Circular 39/2025/TT-NHNN opening and use of overseas foreign-currency accounts of institutional residents

CIRCULAR

Prescribing the opening and use of overseas foreign-currency accounts of institutional residents

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

Pursuant to the Law No. 32/2024/QH15 on Credit Institutions, which was amended and supplemented by the Law No. 96/2025/QH15;

Pursuant to the Ordinance No. 28/2005/PL-UBTVQH11 on Foreign Exchange, which was amended and supplemented by the Ordinance No. 06/2013/UBTVQH13;

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;

Pursuant to the Government’s Decree No. 70/2014/ND-CP detailing a number of articles of the Ordinance on Foreign Exchange and the Ordinance Amending and Supplementing a Number of Articles of the Ordinance on Foreign Exchange;

At the proposal of the Director of the Foreign Exchange Management Department;

The Governor of the State Bank of Vietnam promulgates the Circular prescribing the opening and use of overseas foreign-currency accounts of institutional residents.

Chapter I

GENERAL PROVISIONS

Article 1. Scope of regulation and subjects of application

This Circular prescribes the opening and use of overseas foreign-currency accounts of institutional residents, including:

1. Credit institutions and foreign bank branches licensed to conduct foreign exchange operations (below referred to as licensed credit institutions).

2. Economic organizations (excluding credit institutions).

3. Other organizations, including Vietnamese state agencies, armed forces units, political organizations, socio-political organizations, socio-political-professional organizations, social organizations, socio-professional organizations, social funds, and charity funds operating in Vietnam.

Article 2. Opening and use of overseas foreign-currency accounts by licensed credit institutions

1. Licensed credit institutions conducting overseas foreign exchange operations under licenses granted by the State Bank of Vietnam (below referred to as the State Bank) may open and use overseas foreign-currency accounts for conducting foreign exchange operations as approved by the State Bank and prescribed by laws of host countries where they open the accounts; they are not required to apply for licenses for opening and use of overseas foreign-currency accounts under this Circular.

2. For borrowing foreign loans in accordance with current law regulations, licensed credit institutions may open and use overseas foreign-currency accounts under contracts or agreements signed with lenders that request the opening of overseas foreign-currency accounts, and under laws of host countries where they open the accounts for borrowing foreign loans; they are not required to apply for licenses for opening and use of overseas foreign-currency accounts under this Circular.

3. After obtaining the State Bank’s licenses for opening and use of overseas foreign-currency accounts (below referred to as licenses), licensed credit institutions may open and use such accounts under the licenses and license modification decisions (if any), this Circular and laws of host countries where they open the accounts in order to:

a) Meet the conditions for grant of licenses for establishment and operation of their overseas representative offices, branches and wholly owned banks in accordance with laws of host countries;

b) Serve the operation of their overseas representative offices.

Article 3. Opening and use of overseas foreign-currency accounts by residents being economic organizations

After obtaining the State Bank’s licenses, economic organizations may open and use overseas foreign-currency accounts under the licenses and license modification decisions (if any), this Circular and laws of host countries where they open the accounts in the following cases:

1. Economic organizations may open and use overseas foreign-currency accounts in order to meet the conditions for grant of licenses for establishment and operation of their branches and representative offices in accordance of laws of host countries.

2. Economic organizations may open and use overseas foreign-currency accounts in order to serve the operation of their overseas branches and representative offices.

3. Economic organizations being enterprises, cooperatives and unions of cooperatives (below referred to as borrowers) may open and use overseas foreign-currency accounts in order to borrow foreign loans as agreed with foreign lenders. Borrowers may use an overseas foreign-currency account for one or more foreign loans.

4. Economic organizations being enterprises eligible for particularly important investment under the Government’s programs, and enterprises making investment in the form of public-private partnership (PPP) may open and use overseas foreign-currency accounts in order to fulfill their commitments, agreements, contracts with foreign partners.

5. Economic organizations may open and use overseas foreign-currency accounts in order to fulfill their commitments, agreements and contracts with foreign partners, including contracts on overseas construction; contracts on ship purchase and sale with foreign partners; and other commitments, agreements or contracts, excluding the opening and use of overseas foreign-currency accounts in order to borrow foreign loans at the request of foreign lenders.

Article 4. Opening and use of overseas foreign-currency accounts by other organizations

After obtaining the State Bank’s licenses, organizations defined in Clause 3, Article 1 of this Circular may open and use overseas foreign-currency accounts under the licenses and license modification decisions (if any), this Circular and laws of host countries where they open the accounts in order to receive foreign aid and financial donations or in other cases permitted by Vietnam’s competent agencies.

Article 5. Use period of overseas foreign-currency accounts

1. For the cases defined at Point a Clause 3 Article 2 and Clause 1 Article 3 of this Circular, the use period of an overseas foreign-currency account (hereinafter referred to as the validity period of a license) shall be considered based on the period stated in the host country’s competent agency’s document permitting the establishment and temporary operation of the organization that opens an overseas foreign-currency account in order to meet the conditions for grant of a license for establishment and operation of its overseas branch, representative office or wholly-owned bank in accordance with law of the host country.

If this agency refuses to permit such establishment and temporary operation, the license must be valid for 1 (one) year from the date of its grant.

2. For the cases specified at Point b Clause 3 Article 2 and Clause 2 Article 3 of this Circular, the validity period of a license shall be considered based on the validity period of the competent foreign agency’s document permitting the organization to establish and operate its overseas branch and representative office.

If this document does not specify the validity period of the license, this license may be valid for 3 years at most from the date of its grant.

3. For the case defined in Clause 3 Article 3 of this Circular, the validity period of a license shall be considered based on the time limit for the borrower to fulfill the repayment obligation for the foreign loan according to the foreign loan agreement (including the foreign loan amendment agreement) and the document confirming the registration or registration of change of the foreign loan (if any).

4. For the cases specified in Clause 4 and Clause 5 Article 3 of this Circular, the validity period of a license shall be considered based on the period for fulfillment of commitments or agreements, or the validity term of the contract with the foreign partner.

5. For the case defined in Article 4 of this Circular, the validity period of a license shall be considered based on the period for receipt of foreign aid or financial donations or the period stated in Vietnam’s competent agency’s document on grant of permission for other cases.

Article 6. Principles of making, submitting, receiving, and noticing results for dossiers of application for grant of licenses or issuance of license modification decisions

1. Dossiers of application for grant of licenses or issuance of license modification decisions shall be submitted directly at the Single-window section of the State Bank or via postal service to the State Bank or submitted online via the National public service portal.

2. An electronic dossier submitting online via the National public service portal may use digital signatures in accordance with the law regulations on performance of administrative procedures in the electronic environment.

In case an administrative procedure has not been provided online on the National public service portal or the National public service portal system encounters an incident or an error that prevents the receipt or exchange of information in the electronic environment, the submission, receipt, notice of results, exchange, and response to information shall be carried out via postal service or directly at the Single-window section of the State Bank.

3. The documents in an electronic dossier shall be electronic documents, or electronic copies scanned from the original (PDF file), except for the written request for grant of a license and the written request for grant of a license modification decision which is completed on the National public service portal.

4. The documents in a paper dossier shall be the originals or copies from the master registers, certified copies, copies certified by the organization as being copied from the original, or copies accompanied by the original for comparison. With regard to the case that the copies are presented together with the originals for comparison, the person in charge of comparison must sign for certification on the copies and be responsible for the accuracy between them.

5. A dossier requesting the State Bank to grant a license or issue a license modification decision shall be made in one set in Vietnamese; a foreign-language dossier shall be translated into Vietnamese and certification of signatures of the translators is required in accordance with Vietnam’s law regulations on certification, except the case specified in Clause 6 of this Article.

6. The organization shall carry out procedures for consular legalization of the competent foreign agency’s document permitting the organization to open its overseas branch or representative office in accordance with current law regulations.

Article 7. Time limit of receipt of dossiers of administrative procedures

The time limit for checking the completeness and accuracy of a dossier is 03 working days from the time the State Bank’s information system for handling of administrative procedures receives the dossier online or from the time the Single-window section of the State Bank receives the dossier directly or via postal service.

Article 8. Competence to grant, revoke or modify licenses

Director of the Foreign Exchange Management Department shall consider and decide to grant, revoke, modify licenses.

Chapter II

PROCEDURES AND DOSSIERS OF APPLICATION FOR OLICENSES

Article 9. Order and procedures for grant of licenses

1. When wishing to open overseas foreign-currency accounts, organizations (excluding licensed credit institutions defined in Clause 1, Clause 2 Article 2 of this Circular) shall make 1 set of dossier and send it to the State Bank in accordance with this Circular.

2. Within 10 working days after receiving a complete and valid dossier, the State Bank shall grant a license, made according to the form provided in Appendix III issued together with this Circular, to the organization.

If the dossier does not meet the conditions for handling, within 05 working days after receiving it, the State Bank shall request in writing the organization to supplement the dossier in accordance with this Circular.

3. If refusing to grant a license, the State Bank shall issue a written notice, clearly stating the reason.

Article 10. Dossiers of application for licenses for opening and use of overseas foreign-currency accounts

1. An application for a license, made according to the form provided in Appendix I issued together with this Circular.

2. Documents proving the purpose of opening of overseas foreign-currency accounts include:

a) For the cases prescribed at Point a Clause 3 Article 2 and Clause 1 Article 3 of this Circular:

(i) The foreign partner’s document proving that the organization must transfer money to the host country or must open an account in the host country in order to be eligible to establish and operate its overseas representative office, branch or wholly owned bank in accordance with law of the host country;

(ii) Document regarding the establishment of an overseas representative office, branch or wholly owned bank issued by the Board of Directors/Members' Council of the licensed credit institution or Decision on the establishment of an overseas branch or representative office signed by the legal representative of the economic organization;

(iii) The host country’s competent agency’s document (if any) permitting the establishment and temporary operation of an overseas representative office, branch or wholly owned bank;

b) For the cases prescribed at Point b Clause 3 Article 2 of this Decree:

(i) The competent foreign agency’s document permitting the establishment of the overseas representative office;

(ii) Document regarding the establishment of a representative office issued by the Board of Directors/Members' Council of the licensed credit institution;

(iii) A decision approving annual expenditure estimates for operation of the overseas representative office, signed by a lawful representative of the licensed credit institution;

c) For the cases prescribed in Clause 2 Article 3 of this Decree:

 (i) The competent foreign agency’s document permitting the establishment of the overseas representative office or branch;

(ii) A decision on establishment of the overseas branch or representative office, signed by a lawful representative of the economic organization;

(iii) A decision approving annual expenditures for operation of the overseas branch or representative office, signed by a lawful representative of the organization;

d) For the cases prescribed in Clause 3 Article 3 of this Decree:

An agreement regarding the account or document proving that the lender requires the borrower to open an overseas foreign-currency account to execute the foreign loan, which clearly stipulates the bank opening the account, the purpose of account opening, revenue and expenditure items on the account, and the limit or basis for limit for transfer of money abroad;

dd) For the cases prescribed in Clause 4 Article 3 of this Decree:

A contract or agreement regarding the account signed with the foreign party or a document proving that the organization opens the overseas foreign-currency account in order to implement commitments, agreements, or contracts with the foreign party;

e) For the cases prescribed in Clause 5 Article 3 of this Decree:

(i) The commitment, agreement, or contract signed with the foreign party and the foreign party’s written request for opening of an overseas foreign-currency account for fulfillment of the commitment, agreement or contract if such is not stated in this commitment, agreement or contract;

(ii) A decision approving overseas annual expense estimates, signed by a lawful representative of the organization;

(iii) A document related to the overseas contracted work in case of performance of an overseas contract: contract signed between the project owner and contractor, contract signed between the contractor and subcontractor, or another relevant paper or document;

(iv) A written explanation of overseas revenues expected to be transferred to the country, enclosed with evidencing papers (if any);

(v) The assessment record or valid temporary inspection certificate issued by a competent Vietnamese agency, or the written inspection certification issued by a competent foreign agency (in case of opening of an overseas foreign-currency account for performance of a ship purchase and sale contract with a foreign partner);

(vi) A document evidencing the origin of foreign currency amounts for performance of a ship purchase and sale contract with the foreign partner (in case of opening of an overseas foreign-currency account for performance of a ship purchase and sale contract with a foreign partner);

g) For the cases prescribed in Article 4 of this Decree:

(i) The competent Vietnamese agency’s decision on the establishment of the organization;

(ii) The foreign partner’s document on provision of financial donation or aid, requesting the opening of an overseas account for receipt of such financial donation or aid;

(iii) The competent Vietnamese agency’s document permitting the organization to receive aid or financial donation, or another relevant document (if any).

Chapter III

PROCEDURES AND DOSSIERS FOR LICENSE MODIFICATION

Article 11. Cases of amendment or addition of contents of a license

1. Cases of modification of contents of a license

a) Change of the name of the organization that opens the foreign-currency account;

b) Amendment or addition of use purposes of the account;

c) Amendment or addition of revenue and expenditure items on the account;

d) Increase (addition) of annual limit for transfer of foreign currency amounts from the country to the overseas foreign-currency account;

dd) Change of limit of the balance of the overseas foreign-currency account;

e) Extension of the use period of the overseas foreign-currency account;

g) Change of the bank where the organization opens its overseas foreign-currency account though the purpose, scope and other contents related to the overseas foreign-currency account use are kept unchanged;

h) Change of the Vietnam-based bank from which money is transferred;

i) Change of the currency of the overseas foreign-currency account.

2. Organizations (except licensed credit institutions as defined in Clauses 1 and 2, Article 2 of this Circular) shall request the State Bank to modify licenses with regard to any cases mentioned in Clause 1 of this Article.

For the cases defined at Point e Clause 1 of this Article, the organizations must submit their dossiers within at least 15 working days before the expiration date of their licenses.

Article 12. Order and procedures for requesting license modification

1. If wishing to have its license modified, an organization (excluding licensed credit institutions defined in Clause 1, Clause 2 Article 2 of this Circular) shall make 1 set of dossier and send it to the State Bank in accordance with this Circular.

2. Within 10 working days after receiving a complete and valid dossier, the State Bank shall grant a license modification decision, made according to the form provided in Appendix IV issued together with this Circular, to the organization.

If the dossier does not meet the conditions for handling, within 05 working days after receiving it, the State Bank shall request in writing the organization to supplement the dossier in accordance with this Circular.

3. If refusing to grant a license modification decision, the State Bank shall issue a written notice on refusal, clearly stating the reason.

Article 13. Dossiers of application for license modification decisions

1. A written request for issuance of a license modification decision, made according to the form provided in Appendix II issued together with this Circular.

2. Documents proving the modification of contents stated in the license, including:

a) For licenses granted under the cases prescribed at Point a Clause 3 Article 2 and Clause 1 Article 3 of this Circular:

(i) The competent foreign agency’s document permitting the establishment and operation of the overseas branch or representative office (for the cases defined at Points b, c, d and e Clause 1 Article 11 of this Circular after the competent foreign agency licenses the establishment and official operation of the overseas branch or representative office of an economic organization or licenses the establishment and official operation of the overseas representative office of a licensed credit institution);

(ii) The competent foreign agency’s document permitting extension of the temporary operation period of the overseas branch, representative office or wholly-owned bank, or a written explanation of the necessity for account use extension in case the competent foreign agency refuses to license the establishment and temporary operation of the overseas branch, representative office or wholly owned bank (for the case defined at Point e Clause 1 Article 11 of this Circular);

(iii) A decision approving annual expenditures for operation of the overseas branch or representative office (for the cases defined at Points b, c, d and e Clause 1 Article 11 of this Circular, after the competent foreign agency licenses the establishment and official operation of the overseas branch or representative office of an economic organization or licenses the establishment and official operation of the overseas representative office of a licensed credit institution);

b) For licenses granted under the cases prescribed at Point b Clause 3 Article 2 and Clause 2 Article 3 of this Circular:

(i) The competent foreign agency’s document permitting extension of the operation period of the overseas branch or representative office, except for the cases where the competent foreign agency’s document permitting the establishment and operation of the overseas branch or representative office does not state the operation period (for the case defined at Point e Clause 1 Article 11 of this Circular);

(ii) A decision approving annual expenditures for operation of the overseas branch or representative office, signed by a lawful representative of the organization (for the cases defined at Points d and dd Clause 1 Article 11 of this Circular);

(iii) Other necessary papers (if any) proving the cases defined in Clause 1 Article 11 of this Circular;

c) For licenses granted under the cases prescribed in Clause 3 Article 3 of this Circular:

(i) Agreement on modification of the contents for overseas foreign-currency account opening. In case the account is used for implementation of additional foreign loans, the organization shall submit a dossier as defined at Point d Clause 2 Article 10 of this Circular;

(ii) A report on use of the overseas foreign-currency account by the time of request for issuance of a license modification decision, enclosed with the borrower’s commitment on the report’s accuracy;

d) For licenses granted under the cases prescribed in Clause 4 Article 3 of this Circular:

 Contract/Appendix on modification of contract or modification agreement signed with the foreign party concerning to the modification of license or other documents proving the cases defined in Clause 1 Article 11 of this Circular;

dd) For licenses granted under the cases prescribed in Clause 5 Article 3 of this Circular:

(i) The commitment, agreement, or contract on modification or modification appendix signed with the foreign party concerning to the modification of license (if any);

(ii) The foreign partner’s written request (if any) for modification of the contents for overseas foreign-currency account opening, if such is not stated in the commitment, agreement or contract;

(iii) Other necessary papers (if any) proving the cases defined in Clause 1 Article 11 of this Circular;

e) For licenses granted under the cases prescribed in Article 4 of this Circular:

Necessary papers proving the cases defined in Clause 1 Article 11 of this Circular.

Article 14. Processing of dossiers of application for licenses and issuance of license modification decisions in case organizations commit administrative violations in opening and use of overseas foreign-currency accounts

In the course of processing dossiers of application for licenses or issuance of license modification decisions, if the State Bank detects that an organization has committed an administrative violation in opening and use of overseas foreign-currency accounts (including its failure to comply with the reporting regime), it shall only consider granting a license or issuing a license modification decision to the organization after the organization has fully executed the administrative violation sanctioning decision in accordance with the law regulations on handling of administrative violations in monetary and banking operations.

Chapter IV

CASES OF AUTOMATIC EXPIRATION OF LICENSES AND REVOCATION OF LICENSES

Article 15. Cases of automatic expiration of licenses and license modification decisions

1. The license and license modification decision (if any) of an organization shall automatically expire in the following cases:

a) Expiration of the license;

b) The organization fails to open the account after 01 year from the effective date of the license;

c) The contract, commitment or agreement with the foreign partner is cancelled, except where the account is being used to execute one or more effective foreign loan contracts;

d) The overseas representative office or branch ceases operation while the license has not expired yet;

dd) The written certification of registration or change registration of the borrower’s foreign loan ceases to be effective or automatically expires in accordance with the State Bank’s regulations on guiding foreign exchange management for foreign loan borrowing and repayment by enterprises, except where the account is being used to execute one or more effective foreign loan contracts;

e) The organization has been granted the license by the State Bank under the cases defined at Point a, Clause 3, Article 2 and Clause 1, Article 3 but the competent foreign agency issues a document refusing to grant the license during the term of the license;

g) The organization is separated, merged, consolidated or dissolved or goes bankrupt as prescribed by law;

h) The organization has its Certificate of Enterprise Registration, Certificate of Investment Registration, Decision on Establishment, or document of equivalent value revoked by the competent State agency.

2. Within 30 days after its license and license modification decision (if any) automatically expire under Clause 1 of this Article, the organization shall:

a) Close the overseas foreign-currency account and transfer the whole balance (if any) of the account to the country and concurrently send a report thereon accompanied by the confirmation from the foreign bank to the State Bank (the Foreign Exchange Management Department) and the State Bank’s regional branch of the locality where the organization is headquartered (for the cases specified at Points a, c, d, dd, g and h Clause 1 of this Article);

b) Close the overseas foreign-currency account and transfer back to the country the whole amount already transferred abroad under the State Bank’s license after subtracting reasonable expenses related to account opening and closure, and concurrently send a report thereon enclosed with the confirmation from the foreign bank and the domestic receiving bank’s credit note to the State Bank (the Foreign Exchange Management Department) and the State Bank’s regional branch of the locality where the organization is headquartered (for the case specified at Point e Clause 1 of this Article).

Article 16. Revocation of licenses and license modification decisions

1. The State Bank shall revoke an organization’s license for opening and use of overseas foreign-currency account in case the person competent to handle administrative violations in monetary and banking operations requests a competent agency to do so as a remedial measure.

2. Within 10 working days after receiving the competent person’s request for license revocation defined in Clause 1 of this Article, the State Bank shall issue a decision to revoke the license and license modification decisions (if any) of the organization (hereinafter referred to as license revocation decision), made according to the form provided in Appendix VI issued together with this Circular.

The organization’s license and license modification decisions (if any) shall cease to be valid on the effective date of the license revocation decision.

3. The State Bank shall send the license revocation decision to the organization for implementation; and send a copy of this document to the State Bank’s regional branch of the locality where the organization is headquartered and to the licensed credit institution where the organization executes the remittance of money to the overseas foreign-currency account for coordinated management and monitoring.

4. Within 30 days after the effective date of the license revocation decision, the organization shall:

a) Close the account and transfer the whole balance of the account to the country;

b) Send a report on account closing accompanied by the confirmation from the foreign bank to the State Bank (the Foreign Exchange Management Department) and send a copy thereof to the State Bank’s regional branch of the locality where the organization is headquartered;

c) Return the originals of license and license modification decisions (if any) to the State Bank (the Foreign Exchange Management Department).

CHAPTER V

RESPONSIBILITIES OF RELATED UNITS

Article 17. Responsibilities of relevant units and organizations

1. Responsibilities of the Foreign Exchange Management Department:

a) To receive dossiers of application for licenses or issuance of license modification decisions from organizations, consider the grant and revocation of such licenses and license modification decisions;

b) To receive and summarize reports on opening and use of overseas foreign-currency accounts of organizations;

c) To monitor, inspect, and coordinate with relevant units to handle issues arising during the implementation of this Circular.

2. Responsibilities of the State Bank’s regional branches:

a) To inspect, examine and handle the acts of violation against regulations on opening and use of overseas foreign-currency accounts of organizations in localities within their competence;

b) To urge organizations in localities to comply with the reporting regime.

3. Responsibilities of licensed credit institutions:

a) To examine and control papers and documents produced by organizations to ensure the remittance of money to overseas foreign-currency accounts of organizations complying with licenses, license modification decisions and relevant laws;

b) To archive papers and documents related to foreign exchange transactions in accordance with this Circular and relevant laws;

c) To promptly report violations defined in this Circular to the State Bank (the Foreign Exchange Management Department) for handling;

d) To strictly implement this Circular and relevant law regulations;

dd) To guide the clients to strictly implement this Circular and relevant law regulations.

4. Responsibilities of organizations (except for licensed credit institutions defined in Clauses 1 and 2 Article 2 of this Circular):

a) Before the 10^th of the first month of a quarter following the reporting quarter, to send reports on use of overseas foreign-currency accounts (made according to the form provided in Appendix V issued together with this Circular) directly or via postal service to the State Bank (the Foreign Exchange Management Department) and the State Bank’s regional branches of localities where the organizations are headquartered;

The period for closing data shall be counted from 15^th of the month preceding the reporting period to the 14^th of the last month of the quarter of the reporting period;

b) To strictly comply with licenses and license modification decisions granted and issued by the State Bank;

c) To strictly implement this Circular and relevant laws;

d) To clearly specify the money transfer purpose for money transfer orders via the overseas foreign-currency accounts related to the execution of transactions for capital withdrawal, debt repayment (principal, interest), and fee payment for the foreign loan.

dd) To take responsibility before the law for the truthfulness and accuracy of the contents in the dossier submitted to the State Bank.

Chapter VI

IMPLEMENTATION PROVISIONS

Article 18. Effect

1. This Circular takes effect on December 15, 2025 and replaces the Circular No. 20/2015/TT-NHNN prescribing the opening and use of overseas foreign-currency accounts of institutional residents.

2. Transitional provisions

a) Organizations that have been granted the licenses for opening and use of overseas foreign-currency accounts and license modification decisions (if any) by the State Bank before the effective date of this Circular shall continue to carry out according to the licenses and license modification decisions (if any) of the State Bank, except for the cases defined in Article 15 of this Circular.
 The modification of licenses shall comply with this Circular.

b) Organizations that have submitted their dossiers of application for licenses and license modification decisions before the effective date of this Circular shall continue to be considered and decided upon by the State Bank in accordance with Circular No. 20/2015/TT-NHNN.

Article 19. Responsibility for implementation organization

Heads of relevant units under the State Bank of Vietnam, licensed credit institutions, and foreign bank branches licensed for foreign exchange activities in Vietnam shall be responsible for the implementation of this Circular.