Circular 25/2025/TT-NHNN amends Circular 17/2024/TT-NHNN on opening and use of payment accounts

CIRCULAR

Amending and supplementing a number of articles of Circular No. 17/2024/TT-NHNN on the opening and use of payment accounts at payment service providers

Pursuant to the Law on the State Bank of Vietnam No. 46/2010/QH12;

Pursuant to the Law on Credit Institutions No. 32/2024/QH15;

Pursuant to the Anti-Money Laundering Law No. 14/2022/QH15;

Pursuant to the Government's Decree No. 52/2024/ND-CP on cashless payment;

Pursuant to the Government’s Decree No. 19/2023/ND-CP detailing a number of articles of the Anti-Money Laundering Law;

Pursuant to the Government’s Decree No. 26/2025/ND-CP defining the functions, tasks, powers and organizational structure of the State Bank of Vietnam;

At the proposal of the Director of the Payment Department;

The Governor of the State Bank of Vietnam hereby promulgates the Circular amending and supplementing a number of articles of Circular No. 17/2024/TT-NHNN, on the opening and use of payment accounts at payment service providers.

Article 1. To amend and supplement Clause 2 of Article 7

“2. The SBV Regional Branches shall open payment accounts for units of the State Treasury, credit institutions and foreign bank branches.”.

Article 2. To amend, supplement and annul a number of points and clauses of Article 9

1. To annul Point a(iv) and Point b(iv), Clause 3, Article 9.

2. To replace the phrase “State Bank Branches” with the phrase “SBV Regional Branches” in Clauses 3 and 4, Article 9.

Article 3. To amend and supplement a number of points and clauses of Article 12

1. To amend and supplement Point a, Clause 2, Article 12 as follows:

“a) For an individual who is a Vietnamese citizen: Citizen identity card, identity card or electronic identity card or birth certificate for persons under 14 years of age who have not yet been issued an identity card;”.

2. To amend and supplement Point c(i), Clause 2, Article 12 as follows:

“(i) Passport or other identity document issued by a competent foreign authority; in case of a foreign national residing in Vietnam, an entry visa, a valid document in lieu of a visa, or a document evidencing visa exemption shall be required; or”.

3. To amend and supplement Clause 3, Article 12 as follows:

“3. For institutional customers: Documents, information, and data for verification of customer identification in accordance with the Anti-Money Laundering Law, together with documents, information, and data of the lawful representative, chief accountant, or person in charge of accounting (if any), as prescribed in Clause 2 of this Article. Where the organization utilizes an electronic identification account, the bank or foreign bank branch shall not require submission of documents, information, and data already contained in such electronic identification account.”.

Article 4. To add Point c1 after Point c, Clause 1 of Article 13

“c1) Payment account number, and payment account name. The designation of the payment account name shall be as follows:

(i) For an individual’s payment account, the payment account name shall be designated in accordance with the full name stated on the customer’s identity document;

(ii) For an organization’s payment account, the payment account name shall include the name of the organization as stated on the establishment license, establishment decision, enterprise registration certificate, or documents evidencing the lawful establishment and operation;

(iii) For a joint payment account, the payment account name shall be designated by the bank or foreign bank branch so as to reflect the names of the account holders and shall not be identical to the payment account name of any other individual or organization.”.

Article 5. To amend and supplement a number of clauses of Article 15

1. To amend and supplement Clause 2, Article 15 as follows:

“2. The banks and foreign bank branches shall check the legality, validity and cross-check to ensure the correctness and accuracy of documents, information and data provided by customers and conduct verification of customer identification information in accordance with the law on anti-money laundering, and the following provisions:

a) With respect to payment account holders being individuals:

(i) Where the account holder or the representative is an individual using an identity card, electronic identity card, citizen identity card with information storage component, or electronic identification, the bank or foreign bank branch must meet the account holder or the representative of the account holder in person, check and cross-check the identity document, and match the biometric information of the account holder or the representative under Point b, Clause 1, Article 16 of this Circular;

(ii) Where the account holder or the representative is an individual using a citizen identity card without information storage component, or a birth certificate, for persons under 14 years of age without an identity card or passport, the bank or foreign bank branch must meet the account holder or the representative of the account holder in person, check and cross-check the identity document, and match the biometric information of the account holder or the representative with that displayed on the identity document;

(iii) Where the account holder is a foreign individual not present in Vietnam, the bank or foreign bank branch may verify the customer information through a third party or by hiring another organization;

(iv) Where the representative is an organization, compliance shall be in accordance with Point b of this Clause.

b) With respect to payment account holders being organizations:

(i) Where the account holder is an organization established and operating in Vietnam (except as provided at Point d of this Clause), the bank or foreign bank branch must meet the lawful representative of the account holder in person and verify such lawful representative’s information in accordance with Points a(i), a(ii), and a(iii) of this Clause;

(ii) Where the account holder is a foreign legal entity (except as provided at Point d of this Clause), the bank or foreign bank branch may verify the information of the lawful representative of the account holder through a third party or by hiring another organization, provided that such third party or organization meets the lawful representative in person and checks and cross-checks the identity document, and matches the biometric information of the lawful representative with the that displayed on his/her identity document.

c) With respect to joint payment accounts:

(i) Where the joint account holder is an individual, compliance shall be in accordance with Point a of this Clause;

(ii) Where the joint account holder is an organization, compliance shall be in accordance with Point b of this Clause.

d) Banks and foreign bank branches shall not be required to comply with Point b of this Clause with respect to the following organizations:

(i) State agencies and public non-business units;

(ii) Credit institutions and foreign bank branches;

(iii) Organizations listed in accordance with the Law on Securities;

(iv) Organizations included in the Fortune Global 500 list published by Fortune magazine in the preceding year;

(v) Other organizations selected by the bank or foreign bank branch, provided that the bank or foreign bank branch bears full responsibility for any risks arising from such selection. The list of organizations selected by the bank or foreign bank branch shall conform to the criteria prescribed in its internal regulations on opening and use of payment accounts. Banks and foreign bank branches must ensure accurate verification of customers opening accounts and bear full responsibility for identification of customers opening payment accounts at their entities.

dd) In case where a customer registers to conduct transactions via application software providing online banking services, the bank or foreign bank branch must check the telephone number information of the account holder or the account holder's representative (for individual customers), or the account holder's lawful representative (for institutional customers), to ensure that the subscriber’s information matches the information on that person’s identity document.”.

2. To add Clause 7 as follows:

“7. The provisions of Clause 2 of this Article shall not apply to the opening of payment accounts as prescribed in Articles 15a and 16 of this Circular.”.

Article 6. To add Article 15a after Article 15

“Article 15a. Opening and use of payment accounts by foreign investors being non-residents conducting indirect investment activities in Vietnam

1. A foreign investor being a non-resident (hereinafter referred to as the foreign investor) that conducts indirect investment activities in Vietnam shall authorize an institution having a depository service agreement with such foreign investor to open, close, and use a payment account at a bank or foreign bank branch. The bank or foreign bank branch shall conduct customer identification for both the foreign investor and the authorized institution in accordance with the law on anti-money laundering.

2. The opening and use of payment accounts of foreign investors for the purpose of conducting indirect investment activities in Vietnam shall comply with this Circular, applicable regulations on foreign exchange management, and the following provisions:

a) The requirement of consular legalization under Point a, Clause 6, Article 12 of this Circular shall not apply. Documents in the foreign investor's payment account opening dossier issued by a competent foreign authority must be notarized or certified in accordance with Vietnamese laws or foreign laws within 12 months up to the date the bank or foreign bank branch receives the dossier;

b) The bank or foreign bank branch shall check the legality, validity and cross-check to ensure the correctness and accuracy of documents, information and data provided by the customer and conduct verification of customer identification information in accordance with the law on anti-money laundering.

c) Provisions of Point b, Clause 1, Article 5; Clause 3, Article 19 and Point b, Clause 2, Article 21 of this Circular shall not apply.

3. Banks and foreign bank branches may utilize the SWIFT system in opening and using payment accounts for foreign investors to conduct indirect investment activities in Vietnam. The opening of payment accounts through the SWIFT system shall be carried out in accordance with this Article.”.

Article 7. To amend and supplement a number of points and clauses of Article 16

1. To amend and supplement Point c, Clause 2, Article 16 as follows:

“c) Storing and preserving complete and detailed customer identification documents, information, and data during the opening and use of payment accounts by electronic means, including customer identification information; biometric factors of the individual payment account holder, the lawful representative of the organization opening a payment account; audio, images, video recordings, and sound recordings; the telephone number registered for transactions via application software providing online banking services; the unique identification information of the transaction device; transaction logs; and the results of biometric information comparison as prescribed at Point b, Clause 1 of this Article. Information and data must be stored safely, securely, and backed up, ensuring the completeness and integrity of the data for inspection, cross-checking, account holder authentication in the course of payment account usage, settlement of inquiries, complaints, disputes, and provision of information upon request from competent authorities. The duration shall comply with the law on anti-money laundering and the law on e-transactions;”.

2. To amend and supplement Clause 3, Article 16 as follows:

“3. The opening of payment accounts by electronic means shall not apply to:

a) Joint payment accounts;

b) Individual customers as prescribed at Points b and c, Clause 1, Article 11 of this Circular.”.

Article 8. To amend and supplement a number of points and clauses of Article 17

1. To amend and supplement Point d, Clause 5, Article 17 as follows:

“d) Applying forms of electronic transaction authentication for each type of transaction in electronic payment in accordance with the State Bank's regulations on safety and security for the provision of online banking services.”

2. To add Point e, Clause 5, Article 17 as follows:

“e) Provisions of Point c, Clause 5, Article 17 of this Circular shall not apply to the following cases:

(i) A customer withdraws cash by physical card at an ATM;

(ii) A bank or a foreign bank branch debits in accordance with Point a(iv), Clause 1, Article 21 of this Circular;

(iii) A customer being an organization as prescribed at Point d, Clause 2, Article 15 of this Circular;

(iv) A customer being a foreign investor opening a payment account in accordance with Article 15a of this Circular.”.

Article 9. To amend and supplement a number of points and clauses of Article 19

1. To amend and supplement Point a(i), Clause 1, Article 19 as follows:

“(i) Measures for checking the legality and validity and for cross-checking to ensure the consistency and accuracy of documents, information, and data in the customer’s payment account opening dossiers; periodic performance of cross-checking and re-verification of customer identification information in the use of payment accounts;”.

2. To amend and supplement Point b, Clause 1, Article 19 as follows:

“b) The set of criteria for identifying payment accounts showing signs of suspected fraud, scam, or violations of law (hereinafter referred to as the set of criteria) shall at least include the signs concerning: suspicion regarding the legality or validity of papers, documents, information, or data in the payment account opening dossier; the number, value, or frequency of transactions via the payment account inconsistent with the account holder’s customer identification information (including information relating to occupation and position of the individual customer); the payment account holder or the lawful representative of the organization opening the payment account being on the warning list of competent authorities; payment accounts having payment transactions but the customer cannot be contacted. Banks and foreign bank branches must regularly review, revise, supplement, and update the set of criteria based on documents, information, and data when opening and using customers’ payment accounts;”.

3. To amend and supplement Point c(iii), Clause 1, Article 19 as follows:

“(iii) Cases of refusal or suspension from cash withdrawals or payment transactions by electronic means; including the case where the payment account has payment transactions but the customer cannot be contacted via the provided contact information.”

Article 10. To amend and supplement a number of points and clauses of Article 21

1. To amend and supplement Point dd, Clause 2, Article 21 as follows:

“dd) Periodically update customer information, or upon the customer’s notification of changes in the payment account opening dossier, or where there is doubt as to the accuracy and completeness of previously collected customer identification information, ensure that the updated information is fully verified as prescribed, and promptly update and verify customer identification information when determining that a customer has a high-risk level according to the criteria issued by the bank or foreign bank branch. Safely store and retain payment account dossiers and transaction documents through the account in compliance with law;”.

2. To amend and supplement Point i, Clause 2, Article 21 as follows:

“i) Guide customers on safe use of payment accounts, use the correct account number and payment account name as specified in the agreement on opening and using the payment account when conducting payment transactions; notify and explain to customers the prohibited acts in the opening and use of payment accounts; and promptly address and handle customer inquiries and complaints in the opening and use of payment accounts in accordance with this Circular and the agreement between the payment account holder and the bank or foreign bank branch;”.

3. To amend Point k, Clause 2, Article 21 as follows:

“k) Issue, organize the implementation of, and fully comply with internal regulations on the opening and use of payment accounts at banks and foreign bank branches; guide and publicly notify regulations on dossiers, order, and procedures for opening and using payment accounts, as well as regulations on handling inquiries, complaints, and the request form for inquiry and complaint, for customers to comply. The internal regulations must include at least the following:

(i) Regulations on dossiers, order, and procedures for opening payment accounts, including cases of opening payment accounts by electronic means and the opening of payment accounts for customers who are persons with disabilities, persons lacking civil act capacity, and persons who have lost or have restricted civil act capacity;

(ii) Regulations on agreements for opening and using payment accounts and the principles of naming joint payment accounts;

(iii) Regulations on the use of payment accounts;

(iv) Regulations on handling inquiries, complaints, and request form for inquiry and complaint;

(v) Regulations on risk management in the opening and use of payment accounts in conformity with Clause 1, Article 19 of this Circular;

(vi) Criteria for selecting and the list of institutional customers as provided at Point d(v), Clause 2, Article 15.”.

Article 11. To amend and supplement Clause 2 of Article 22

“2. On a monthly basis, before the 10^th day of the month, banks and foreign bank branches shall, at the request of the State Bank, provide information on accounts suspected of involvement in fraud, scams, or violations of law, in accordance with Appendix 02 and Appendix 03 to this Circular. The provision of information shall be carried out by electronic means in accordance with the technical connection guidance provided by the State Bank.

In case of any changes to the information in Appendix 02 and Appendix 03, banks and foreign bank branches shall promptly update and send such changes to the State Bank; and shall take responsibility for the truthfulness and accuracy of the information and data provided to the State Bank.”.

Article 12. To amend and supplement Article 25

“Article 25. Implementation responsibility

Heads of units under the State Bank, credit institutions, and foreign bank branches shall organize the implementation of this Circular.

Article 13. To amend and supplement Appendices to Circular No. 17/2024/TT-NHNN

1. To replace Appendix No. 02 to Circular No. 17/2024/TT-NHNN with Appendix 02 to this Circular.

2. To add Appendix 03.

Article 14. Implementation responsibility

Heads of units under the State Bank, credit institutions, and foreign bank branches shall organize the implementation of this Circular.

Article 15. Effect

1. This Circular takes effect from August 31, 2025, except for the cases specified in Clauses 2 and 3 of this Article.

2. Provisions of Article 4 of this Circular take effect from March 01, 2026.

3. Provisions of Article 5, Article 9 and Clauses 2 and 3, Article 10 of this Circular take effect from December 01, 2025.

* All Appendices are not translated herein.