DFDL Vietnam Legal Alert: New National Action Plan in Relation to Virtual Assets and Virtual Asset Service Providers

Currently, Vietnamese law does not contain a specific legal framework for the virtual assets and virtual asset service providers. Nevertheless, this silent situation would be changed in 2025.

Recently, the Prime Minister issued Decision No. 194/QD-TTg (dated 23 February 2024) regarding the implementation of the national action plan to fulfill the commitments of the Government of Vietnam on anti-money laundering, counter-terrorism financing, and proliferation of weapons of mass destruction (“Decision 194”). The national action plan outlined in Decision 194 includes a series of actions with corresponding specific timelines, demonstrating the Government’s determination to remove Vietnam from the Jurisdictions under the Increased Monitoring List (Grey List). Among the activities outlined, the legal framework for the virtual assets and virtual asset service providers would be built. So, businesses should also pay attention to several important aspects that may affect their operations:


In 2024

Until September 2024, the State Bank of Vietnam was tasked with completing a risk assessment of money laundering in sectors including casinos, gaming businesses, virtual assets, legal entities, and contractual agreements. The State Bank of Vietnam was also assigned the responsibility of enhancing its information technology system to minimize identified risks (improving the quality of suspicious transaction reports, timely financial intelligence information, enhancing coordination and responsiveness…).

Additionally, the Government of Vietnam plans to enhance the signing of Mutual Legal Assistance Agreements in criminal matters with foreign countries, particularly those with high risks of money laundering offenses and underlying crimes.


In 2025

By January 2025, the Ministry of Justice has been tasked with conducting research and review to propose amendments, supplements, or issuance of relevant legal documents to address deficiencies in compliance with technical standards regarding money laundering.

By May 2025, the Ministry of Finance and relevant ministries are to establish a legal framework for Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs) and demonstrate the enforcement of this legal framework, including: (i) enhancing the understanding of regulatory and supervisory agencies regarding risks in this field; (ii) providing training and disseminating knowledge to enhance the understanding and obligations of VASPs regarding anti-money laundering, counter-terrorism financing, and proliferation of weapons of mass destruction, while also outlining measures for dealing with violations.


The activities outlined in the national action plan specified in Decision 194 highlight several key points that businesses should take note of:

– In the coming years (2024 and 2025), businesses need to monitor the legislative activities of relevant authorities regarding new measures and requirements for anti-money laundering, which may increase compliance obligations and costs for businesses. Emerging sectors such as virtual assets or services related to virtual assets will also be subject to stricter regulations to ensure oversight by the Ministry of Finance and the State Bank of Vietnam regarding money laundering activities.

– Government agencies will increase both the quantity and quality of their personnel, and undertake various activities to assess, gather data, and inspect related to money laundering activities in businesses, especially entities within the scope requiring evaluation as per legal regulations. Consequently, businesses need to align their documentation, records, information data platforms, etc., to facilitate the potential activities of government agencies.