intermediary networks, and the Swiss reform trajectory; no cross-jurisdictional link between those standing trackers and the Vietnam findings above was established this cycle. #### Outlook Absent a specific published reform calendar for either designated non-financial business and profession supervision or land-border enforcement capacity, the near-term outlook for the enabler-jurisdiction posture of Vietnam is one of continued episodic response layered atop unresolved structural gaps. The October 2026 Financial Action Task Force plenary review will indirectly test progress in this domain insofar as designated non-financial business and profession supervision bears on the broader Recommendation compliance picture, but no jurisdiction-specific supervisory reform has been scheduled on the evidence available this cycle. Judgment: No new finding this cycle. Probable #### Conflict Finance and Extractive-Industry Integrity No Vietnam-specific conflict-finance nexus was identified in this research cycle. The domain tracker for conflict finance and extractive-industry integrity records a no-change status for the Vietnam profile, and standing global coverage of this domain, spanning Russian war-economy financing, Sahel conflict-mineral trade, Democratic Republic of Congo mining-sector governance and oil-revenue corruption, is carried forward unchanged rather than refreshed this cycle. This is an honest gap rather than a substantive finding: the absence of a documented Vietnam conflict-finance channel in this research window does not establish that no such exposure exists, only that none was surfaced by the sources reviewed. Continue reading What did change, structurally, this cycle is coverage rather than substance: the Vietnam-scoped research pass established a baseline jurisdiction profile against which any future conflict-finance signal, should one emerge, for example through the cross-border trade corridor documented under the enabler-jurisdiction domain, can be assessed for incremental change. #### Outlook No conflict-finance-specific regulatory horizon item was identified for Vietnam this cycle. The next material test of this domain will be whether a future research pass surfaces a documented link between the cross-border gold and goods trade corridor already assessed under enabler-jurisdiction coverage and any armed-conflict or extractive-industry financing channel; absent that, this domain remains carried forward at no-change status, consistent with the honesty-over-coverage principle governing this brief. Judgment: No new finding this cycle. Probable #### Crypto, Digital Assets, and Financial Innovation Vietnam's digital-asset regulatory position this cycle is defined by a structural gap between new statutory obligation and actual supervised population. Law 23/2026/QH16, passed 24 August 2026 and taking effect 1 December 2026, brings virtual-asset and crypto-asset service providers into AML reporting-entity scope for the first time, meaning customer due diligence, transaction monitoring and suspicious-transaction-reporting duties will formally attach to the sector from that date. At the same time, the separate Resolution 05/2025/NQ-CP crypto-exchange pilot framework has issued no final operating licence as of 21 October 2026; five applicants have passed only an initial document-completeness review before Vietnam's securities regulator. The practical consequence is that the new AML reporting obligation takes effect against a licensed population that, as of this cycle, does not yet exist: no crypto-asset exchange is currently operating under a final Vietnamese licence to which the reporting duty could attach in practice. Continue reading This combination is analytically significant on an architecture-over-incident basis: Vietnam is building the AML perimeter for virtual-asset service providers ahead of, rather than alongside, the market-access framework that would populate that perimeter with licensed entities. Where enforcement volume in a jurisdiction's crypto sector is low because the licensed sector itself is essentially empty, that absence is itself a signal worth surfacing rather than a gap to pass over silently. #### Outlook The marker to watch is whether the Resolution 05 pilot moves any of the five document-stage applicants to a final licence before or shortly after 1 December 2026, when the AML reporting-entity obligation takes effect. Until a licence issues, the new AML duty has a statutory but not yet a practical subject. FATF's June 2026 statement citing Vietnam's risk-understanding deficiencies is relevant context here: examiners assessing Vietnam's progress against its action plan are likely to look specifically at whether VASP-sector AML obligations have moved beyond statute into supervised practice. Judgment: FATF's October statement ties an open action item to virtual-asset regulation, intersecting Vietnam's unlicensed crypto pilot. Uncertain #### Compliance Technology and Active Defence No material Vietnam-specific regulatory-technology or supervisory-technology development was identified this cycle. What was identified is a sourcing gap: no dedicated Vietnamese RegTech or SupTech supervisory guidance and no direct State Bank of Vietnam Anti-Money Laundering Division primary-source portal was located in this research window, meaning Vietnam-specific detail in this domain is substantiated primarily through Financial Action Task Force and Asia-Pacific Group mutual-evaluation documentation rather than through primary domestic technology-supervision sources. Continue reading This is explicitly a coverage gap in the evidence base of this monitor rather than a substantive statement about the actual internal compliance-technology posture of the State Bank of Vietnam, which may be more developed than open-source visibility currently allows. Honesty over coverage governs this entry: rather than inferring a RegTech or SupTech posture from adjacent Financial Action Task Force findings, this domain is carried forward at watch status with the sourcing gap explicitly flagged for the next research cycle. The absence of visible compliance-technology infrastructure discussion in the primary sources reviewed this cycle stands in some contrast to the more active discussion of technology-enabled criminal infrastructure documented elsewhere in this brief, namely the stablecoin chain-hopping and payment-processor architecture assessed under the digital-asset domain, and that asymmetry between visible criminal-side technology and comparatively invisible supervisory-side technology is itself worth tracking across future cycles. #### Outlook Direct State Bank of Vietnam publications, should they become accessible in a future research pass, would materially improve coverage of this domain for Vietnam. Absent that, this domain remains at watch status with no material development to report and no regulatory horizon item currently tracked specifically for Vietnamese compliance technology. Judgment: No RegTech/guidance development this cycle. Probable #### AML/CTF Regime Vietnam's standing under the Financial Action Task Force's grey-list process sharpened at the plenary held on 30 October 2026, when the task force recorded significant concern over the pace of progress against Vietnam's action plan. Every deadline in that plan had already expired in May 2025, so the sharpened language lands against a backdrop of a remediation timetable that has lapsed rather than one that is merely running late. For an AML/CTF regime reading, the relevant fact is not the grey-list listing itself, which was already the standing position, but the directional shift in how the task force characterises Vietnam's rate of movement: a plenary statement expressing concern about pace, issued after deadlines have already passed, reads as a harder marker than a routine monitoring continuation. Continue reading This finding is carried at a probable standing because the reporting available this cycle traces to secondary compliance-news summarisation of the plenary rather than to the task force's own published statement. The pinpoint citation to the primary text remains an open item, and the language above should be read with that sourcing limitation in mind: the substance of the retention and the characterisation of concern are reported consistently across what was available, but the primary document has not yet been independently checked against the secondary account. Under the designation conventions this monitor applies, Vietnam's position is properly described as increased monitoring, which is the Financial Action Task Force's own graduated-listing status, rather than being conflated with a call for countermeasures, which is a materially more severe designation reserved for jurisdictions the task force asks members to apply defensive measures against. Nothing in the material reaching this cycle suggests Vietnam has moved to that more severe category. Equally, this is not a sanctions designation in the comprehensive or sectoral sense used elsewhere in this monitor's taxonomy; it is a multilateral standards-body monitoring status, and the two should not be read interchangeably when assessing counterparty exposure. A secondary thread links this regime-level finding to an open action-plan item specifically concerned with virtual-asset regulation, tying back to Vietnam's unlicensed exchange pilot under Resolution 05/2025. That linkage, however, rests on a single commentary source and was not corroborated against the task force's own statement this cycle, so it is carried at a lower, uncertain standing and should be treated as an area for confirmation rather than an established cross-reference. No other substantive AML/CTF regime development for Vietnam reached the bar for inclusion this cycle beyond the plenary outcome and its linked virtual-asset item. #### Outlook The operative question for Vietnam's AML/CTF regime standing is whether tangible legislative or supervisory steps become visible before the task force's next scheduled review brings the file back for reassessment. The combination of lapsed deadlines and hardening plenary language does not, on its own, indicate when or whether the grey-list status might change, but it does indicate that the task force's patience with the current pace is diminishing rather than growing. As the primary plenary statement has not yet been retrieved and checked, confirmation of the precise language used, and of the specific deficiencies still outstanding, remains a priority for the next review of this file. This outlook is offered as an analytical reading of the trajectory evident in the material reviewed, not as a prediction of the outcome of any future plenary. Judgment: FATF sharpened its concern over Vietnam's pace of progress on its grey-list action plan, with all deadlines expired since May 2025. Probable #### Commercial Activity A wave of commercial positioning in Vietnam's crypto-exchange sector this period is best read against the backdrop of the VND10 trillion pilot capital threshold set under Resolution 05/2025/NQ-CP. OKX Ventures and HashKey Capital agreed to invest in the VPBank-ecosystem exchange CAEX, announced on 10 April 2026, a transaction whose financial terms have not been publicly disclosed. Separately, South Korea's Bithumb signed a memorandum of understanding with SSI Digital, Vietnam's largest securities firm, announced on 7 May 2026, to explore building a licensed crypto exchange. Both transactions are corroborated by multiple independent trade-press sources, though neither a party press release nor a regulatory filing was reached, which caps confidence at probable. Continue reading The analytical significance of this commercial wave is in its timing relative to the licensing gap described under crypto and digital-asset financial innovation: international crypto-native capital (OKX, HashKey, Bithumb) is positioning alongside incumbent Vietnamese financial institutions (VPBank's securities arm, SSI) before any exchange has received a final operating licence. This is consistent with market participants treating the capital threshold, rather than the licence grant itself, as the binding near-term constraint — meeting the VND10 trillion bar and securing qualifying institutional shareholders appears to be the race that matters commercially, even while the regulatory outcome of that race remains undetermined. From a financial-integrity standpoint, a wave of foreign capital entering a not-yet-licensed, not-yet-supervised exchange sector is worth tracking independently of any adverse finding: it is the kind of structural positioning that, if one or more of these ventures secures a licence, will determine which entities become the supervised AML/CTF gatekeepers for Vietnam's formal crypto market, and which jurisdictions' capital and expertise sit behind them. #### Outlook The commercial positioning described here is a leading indicator for which entities are likeliest to receive Vietnam's first crypto-exchange licences, should the Ministry of Finance move from initial review to final approval. Absent amount disclosure on either transaction, the scale of capital actually committed remains unverified beyond the parties' stated intent to meet the pilot's institutional-ownership and capital-threshold requirements. Judgment: No commercial-activity development this cycle. Probable Regulatory horizon Consultation 2027 · ±year ### APG Third Mutual Evaluation of Vietnam Vietnam is building out national ML/TF/PF risk assessments and targeted-financial-sanctions implementation ahead of a formal third-round mutual evaluation. [Asia/Pacific Group on Money Laundering (APG) Source](https://vietnamlawmagazine.vn/action-plan-launched-to-strengthen-anti-money-laundering-framework-79323.html) In Force Pending 2027-Q1 · ±quarter ### Resolution 66.23/2026/NQ-CP sunset / permanent AML-law amendment The temporary resolution expires 28 February 2027 or upon entry into force of permanent amending legislation, whichever is first. [Government of Vietnam Source](https://www.vietnam-briefing.com/news/vietnam-anti-money-laundering-beneficial-ownership-rules-2026.html) 2 dated · 2 pending date · baseline fim-2026-07-05 Role action cards MLRO ### FATF sharpened its warning on Vietnam's grey-list progress at the 30 October 2026 plenary. Enhanced due diligence expectations tied to Vietnam's increased-monitoring status remain active and are reinforced by the sharper language, even though the category itself is unchanged. All action-plan deadlines have been expired since May 2025, underscoring the structural nature of the deficiency. 1 evidence refs Compliance ### Vietnam remains on the increased-monitoring list with no change to its regulatory category. Jurisdictional risk-rating frameworks referencing FATF status for Vietnam do not require a category change, but should reflect the sharpened concern language from the October plenary as supporting context for continued enhanced-monitoring treatment. 1 evidence refs Legal ### No escalation to a call-for-action designation occurred this cycle for Vietnam. The absence of escalation is a relevant data point for advising on counterparty risk tied to Vietnam exposure, though the sharpened concern language signals the margin for continued non-escalation may be narrowing. 1 evidence refs Board ### Vietnam's grey-list status persists with sharper Task Force concern over unmet deadlines dating to May 2025. This is a continuation rather than a new material risk, but the prolonged non-resolution of action-plan items is a reputational and strategic exposure factor for institutions with significant Vietnam-linked business. 1 evidence refs CTO ### A secondary source links an open Vietnam action-plan item to virtual-asset regulation and an unlicensed crypto pilot. The Resolution 05/2025 crypto-exchange pilot remains unlicensed, and this cycle's reporting, carried at lower confidence, ties that gap to the Task Force's ongoing concerns. This is relevant context for any platform architecture decisions touching Vietnam-linked virtual-asset rails. 1 evidence refs Risk ### Vietnam's structural grey-list deficiency persists, now with a flagged virtual-asset dimension. The core finding is a continuation at stable confidence; the virtual-asset linkage is an emerging, lower-confidence signal worth monitoring for corroboration, particularly for exposure concentrated in crypto-asset counterparties. 2 evidence refs Operations ### No change to screening or monitoring thresholds is indicated by this cycle's Vietnam finding. Existing enhanced-monitoring workflows tied to Vietnam's grey-list status continue to apply unchanged; no new typology or threshold adjustment is evidenced this cycle. 1 evidence refs Audit ### Documentation of Vietnam's continued grey-list status should reference the October 2026 plenary statement. Audit trails citing jurisdictional risk status for Vietnam should be updated to reflect the most recent plenary confirmation and the sharpened concern language, pending primary-source corroboration. 1 evidence refs Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No material change found relevant to VN this cycle. T2 · EU AML Package / AMLA no_change Not applicable to VN (non-EEA). T3 · FATF Grey List material_change FATF's 30 October 2026 plenary retained Vietnam on the grey list with a sharper warning on pace of progress. T4 · Beneficial-Ownership Register Status no_change No new VN-specific beneficial-ownership development this cycle. T5 · Crypto & Digital-Asset Integrity watch Resolution 05/2025 crypto-exchange pilot remains unlicensed; FATF's October statement links this gap to Vietnam's outstanding action-plan items. T6 · Sanctions Regime Divergence no_change No VN-specific sanctions-divergence development this cycle. Registers ### Enforcement actions - 21 Apr 2025 - 29 Jan 2026 - 14 Oct 2025 - 1 Jun 2025 - 14 May 2025 - 10 Jun 2026 - 7 Jul 2026 - 24 Mar 2026 - 31 Dec 2025 - 31 May 2026 - 19 Aug 2026 - Appeal ruling in Vietnam's largest-ever fraud/money-laundering case, involving alleged embezzlement of over $12 billion from Saigon Commercial Bank via a network of shell entities and proxy shareholders. 21 Apr 2025 - Continuing asset-forfeiture proceedings in the Van Thinh Phat case; courts ruled that personal luxury items, including crocodile-skin Hermes Birkin bags, constituted proceeds of the embezzlement scheme and are subject to forfeiture. 29 Jan 2026 - Coordinated designation of the Cambodia-based Prince Group transnational criminal organization and Huione Group's crypto-payment infrastructure underpinning Southeast Asian pig-butchering scam compounds that traffic and target Vietnamese nationals among other nationalities. 14 Oct 2025 - Nationwide cybercrime crackdown across Cambodia arresting hundreds of foreign nationals, including Vietnamese, working in scam compounds, part of an 18-operation campaign ordered by Prime Minister Hun Manet. 1 Jun 2025 - PM Pham Minh Chinh ordered creation of a task force to combat illegal transhipment of counterfeit goods of Vietnamese origin and IP-infringing exports, amid concerns raised in US tariff negotiations over transshipment abuse. 14 May 2025 ### Sanctions changes - 25 Mar 2026 - 4 Dec 2025 - 14 Oct 2025 - 16 Jan 2026 - 30 Jun 2026 - Following the UK's 2024 MLR reform, HRTC status under Regulation 33 of the Money Laundering Regulations now tracks the live FATF 'Jurisdictions under Increased Monitoring' and 'Call for Action' lists automatically rather than a fixed statutory schedule; Vietnam's continued FATF grey-listing keeps it classified as a UK HRTC requiring enhanced due diligence, with further amendment regulations laid before Parliament in March 2026. 25 Mar 2026 - The European Commission adopted Delegated Regulations (EU) 2026/46 and (EU) 2026/83 (December 2025), updating the EU high-risk third-country list following FATF's June and October 2025 plenaries: Bolivia and the British Virgin Islands were added while Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania were delisted; Vietnam's listing continued unchanged as it remained on the FATF grey list throughout the review cycle. 4 Dec 2025 - The October 2025 coordinated action against the Prince Group TCO and Huione Group (Southeast Asian scam-compound financial infrastructure with substantial Vietnamese victim/operator exposure) saw OFAC designate 146 targets while OFSI separately sanctioned Byex Exchange, illustrating that the two regimes' designation lists for the same underlying criminal network were not identical. 14 Oct 2025 ### Regulatory horizon (register) - Resolution 66.23/2026/NQ-CP sunset / permanent AML-law amendment - APG Third Mutual Evaluation of Vietnam - Resolution 66.23/2026/NQ-CP sunset / permanent AML-law amendment - CASP AML reporting-entity designation commences - FATF October 2026 Plenary review of Vietnam - FATF October 2026 Plenary review of Vietnam's action plan - Law 23/2026/QH16 (AML Law amendment) and Law 13/2026/QH16 (WMD proliferation-financing law) - FATF October 2026 Plenary review of Vietnam's action plan - Vietnam virtual-asset pilot licensing/AML framework build-out - Prospective Vietnam beneficial-ownership legal reform ### Active schemes - - - - Sources - [Arrangements list - Taxation and Customs Union - European Commission](https://taxation-customs.ec.europa.eu/customs/rules-origin-goods/preferential-rules-origin/arrangements-list_en) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Vietnam Law Magazine](https://vietnamlawmagazine.vn/action-plan-launched-to-strengthen-anti-money-laundering-framework-79323.html) - [VietnamNet](https://vietnamnet.vn/en/onus-crypto-case-arrests-made-in-multi-billion-dollar-fraud-probe-2501026.html) - [Vietnam+ (VNA)](https://en.vietnamplus.vn/vietnam-fines-crypto-traders-up-to-1900-usd-for-using-unlicensed-platforms-post348548.vnp) - [AGB](https://agbrief.com/news/27/01/2026/cambodia-aims-to-avoid-fatf-grey-listing/) - [Journal of Contemporary China (Taylor & Francis)](https://www.tandfonline.com/doi/full/10.1080/10670564.2025.2484205) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern) - [Illicit Edge](https://illicitedge.com/chinese-money-laundering-networks-serving-mexico-based-drug-cartels/) - [Washington Trade & Tariff Letter](https://www.wttlonline.com/stories/colombia-designated-major-trafficker-in-fraa-review,14278) - [US Treasury/OFAC](https://home.treasury.gov/news/press-releases/jy2048) - [AMLA (EU)](https://www.amla.europa.eu/amla-takes-next-step-toward-2027-selection-entities-direct-supervision_en) - [https://vietnamlawmagazine.vn/action-plan-launched-to-strengthen-anti-money-laundering-framework-79323.html](https://vietnamlawmagazine.vn/action-plan-launched-to-strengthen-anti-money-laundering-framework-79323.html) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [https://www.vietnam-briefing.com/news/vietnam-beneficial-ownership-rules-decree-296.html](https://www.vietnam-briefing.com/news/vietnam-beneficial-ownership-rules-decree-296.html) - [https://indochinecounsel.com/regulatory-notes-vietnam-raises-penalties-for-beneficial-ownership-and-corporate-registration-non-compliance](https://indochinecounsel.com/regulatory-notes-vietnam-raises-penalties-for-beneficial-ownership-and-corporate-registration-non-compliance) - [https://www.dfdl.com/insights/legal-and-tax-updates/vietnam-tightens-anti-money-laundering-framework/](https://www.dfdl.com/insights/legal-and-tax-updates/vietnam-tightens-anti-money-laundering-framework/) - [https://blogs.duanemorris.com/vietnam/2026/01/05/vietnam-guide-to-anti-money-laundering-2/](https://blogs.duanemorris.com/vietnam/2026/01/05/vietnam-guide-to-anti-money-laundering-2/) - [https://www.vietnam-briefing.com/news/vietnam-anti-money-laundering-beneficial-ownership-rules-2026.html](https://www.vietnam-briefing.com/news/vietnam-anti-money-laundering-beneficial-ownership-rules-2026.html) - [https://www.fatf-gafi.org/en/news/targeted-updated-va-vasps-2026.html](https://www.fatf-gafi.org/en/news/targeted-updated-va-vasps-2026.html) - [https://www.cryptoverselawyers.io/vietnam-first-crypto-regulation-licensing/](https://www.cryptoverselawyers.io/vietnam-first-crypto-regulation-licensing/) - [https://vietnamlawmagazine.vn/sbv-revises-aml-law-to-remove-the-country-from-fatfs-grey-list-74305.html](https://vietnamlawmagazine.vn/sbv-revises-aml-law-to-remove-the-country-from-fatfs-grey-list-74305.html) - [https://www.mondaq.com/corporate-governance/1827624/vietnam-introduces-a-new-era-of-corporate-transparency-decree-296-establishes-mandatory-beneficial-ownership-look-through-rules-and-tightens-business-suspension-regime](https://www.mondaq.com/corporate-governance/1827624/vietnam-introduces-a-new-era-of-corporate-transparency-decree-296-establishes-mandatory-beneficial-ownership-look-through-rules-and-tightens-business-suspension-regime) - [https://thediplomat.com/2026/06/vietnamese-police-disrupt-online-scam-operations-relocating-from-cambodia/](https://thediplomat.com/2026/06/vietnamese-police-disrupt-online-scam-operations-relocating-from-cambodia/) - [VnEconomy](https://en.vneconomy.vn/banking-related-laws-amended-passed.htm) - [Vietnam News Agency (VietnamPlus)](https://en.vietnamplus.vn/legal-amendments-aim-to-strengthen-banking-anti-money-laundering-framework-post349520.vnp) - [Vietnam Briefing (Dezan Shira)](https://www.vietnam-briefing.com/news/vietnam-anti-money-laundering-beneficial-ownership-rules-2026.html) - [BIDV](https://bidvinfo.com.vn/en/publication-of-the-presidents-decree-on-the-law-amending-and-supplementing-certain-provisions-of-the-law-on-the-state-bank-of-vietnam-the-law-on-the-prevention-and-combating-of-money-laundering-and-th-10020618.html) - [iGaming Expert](https://igamingexpert.com/regions/asia/cambodia-scam-centre-crackdown/) - [AGBrief](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/) - [Baker McKenzie](https://www.bakermckenzie.com/en/insight/publications/2026/08/mexico-new-general-rules-of-the-anti-money-laundering-law) - [CryptoRank/BitcoinWorld](https://cryptorank.io/news/feed/b7225-nine-months-seven-applicants-zero-licences-vietnams-crypto-waiting-game) - [https://bfsc-law.com/new-regulations-beneficial-ownership-enterprises-vietnam-july-2026/](https://bfsc-law.com/new-regulations-beneficial-ownership-enterprises-vietnam-july-2026/) - [https://www.loc.gov/item/global-legal-monitor/2023-05-04/vietnam-anti-money-laundering-law-takes-effect/](https://www.loc.gov/item/global-legal-monitor/2023-05-04/vietnam-anti-money-laundering-law-takes-effect/) - [https://www.smallworldfs.com/blog/2026/08/30/vietnam-crypto-licensing-takes-big-step-as-5-firms-pass-first-review/](https://www.smallworldfs.com/blog/2026/08/30/vietnam-crypto-licensing-takes-big-step-as-5-firms-pass-first-review/) - [https://www.coindesk.com/markets/2026/04/10/okx-hashkey-back-usd380-million-vietnam-crypto-push-as-new-rules-near-rollout](https://www.coindesk.com/markets/2026/04/10/okx-hashkey-back-usd380-million-vietnam-crypto-push-as-new-rules-near-rollout) - [https://www.blockhead.co/2026/05/11/bithumb-signs-deal-with-vietnams-largest-securities-firm-to-build-local-crypto-exchange/](https://www.blockhead.co/2026/05/11/bithumb-signs-deal-with-vietnams-largest-securities-firm-to-build-local-crypto-exchange/) - [https://indochinecounsel.com/special-alert-navigating-vietnams-new-anti-money-laundering-law-key-changes-and-updates](https://indochinecounsel.com/special-alert-navigating-vietnams-new-anti-money-laundering-law-key-changes-and-updates) - [https://www.lexology.com/library/detail.aspx?g=902b7b51-963b-439d-b954-4615b5eb34bc](https://www.lexology.com/library/detail.aspx?g=902b7b51-963b-439d-b954-4615b5eb34bc) - [https://kpmg.com/vn/en/insights/2026/10/new-regulations-on-law-on-anti-money-laundering.html](https://kpmg.com/vn/en/insights/2026/10/new-regulations-on-law-on-anti-money-laundering.html) - [https://vietnamnews.vn/economy/1798153/crypto-assets-added-to-anti-money-laundering-law.html](https://vietnamnews.vn/economy/1798153/crypto-assets-added-to-anti-money-laundering-law.html) - [Zyphe](https://www.zyphe.com/resources/news/fatf-grey-list-october-2026-plenary-removals) - [AML UAE](https://amluae.com/fatf-grey-list-update-october-2026/) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Vietnam](https://www.fatf-gafi.org/en/countries/detail/Vietnam.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Jurisdictions under Increased Monitoring - 13 June 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html) - [Mutual Evaluation of Vietnam](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofvietnam.html) - [Vietnam's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-Vietnam-2025.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [Jurisdictions under Increased Monitoring - 21 February 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [1 Notice to Customers: Beneficial Ownership Information Reference Guide](https://www.fincen.gov/system/files/shared/BOI-Notice-to-Customers-508FINAL.pdf) - [GUIDANCE FOR A RISK-BASED APPROACH BENEFICIAL OWNERSHIP AND](https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.pdf.coredownload.inline.pdf) - [Vietnam Passes Law to Support Troubled Banks, Tackle Bad Debt - Bloomberg](https://www.bloomberg.com/news/articles/2025-06-27/vietnam-passes-law-to-tackle-bank-crisis-resolving-bad-debts) - [Beneficial Ownership](https://www.fatf-gafi.org/en/topics/beneficial-ownership.html) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Vietnam Tests Crypto Trading Market With Five-Year Trial - Bloomberg](https://www.bloomberg.com/news/articles/2025-09-09/vietnam-tests-crypto-trading-market-with-five-year-trial-program) - [Blockchain Legal & Regulatory Guidance Practice Note: Part Six: VASPs](https://www.elliptic.co/blog/analysis/blockchain-legal-regulatory-guidance-practice-note-part-six-virtual-asset-service-providers) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Virtual Assets](https://www.fatf-gafi.org/en/topics/virtual-assets.html) - [Crypto Adoption Accelerates in APAC Region](https://www.chainalysis.com/blog/asia-pacific-crypto-adoption-2025/) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [Crypto Regulatory Affairs: Hong Kong updates guidance for intermediaries on virtual asset-related activities](https://www.elliptic.co/blog/crypto-regulatory-affairs-hong-kong-updates-guidance-for-intermediaries-on-virtual-asset-related-activities) - [Crypto regulatory affairs: HKMA’s tokenization pilot program begins](https://www.elliptic.co/blog/crypto-regulatory-affairs-hkma-tokenization-pilot-program-begins) - [Crypto regulatory affairs: Hong Kong regulator lays out cryptoasset roadmap](https://www.elliptic.co/blog/crypto-regulatory-affairs-hong-kong-regulator-lays-out-cryptoasset-roadmap) - [Crypto Firms Help Take Down International ‘Pig Butchering’ Scam | OCCRP](https://www.occrp.org/en/news/crypto-firms-help-take-down-international-pig-butchering-scam) - [U.S. Launches New Strike Force to Combat $10 Billion Scam Industry](https://www.chainalysis.com/blog/ofac-targets-pig-butchering-scams-november-2025/) - [The Scam Center Strike Force: A Whole-of-Government Response to Global Crypto Fraud | TRM Labs](https://www.trmlabs.com/resources/blog/the-scam-center-strike-force-a-whole-of-government-response-to-global-crypto-fraud) - [US Authorities Warn of "Pig Butchering" Investment Scam | OCCRP](https://www.occrp.org/en/news/us-authorities-warn-of-pig-butchering-investment-scam) - [Cambodia Extradites Another Associate of Alleged ‘Criminal’ Conglomerate to China | OCCRP](https://www.occrp.org/en/news/cambodia-extradites-another-executive-from-alleged-criminal-conglomerate-to-china) - [15 Malaysians Rescued from Cambodia’s Cyber Scam Traffickers | OCCRP](https://www.occrp.org/en/news/15-malaysians-rescued-from-cambodias-cyber-scam-traffickers) - [US Authorities Warn of "Pig Butchering" Investment Scam](https://www.occrp.org/en/27-ccwatch/cc-watch-briefs/18026-us-authorities-warn-of-pig-butchering-investment-scam) - [U.S. Crackdown on Southeast Asian Crypto Scam Centers](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [Palau-based Figure Exposed by OCCRP is Among Scores Sanctioned Over Online Scams | OCCRP](https://www.occrp.org/en/news/palau-based-figure-exposed-by-occrp-is-among-scores-sanctioned-over-online-scams) - [DOJ Seizes $15 Billion in Bitcoin](https://www.chainalysis.com/blog/southeast-asia-crypto-scam-network-mining-pig-butchering-october-2025/) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Russian Attempts to Evade Sanctions Using New Overseas ...](https://ofac.treasury.gov/media/933146/download) - [Russia-related and Russia-/Ukraine-related Designations; Venezuela-related Designations; Publication of Russia-related Determinations; Issuance of Russia-related General Licenses and Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250110) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [How A7A5 and Grinex Enable The Russian Shadow Crypto Economy](https://www.chainalysis.com/blog/a7a5-grinex-russian-crypto-economy-ofac-sanctions-august-2025/) - [OFAC Sanctions Aeza Group for Hosting Global Bulletproof Service](https://www.chainalysis.com/blog/ofac-sanctions-aeza-group-bulletproof-hosting-crypto-payments-july-2025/) - [OFAC Targets $600 Million Iranian Shadow Banking Network](https://www.chainalysis.com/blog/ofac-sanctions-iranian-shadow-crypto-banking-network-september-2025/) - [Collaboration in the Wake of Record-Breaking Bybit Theft](https://www.chainalysis.com/blog/bybit-exchange-hack-february-2025-crypto-security-dprk/) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [Russian Harmful Foreign Activities Sanctions](https://ofac.treasury.gov/faqs/topic/6626) - [Vietnam Mogul Wins Appeal, Still Faces 30 Years Behind Bars - Bloomberg](https://www.bloomberg.com/news/articles/2025-04-20/vietnam-property-tycoon-back-in-court-for-life-sentence-appeal) - [Vietnam Mogul Scrambles to Pay Back Bondholders Ahead of Life Sentence Appeal - Bloomberg](https://www.bloomberg.com/news/articles/2025-03-24/vietnam-mogul-scrambles-to-pay-back-bondholders-as-appeal-starts) - [Vietnam $12 Billion Fraud Trial of Property Tycoon to Start Amid Anti-Graft Push - Bloomberg](https://www.bloomberg.com/news/articles/2024-03-04/vietnam-12-billion-fraud-trial-to-begin-amid-anti-graft-push) - [Vietnam Tycoon Truong My Lan Loses Death Penalty Appeal Over Fraud Scandal - Bloomberg](https://www.bloomberg.com/news/articles/2024-12-03/mogul-seeks-to-avoid-execution-in-vietnam-s-biggest-fraud-case) - [Vietnam Property Tycoon Faces Trial Over $12.5 Billion Fraud - Bloomberg](https://www.bloomberg.com/news/articles/2023-12-18/vietnam-property-tycoon-faces-trial-over-12-5-billion-fraud) - [Vietnam Seeks Death for Tycoon in $12 Billion Fraud Case, Media Reports Say](https://www.bloomberg.com/news/articles/2024-03-19/vietnam-seeks-death-for-tycoon-in-12-billion-fraud-case-media) - [Vietnam Tycoon Lan Sentenced to Death Over $12 Billion Fraud - Bloomberg](https://www.bloomberg.com/news/articles/2024-04-11/vietnam-tycoon-lan-sentenced-to-death-in-12-billion-fraud-case) - [Vietnam Tycoon Truong My Lan Faces Second Trial While Appealing Death Penalty - Bloomberg](https://www.bloomberg.com/news/articles/2024-09-06/vietnam-tycoon-faces-2nd-trial-while-appealing-death-penalty) - [Vietnam to Sell Tycoon’s Yacht And Hermes Bags to Cover Fraud - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-29/vietnam-to-sell-tycoon-s-yacht-and-hermes-bags-to-cover-fraud) - [Vietnam Tycoon Seeks to Manage Her Assets From Prison: Media - Bloomberg](https://www.bloomberg.com/news/articles/2025-05-13/vietnam-tycoon-seeks-to-manage-her-assets-from-prison-media) - [Anti‐money laundering and counter‐terrorist financing measures Vietnam](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/APG-Mutual-Evalutaion-Report-Vietnam-2022.pdf.coredownload.inline.pdf) - [Vietnam's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-vietnam-2022.html) - [News](https://www.fatf-gafi.org/en/the-fatf/news.html) - [Country policy and information note: fear of illegal moneylenders, Vietnam, February 2025 (accessible) - GOV.UK](https://www.gov.uk/government/publications/vietnam-country-policy-and-information-notes/country-policy-and-information-note-fear-of-illegal-moneylenders-vietnam-january-2023-accessible) - [Vietnam PM Orders Crackdown on Trade Fraud, Counterfeit Goods - Bloomberg](https://www.bloomberg.com/news/articles/2025-05-14/vietnam-pm-orders-crackdown-on-trade-fraud-counterfeit-goods-manldi6g) - [Vietnam Traders Say Gold Reforms to Help Dong, Curb Price Gap - Bloomberg](https://www.bloomberg.com/news/articles/2025-09-28/vietnam-s-plans-to-its-gold-market-are-backed-by-trading-group) - [` 1st Follow-Up Report Mutual Evaluation of Vietnam June 2023](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Vietnam-FUR-2023.pdf.coredownload.inline.pdf) - [Vietnam's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Vietnam-FUR-2024.html) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering and Combating the Financing of Terrorism and Counter-Proliferation Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-and-4) - [GIABA Follow-Up Report Senegal - 2024](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GIABA-Senegal-FUR-2024.pdf.coredownload.pdf) - [Vietnam MER 2022](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/APG-Mutual-Evalutaion-Report-Vietnam-2022.pdf) - [Scam centres are a ‘human rights crisis’, independent experts warn | UN News](https://news.un.org/en/story/2025/05/1163521) - [Myanmar Says It Repatriated 70,000 Foreigners Forced to Work in Scam-Centers | OCCRP](https://www.occrp.org/en/news/myanmar-says-it-repatriated-70000-foreigners-forced-to-work-in-scam-centers) - [Cambodia Arrests Nearly 1,000 in Nationwide Cybercrime Crackdown | OCCRP](https://www.occrp.org/en/news/cambodia-arrests-nearly-1000-in-nationwide-cybercrime-crackdown) - [Cambodia: Over 48,000 Scammers Deported amid Scam Center Crackdown | OCCRP](https://www.occrp.org/en/news/cambodia-over-48000-scammers-deported-amid-scam-center-crackdown) - [Police Free 215 Foreign Nationals From Scam Center in Cambodia - Bloomberg](https://www.bloomberg.com/news/articles/2025-02-23/police-free-215-foreign-nationals-from-scam-center-in-cambodia) - [Myanmar Detains Over 10,000 Foreigners in Scam Center Crackdown - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-28/myanmar-detains-over-10-000-foreigners-in-scam-center-crackdown) - [Crushing scam farms, Southeast Asia’s ‘criminal service providers’](https://www.unodc.org/unodc/frontpage/2024/July/crushing-scam-farms--southeast-asias-criminal-service-providers.html) - [OFAC Sanctions Human Trafficking Network Engaged in Pig Butchering | TRM Labs](https://www.trmlabs.com/post/ofac-sanctions-human-trafficking-network-engaged-in-pig-butchering) - [Scam no more: how the Philippines is cracking down on online fraud centres with UN support](https://www.unodc.org/unodc/frontpage/2026/April/scam-no-more_-how-the-philippines-is-cracking-down-on-online-fraud-centres-with-un-support.html) - [Ngày cập nhật: 24/7/2024 1 Mạng Lưới Hành Pháp Đối Với Tội Phạm](https://www.fincen.gov/system/files/shared/BOI_FAQs_QA_01.2024_Vietnamese_v2.pdf) - [FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us) - [Beneficial Ownership Regulations and Company Registries in Southeast Asia](https://www.unodc.org/roseap/uploads/documents/topics/anti-corruption/2022/Beneficial_ownership_regulations_and_company_registries_in_Southeast_Asia.pdf) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Beneficial Ownership Information Reporting Rule Fact Sheet | FinCEN.gov](https://www.fincen.gov/beneficial-ownership-information-reporting-rule-fact-sheet) - [Company Incorporation in Vietnam: Legal Requirements for European Investors - IP Helpdesk](https://intellectual-property-helpdesk.ec.europa.eu/news-events/news/company-incorporation-vietnam-legal-requirements-european-investors-2021-09-30_en) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html) - [Mạng Lưới/Hệ Thống Chống Các Hành Vi Phạm Pháp Liên Quan Đến Tài Chánh](https://www.fincen.gov/system/files/shared/BOI_Small_Compliance_Guide-Vietnamese_508C.pdf) - [Quick Reference | FinCEN.gov](https://www.fincen.gov/boi/quick-reference) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [Anti-Money Laundering and Terrorist Financing Directive 4 - Finance](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [Methodology for identifying high-risk third countries under ...](https://finance.ec.europa.eu/document/download/f745b6e8-735b-4855-b050-f52276356fe6_en) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [HM Treasury Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/hm-treasury-advisory-notice-high-risk-third-countries) - [ECSH31555 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh31555) - [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2) - [ECSH64830 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh64830) - [High-risk third countries](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries) - [ECSH33336 - High-risk third countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh33336) - [S T A T U T O R Y I N S T R U M E N T S 2023 No. 1306 FINANCIAL SERVICES](https://www.legislation.gov.uk/uksi/2023/1306/pdfs/uksi_20231306_en.pdf) - [EU-Viet Nam agreements - EU Trade - European Union](https://policy.trade.ec.europa.eu/eu-trade-relationships-country-and-region/countries-and-regions/viet-nam/eu-viet-nam-agreements_en) - [Jurisdictions under Increased Monitoring - 27 October 2023](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Increased-monitoring-october-2023.html) - [Arrangements list - Taxation and Customs Union - European Commission](https://taxation-customs.ec.europa.eu/customs/rules-origin-goods/preferential-rules-origin/arrangements-list_en) - [FATF/Asia-Pacific Group on Money Laundering (APG)](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/APG-Mutual-Evalutaion-Report-Vietnam-2022.pdf.coredownload.inline.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-Vietnam-2025.html) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [UK Gambling Commission / HM Treasury](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries) - [European Commission](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-04-20/vietnam-property-tycoon-back-in-court-for-life-sentence-appeal) - [OCCRP](https://www.occrp.org/en/news/cambodia-arrests-nearly-1000-in-nationwide-cybercrime-crackdown) - [Chainalysis](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [UNODC](https://www.unodc.org/unodc/frontpage/2024/July/crushing-scam-farms--southeast-asias-criminal-service-providers.html) Coverage gaps fim-int-2026-07-07-G001: No centralized public beneficial-ow… fim-int-2026-07-07-G001: No centralized public beneficial-ownership register or verification mechanism exists for Vietnam; direct national-registry primary-source access would substantiate real-time beneficial-ownership compliance status beyond FATF follow-up-report characterisations. [resolved] fim-int-2026-07-07-G002: No direct evidence of designated no… fim-int-2026-07-07-G002: No direct evidence of designated non-financial business and profession or virtual asset service provider supervisory statistics or enforcement actions was located; primary State Bank of Vietnam or Ministry of Planning and Investment supervisory data between FATF review cycles would clarify whether the trust and company service provider AML-supervisor vacuum has been addressed. [resolved] fim-int-2026-07-07-G003: The specific current-cycle European… fim-int-2026-07-07-G003: The specific current-cycle European Union high-risk third-country annex text naming Vietnam was not independently re-pulled this run; direct retrieval of the live annex would confirm continued listing status rather than relying on the December 2025 delegated-regulation announcement alone. [resolved] fim-int-2026-07-07-G004: The baseline enforcement register a… fim-int-2026-07-07-G004: The baseline enforcement register and the R3 challenge review report conflicting figures, thirty years versus twenty years, for the April 2025 appellate fraud sentence against Truong My Lan; a primary Vietnamese court record or additional corroborating tier-one or tier-two source is needed to resolve the discrepancy. [resolved] fim-int-2026-07-07-G005: No dedicated Vietnamese RegTech or … fim-int-2026-07-07-G005: No dedicated Vietnamese RegTech or SupTech supervisory guidance or State Bank of Vietnam Anti-Money Laundering Division primary-source portal was accessible this cycle; direct State Bank of Vietnam publications would improve D6 coverage for Vietnam. [resolved] fim-int-2026-07-07-G006: This cycle research bundle was Viet… fim-int-2026-07-07-G006: This cycle research bundle was Vietnam-scoped and did not substantively refresh the standing European Union AMLA, AMLR and sixth AML Directive horizon anchors; these were omitted rather than carried forward without current-cycle support and should be refreshed on the next European Union-scoped research cycle. [resolved] fim-int-2026-07-07-G007: The 25 June 2025 abolition of the d… fim-int-2026-07-07-G007: The 25 June 2025 abolition of the death penalty for embezzlement and its commutation effect on the Truong My Lan sentence is currently substantiated only via tier-three and tier-four secondary sources; a primary Vietnamese National Assembly or court record would raise this to High confidence. [resolved] fim-int-2026-07-14-G001: Ministry of Justice court-level pro… fim-int-2026-07-14-G001: Ministry of Justice court-level prosecution/conviction statistics for money-laundering cases were not separately published this cycle, limiting corroboration of FATF's ML-prosecution-volume action-plan item. [resolved] fim-int-2026-07-14-G002: APG mutual-evaluation follow-up com… fim-int-2026-07-14-G002: APG mutual-evaluation follow-up communication (distinct from the FATF plenary statement) was not located this cycle. [resolved] fim-int-2026-07-14-G003: No Tier-1/2 government-portal sourc… fim-int-2026-07-14-G003: No Tier-1/2 government-portal source (SSC/MOF gazette) was retrieved directly for the crypto-exchange licensing pilot; reliance is on secondary/vendor-adjacent legal commentary. [resolved] fim-int-2026-07-14-G004: D1 (sanctions) and D4 (conflict fin… fim-int-2026-07-14-G004: D1 (sanctions) and D4 (conflict finance) domains returned no Vietnam-specific findings this cycle; this reflects thin coverage rather than confirmed absence. [resolved] fim-int-2026-07-14-G005: MX and CO Tier-D corridor jurisdict… fim-int-2026-07-14-G005: MX and CO Tier-D corridor jurisdictions returned no material VN-adjacent signal this cycle (actively checked, not omitted). [resolved] fim-int-2026-08-05-G001: No Tier-1 primary decision text loc… fim-int-2026-08-05-G001: No Tier-1 primary decision text located for Decision 707/QD-TTg (VN 2026-2030 AML/CTF/CPF action plan). [resolved] fim-int-2026-08-05-G002: No material RegTech/AI-supervisory … fim-int-2026-08-05-G002: No material RegTech/AI-supervisory guidance development surfaced for D6 this cycle. [resolved] fim-int-2026-08-05-G003: No jurisdiction-specific NRA citati… fim-int-2026-08-05-G003: No jurisdiction-specific NRA citation located for VN, KH, LA, MX or CO this cycle. [resolved] fim-int-2026-08-05-G004: Cambodia, Laos, Mexico (Section 311… fim-int-2026-08-05-G004: Cambodia, Laos, Mexico (Section 311/2313a casino sanctions) and Colombia FRAA findings rest on Tier-3/4 sourcing without Tier-1/2 government corroboration this cycle. [resolved] fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No direct Tier-1 government-gazette text was retrieved this cycle for the Decree 296/Decree 288 BO-regime changes; all findings rest on Tier-3 legal-commentary corroboration. [resolved] fim-int-2026-08-20-G002: Mexico and Colombia Tier-D coverage… fim-int-2026-08-20-G002: Mexico and Colombia Tier-D coverage was not actively searched this cycle due to pooled-budget prioritization toward the VN-bound dispatch; recorded as awaiting_primary_source, not an earned null. [resolved] fim-int-2026-08-20-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1, D3, D4 and D6 findings were thin this cycle given the VN-bound dispatch focus; no material trigger evaluated for these domains beyond the standing-tracker carry-forward. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 (enabler jurisdictions/professional facilitators) not substantively researched this cycle within the pooled search budget. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): D4 (conflict finance) not substantively researched this cycle. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D6'}): D6 (compliance technology/RegTech) enforcement_gap_log not substantively researched this cycle. [resolved] fim-int-2026-09-28-G004: No primary FATF/SBV/MOF gazette tex… fim-int-2026-09-28-G004: No primary FATF/SBV/MOF gazette text was directly retrieved this cycle; all findings rest on secondary trade-press/law-firm commentary. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Official Gazette text of Law No. 23/2026/QH16 amending the SBV Law, AML Law and Credit Institutions Law was not retrieved this cycle, capping confidence on the CASP reporting-entity designation at Probable. [resolved] fim-int-2026-10-04-G002: No Colombia (CO) Tier D material ch… fim-int-2026-10-04-G002: No Colombia (CO) Tier D material change was found this cycle despite active searching; coverage remains thin for this Tier D jurisdiction. [resolved] fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D6'}): No dedicated VN-focused RegTech/AI-transaction-monitoring or compliance-technology development was identified this cycle for D6, a structural coverage gap rather than a finding of absence. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No primary Vietnamese gazette text (chinhphu.vn) was reached for Decree 296/2026/ND-CP or Resolution 66.23/2026/NQ-CP, capping confidence at Probable. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No T1 MOF/SSC registry page was located confirming whether a crypto-exchange licence has issued since 30 August 2026. [resolved] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): No VN-specific sanctions, conflict-finance or enabler-jurisdiction signal was found this cycle; D1/D3/D4 remain thinly covered for this single-JID dispatch. [resolved] fim-int-2026-10-25-G001: No Tier-1 Official Gazette text of … fim-int-2026-10-25-G001: No Tier-1 Official Gazette text of Law 23/2026/QH16 was retrieved; passage and effective date rest on secondary commentary (KPMG T4) and VNA-affiliated press (T3). [resolved] fim-int-2026-10-25-G002: No FATF statement specific to an Oc… fim-int-2026-10-25-G002: No FATF statement specific to an October 2026 plenary outcome for Vietnam was located, leaving grey-list trajectory unconfirmed beyond the June 2026 statement. [resolved] fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1-D6 substantive findings for VN not located this cycle beyond the D5 FATF/crypto-pilot linkage. [open] fim-int-2026-11-01-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G004 ({'scheme': 'financial_integrity', 'value': 'D7'}): FATF statement pinpoint citation (obligation_refs) awaiting primary fatf-gafi.org source. [open] fim-int-2026-10-30-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-30-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No Tier-1 fatf-gafi.org primary plenary statement text was retrieved for the 30 October 2026 FATF statement on Vietnam this cycle. [open] fim-int-2026-10-30-G002: No D1-D6 substantive findings were … fim-int-2026-10-30-G002: No D1-D6 substantive findings were located for VN this cycle beyond the D5/D7 FATF-linked signal. [open] FIM-GAP-001 (D2): Recommendation 24 (beneficial ownership tr… FIM-GAP-001 (D2): Recommendation 24 (beneficial ownership transparency of legal persons) remains rated Partially Compliant per successive FATF follow-up reports through 2025-2026, with authorities lacking an effective regime for adequate, accurate and up-to-date BO information. FIM-GAP-002 (D3): DNFBP and VASP supervision remains negligi… FIM-GAP-002 (D3): DNFBP and VASP supervision remains negligible; Decree 19/2023 designates no AML supervisor for TCSPs, and risk-based supervision of real estate, casinos and virtual asset service providers has not been implemented despite the 2022 MER's findings and the 2025 crypto-trading pilot launch. FIM-GAP-003 (D1): Recommendation 29 (financial intelligence/… FIM-GAP-003 (D1): Recommendation 29 (financial intelligence/TFS-related NPO oversight) remains rated Partially Compliant; risk-based NPO supervision and targeted financial sanctions implementation for TF/PF remain underdeveloped per the FATF's 2025-2026 follow-up assessments. FIM-GAP-004 (D6): This baseline could not directly access a … FIM-GAP-004 (D6): This baseline could not directly access a State Bank of Vietnam AML Division primary-source portal or English-language national risk assessment; Vietnam-specific detail is substantiated primarily through FATF/APG mutual-evaluation documentation, and no dedicated Vietnamese RegTech/SupTech supervisory guidance was located in this research window. ## Evidence #### Confidence-tiered claims Effective 1 December 2026, crypto-asset service providers become AML reporting entities obliged to file suspicious-transaction reports with the SBV, under Law No. 23/2026/QH16 amending the SBV Law, AML Law and Credit Institutions Law. [[Source 1]](#sec-sources) Probable · 1 source Resolution No. 66.23/2026/NQ-CP (24 July 2026) defines a beneficial owner using a 25% direct/indirect ownership-or-control threshold, or absent an identifiable controller, the person holding highest executive authority. [[Source 1]](#sec-sources) Probable · 1 source Vietnam remained on the FATF 'Jurisdictions under Increased Monitoring' list as of the 19 June 2026 Plenary; the October 2026 Plenary outcome is pending. [[Source 1]](#sec-sources) Probable · 1 source A Ministry of Finance decree on administrative sanctions in crypto assets/crypto markets took effect 1 September 2026, running for the duration of the five-year Resolution 05/2025/NQ-CP pilot, fining individual users trading outside a licensed platform up to VND 50 million and permitting referral of AML-flagged conduct to criminal investigation. [[Source 1]](#sec-sources) Probable · 1 source Cambodian authorities investigated all 195 licensed casinos nationwide in August 2026, suspending 29 licences and recording 23 further closures/expirations, as part of an anti-scam-compound crackdown ahead of a possible third FATF grey-list placement. [[Source 1]](#sec-sources) Probable · 1 source SHCP published General Rules in the Official Gazette on 7 August 2026 operationalising the July 2025 and March 2026 AML Law reforms for Vulnerable Activities, including a new beneficial-ownership identification hierarchy and updated compliance-manual requirements. [[Source 1]](#sec-sources) Probable · 1 source Three-tier beneficial-ownership identification regime: 25% ownership threshold, family/contractual-group aggregation, indirect-ownership test; CDD and BO-verification provisions amended to align with international tax-information-exchange commitments [[Source 1]](#sec-sources) Probable · 1 source No final exchange licence issued as of 30 August 2026, despite five applicants passing initial Ministry of Finance review; Decree 284/2026/ND-CP (effective 1 Sept 2026) fines unlicensed exchange operation/advertising at VND180-200 million [[Source 1]](#sec-sources) Probable · 1 source Reporting entities include financial institutions, payment-intermediary providers, and DNFBPs including prize-winning video games, casino, lottery and betting operators (Art 4); VND400,000,000 reporting threshold; STR within 3 working days of transaction or 1 working day of detection [[Source 1]](#sec-sources) Probable · 1 source OKX Ventures and HashKey Capital invested in CAEX (announced 10 April 2026) to meet VND10 trillion pilot capital threshold; Bithumb signed an MOU with SSI Digital (announced 7 May 2026) [[Source 1]](#sec-sources) Probable · 1 source Remains on the FATF list of Jurisdictions under Increased Monitoring per the 19 June 2026 Plenary; October 2026 Plenary outcome not yet published [[Source 1]](#sec-sources) Probable · 1 source Virtual asset / crypto-asset service providers become AML reporting entities [[Source 1]](#sec-sources) Probable · 1 source FATF retained Vietnam on the increased-monitoring (grey) list at its 30 October 2026 plenary, expressing significant concern over the pace of progress; all Vietnam action-plan deadlines expired May 2025. [[Source 1]](#sec-sources) Probable · 1 source Including indirect ownership and legal arrangements; new transparency/recordkeeping duties [[Source 1]](#sec-sources) Probable · 1 source Prevention and Combat of Financing of the Proliferation of Weapons of Mass Destruction [[Source 1]](#sec-sources) Probable · 1 source No final operating licence issued as of 21 October 2026; five applicants passed only initial document-completeness review [[Source 1]](#sec-sources) Probable · 1 source FATF expressed significant concern over pace of progress at 30 Oct 2026 plenary; all deadlines expired May 2025 [[Source 1]](#sec-sources) Probable · 1 source Links to unlicensed Resolution 05/2025 crypto-exchange pilot [[Source 1]](#sec-sources) Uncertain · 1 source Secondary reporting on the October 2026 FATF statement ties Vietnam's unresolved action-plan items to virtual-asset regulation, overlapping with the as-yet-unlicensed Resolution 05/2025 crypto exchange pilot. [[Source 1]](#sec-sources) Uncertain · 1 source