Circular 27/2025/TT-NHNN guiding the Anti-Money Laundering Law

CIRCULAR

Guiding the implementation of a number of articles of the Anti-Money Laundering Law

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 Counter-Terrorism Law No. 28/2013/QH13;

Pursuant to the Law on Customs No. 54/2014/QH13, amended and supplemented under Law No. 90/2025/QH15;

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 Anti-Money Laundering Department.

The Governor of the State Bank of Vietnam promulgates the Circular guiding the implementation of a number of articles of the Anti-Money Laundering Law.

Article 1. Scope of regulation

This Circular provides criteria for and methods of assessing money laundering risks of reporting entities; processes of money laundering risk management and customer classification based on money laundering risk levels; internal anti-money laundering regulations; regime of reporting on high-value transactions subject to reporting; regime of reporting on suspicious transactions; electronic funds transfer transactions; regime of reporting on electronic funds transfer; and electronic data reporting forms and deadlines; threshold values and documents required to be presented to customs offices at border gates upon carrying foreign-currency or Vietnam-dong cash, negotiable instruments, precious metals, and gems in excess of prescribed limits.

Article 2. Subjects of application

1. Financial institutions.

2. Organizations and individuals engaged in related non-financial business lines.

3. Vietnamese organizations and individuals, foreign organizations, foreigners, and international organizations that have transactions with financial institutions or organizations and individuals engaged in related non-financial business lines.

4. Other organizations and individuals involved in anti-money laundering activities.

Article 3. Criteria for, and methods of the assessment of money laundering risks of reporting entities

1. Criteria for assessing money laundering risks of reporting entities include criteria on money laundering threats and criteria on conformity of internal anti-money laundering policies and regulations of reporting entities.

2. Criteria on money laundering threats include criterion on money laundering threats arising from business environment of reporting entities and criterion on money laundering threats arising from business activities of reporting entities, specifically as follows:

a) The criterion on money laundering threats arising from business environment of reporting entities covers money laundering threats arising from business lines and countries or territories of operation of reporting entities which must be based on national money laundering risk assessment results and self-determination by reporting entities;

b) The criterion on money laundering threats arising from business activities of reporting entities covers money laundering threats arising from customers; money laundering threats arising from products and services provided to customers; and money laundering threats arising from product and service distribution methods.

3. Criteria on conformity of internal anti-money laundering policies and regulations of reporting entities cover the comprehensiveness of internal anti-money laundering policies and regulations and effectiveness of the implementation of these policies and regulations, specifically as follows:

a) Comprehensiveness of internal anti-money laundering policies and regulations of reporting entities covers the adequacy of internal anti-money laundering policies and regulations; level of conformity with anti-money laundering regulations; the level of conformity with the level of money laundering risks of reporting entities; and periodical re-evaluation of those internal policies and regulations in order to make them conformable with changes in regulations and suitable to operation realities;

b) Effectiveness of the implementation of internal anti-money laundering policies and regulations by reporting entities covers the effectiveness of the implementation of anti-money laundering measures; the level of understanding and compliance with professional rules and standards of leaders and employees engaged in the anti-money laundering work; and the effectiveness of the management of the anti-money laundering work.

4. The method of the assessment of money laundering risks of reporting entities is the scoring method, that shall be implemented by calculating the score of each criterion specified in Clauses 2 and 3 of this Article, specifically as follows:

a) The score of each criterion specified in Clause 2 of this Article shall be determined on a scale of 1 to 5 on the principle that the smaller the score, the lower the money laundering threats;

b) The score of each criterion specified in Clause 3 of this Article shall be determined on a scale of 1 to 5 on the principle that the smaller the score, the higher level of conformity of internal anti-money laundering policies and regulations;

c) The weight of each criterion specified in Clauses 2 and 3 of this Article is a percentage (%) determined based on the importance of such criterion in the anti-money laundering work. The reporting entity shall determine its own weight based on the size, scope and characteristics of its operation;

d) The score for money laundering threats shall be determined by calculating the total score of each criterion on money laundering threats specified at Point a of this Clause, after being multiplied by the weight specified at Point c of this Clause. Money laundering threats are low if the total score is less than or equal to 1; medium low if the score is greater than 1 and less than or equal to 2; medium if the score is greater than 2 and less than or equal to 3; medium high if the score is greater than 3 and less than or equal to 4; and high if the score is greater than 4 and less than or equal to 5;

dd) The score for conformity of internal anti-money laundering policies and regulations shall be determined by calculating total score of each criterion on conformity of internal anti-money laundering policies and regulations specified at Point b of this Clause, after being multiplied by the weight specified at Point c of this Clause. The level of conformity of internal anti-money laundering policies and regulations will be high if the score is less than or equal to 1; medium high if the score is greater than 1 and less than or equal to 2; medium if the score is greater than 2 and less than or equal to 3; medium low if the score is greater than 3 and less than or equal to 4; and low if the score is greater than 4 and less than or equal to 5;

e) The money laundering risk score shall be determined by calculating the average of the score for money laundering threats and score for conformity of internal anti-money laundering policies and regulations. The lower the score, the lower the money laundering risk level: the money laundering risk level is low if the score is less than or equal to 1; medium low if the score is greater than 1 and less than or equal to 2; medium if the score is greater than 2 and less than or equal to 3; medium high if the score is greater than 3 and less than or equal to 4; and high if the score is greater than 4 and less than or equal to 5.

5. The period for collection of information and data to serve the assessment and updating of money laundering risks of reporting entities is from January 1 to December 31 of the year of assessment and updating. Reporting entities shall complete money laundering risk assessment and updating reports of a year by March 31 of the subsequent year at the latest.

6. Reporting entities that are foreign organizations’ branches may choose to conduct assessment and updating of money laundering risks using criteria, methods and period for collection of information and data in accordance with this Article or regulations of such foreign organizations. In case of opting to conduct the assessment and updating of money laundering risks under the regulations of foreign organizations, reporting entities must notify the State Bank of Vietnam and line ministries and agencies performing state management in their sectors, and shall be responsible for ensuring that: the applied criteria and methods conform to the recommendations of the financial action task force on anti-money laundering; the results of assessment and updating of money laundering risks are presented and reported to competent state agencies in accordance with Clause 7 of this Article.

7. Reporting entities shall report the results of assessment and updating of money laundering risks as prescribed in Clause 2, Article 15 of the Anti-Money Laundering Law to the State Bank of Vietnam and line ministries and agencies performing state management in the sectors of reporting entities, using the corresponding form provided in Appendix I to this Circular.

Article 4. Money laundering risk management process and customer classification based on money laundering risk level

1. Based on the results of assessment and updating of money laundering risks under Article 3 of this Circular, the reporting entity shall formulate and promulgate the process of management of money laundering risks at the reporting entity. Money laundering risk management processes must be prescribed by the reporting entity's competent senior manager as prescribed by law, or a person authorized by such competent senior manager; and shall take the form of a step-by-step process in conformity accordance with the scale, scope and particular characteristics of operations of the reporting entity so as to serve the money laundering risk management. The money laundering risk management process includes at least the following contents:

a) Determination of the scope and objectives of money laundering risk management activities;

b) Determination and assessment of the impact of money laundering risks on the reporting entity;

c) Classification of customers by money laundering risk levels (low, medium and high) based on the following factors: customers themselves; products and services customers are using or intend to use; geographic areas where customers reside or are headquartered and other factors determined and classified by the reporting entity itself as suitable to the reality and specified in the risk management process;

d) Process of identification and assessment of money laundering risks before the provision of new products and services or existing products and services with technological renewal;

dd) Risk management process for performance, refusal, suspension, and post-transaction control of, or review and reporting on, suspicious transactions and electronic funds transfer transactions with inaccurate or inadequate information as required;

e) Risk management process in cases where products and services are provided to customers before the completion of know-your-customer (KYC) information verification as prescribed by law, including specific conditions under which customers may use such products and services prior to the completion of KYC information verification;

g) Applicable measures corresponding to customers’ money laundering risk levels, including the contents of updating KYC information, frequency of updating and verification of KYC information, levels of monitoring customers’ transactions based on money laundering risk levels, reduced KYC measures, and enhanced measures specified in Clauses 2 and 5 of this Article.

2. For customers with a low level of money laundering risks, after establishing for the first time the relationship with the customer, when applying KYC measures in accordance with the Anti-Money Laundering Law and the Government’s Decree detailing a number of articles of the Anti-Money Laundering Law, reporting entities may choose to apply one or all of the following KYC measures at the following reduced level:

a) Not collecting information on the purpose and nature of the business relationship if through assorted transactions or established business relationships, the purpose and nature of such business relationships can be determined;

b) Reducing the frequency of updating KYC information compared to that of customers with medium-level money laundering risks;

c) Reducing the level of monitoring customers’ transactions as compared with customers with medium-level of money laundering risks.

3. Reporting subjects may not apply KYC measures at a reduced level in cases suspected of being related to money laundering, terrorist financing and financing of the proliferation of weapons of mass destruction, or in cases coinciding with scenarios or high-risk situations suspected of being related to money laundering, terrorist financing, or financing of proliferation of weapons of mass destruction as determined by the reporting entity.

4. For customers with medium risk of money laundering, the reporting entity must apply KYC measures in accordance with the Anti-Money Laundering Law and the Government's Decree detailing a number of articles of the Anti-Money Laundering Law.

5. For customers with high-level money laundering risks, in addition to applying KYC measures in accordance with the Anti-Money Laundering Law and the Government’s Decree detailing a number of articles of the Anti-Money Laundering Law, reporting entities shall apply enhanced measures, including:

a) Requiring approval from a managerial authority of at least one level higher than that required for customers with medium-level money laundering risks regarding the establishment or maintenance of business relationships, for high-risk customers;

b) Additionally collecting, updating and verifying information of individual customers to serve customer risk assessment and management, including at least the following information: the average monthly income of customers in at least 6 months before the time of assessment; contact information of agencies and organizations or owners of establishments where customers work or earn their main income (if any); and information relating to the source of money or assets in customers’ transactions;

c) Additionally collecting, updating and verifying information of institutional customers to serve the assessment and management of customer risks, including at least the following information: main revenue-generating production, business and service lines; total revenues in the last 2 years before the time of assessment; information relating to sources of money or assets in customers’ transactions;

d) Additionally collecting, updating and verifying other information (if any) to serve the customer risk assessment and management;

dd) Carrying out enhanced monitoring of customers’ transactions conducted through reporting subjects and their business relationships through the application of measures for controlling and sampling transactions for examination so as to ensure that customers’ transactions are consistent with the purpose and nature of the customers’ business relationships with the reporting entity and customers’ business operations and to promptly detect suspicious signs and review and report on suspicious transactions;

e) Increasing the frequency of updating KYC information in comparison to customers with medium-level money laundering risks.

6. Reporting entities shall identify the beneficiaries of life insurance contracts immediately after the beneficiaries are designated by policyholders and must verify information on the beneficiaries at the time of payment. Information on beneficiaries of life insurance contracts shall be one of the factors for review and classification of customers by money laundering risk levels.

Article 5. Internal regulations on anti-money laundering

Contents of internal regulations on anti-money laundering of the reporting entity specified at Points b, c, e, g, h, i and k, Clause 1, Article 24 of the Anti-Money Laundering Law are prescribed as follows:

1. KYC processes and procedures shall be implemented on a risk-based approach, including the collection, updating, and verification of information in accordance with the law on anti-money laundering, the decentralization of responsibilities for KYC performance according to risk levels and in conformity with the scale, scope, and particular characteristics of operations of the reporting entity, with the following contents:

a) Cases where KYC must be conducted and the collection and updating of KYC information, including the case of identification for customers without accounts, or with accounts but having had no transactions for six consecutive months prior to conducting a transaction or multiple transactions with a total value of VND 400,000,000 or more, or an equivalent value in foreign currency, within one day, except for transactions of account closure or withdrawal of savings interest, repayment of credit card debts, repayment of credit extensions to financial institutions, periodic or scheduled payments registered with financial institutions, transactions of withdrawing interest from securities investment or bond investment activities;

b) Verification of KYC information in accordance with Articles 12, 13, and 14 of the Anti-Money Laundering Law; the regulations on verification of KYC information shall include verification of information on customers’ beneficial owners from reliable information sources;

c) Regulations on KYC information with respect to authorized representatives or legal representatives of customers (if any), including the case where the representative acts on behalf of the customer in legal arrangements;

d) Regulations on KYC information in cases where the customer is an organization as prescribed in Article 10 of the Anti-Money Laundering Law. In such cases, the reporting entity shall collect information on the founders as prescribed. Where it is impossible to collect information on the founders due to divestment, death, dissolution, or inability to obtain sufficient information, the reporting entity must clearly state the reasons for not being able to collect such information during the process of customer identification and updating of customer information;

dd) Regulations on identification of customers participating in legal arrangements, with KYC information including full and abbreviated transaction names (for entrusted organizations) or names of trustees (for individual trustees); head office addresses of trustors being organizations, or nationality addresses of trustors being individuals; registration/licensing information issued by competent foreign authorities (if any); business sectors; trustors, beneficiaries, related parties (if any), and individuals with ultimate controlling rights over the trust;

e) Regulations on continuous monitoring of business relationships with customers on a risk-based approach through close monitoring of transactions corresponding to the risk level of customers during the entire period of establishment and maintenance of business relationships to ensure that transactions are consistent with collected KYC information, understanding of customers’ business operations, and sources of funds or assets in customers’ transactions; and review and assessment of KYC dossiers to ensure that KYC documents and information are regularly updated, especially for high-risk customer groups;

g) Regulations on the time limits for completion of KYC verification and the time limits for review and updating of KYC dossiers in conformity with customers’ risk levels and the law in each period, ensuring feasibility and avoiding disruption of business operations.

2. The money laundering risk management process at the reporting entity must include the contents specified in Clause 1, Article 4 of this Circular.

3. Provisions on information storage, retention period and confidentiality shall comply with Articles 38 and 40 of the Anti-Money Laundering Law, and relevant laws, including the responsibility to store information, dossiers, documents, and results of analysis and assessment (if any) of the reporting entity with respect to transactions below the threshold of reportable transactions, for timely provision to competent state agencies in accordance with law.

4. Regulations on provisional measure application shall comply with Article 44 of the Anti-Money Laundering Law and the Government's Decree detailing a number of articles of the Anti-Money Laundering Law.

5. Regulations on reporting and providing information to the State Bank of Vietnam and competent state agencies, including regulations on methods and procedures for reporting and providing information to ensure the time limit and content of the report as prescribed by law.

6. Provisions on personnel recruitment must include those on identification and selection of personnel who meet working position requirements and shall be provided with basic knowledge about money laundering prevention and combat within 6 months from the date of recruitment.

7. Contents of training and re-training in anti-money laundering operation, including anti-money laundering law and internal anti-money laundering regulations; liability for failure to implement anti-money laundering regulations and internal anti-money laundering regulations; money laundering methods and tricks; money laundering risks related to products and services; and tasks assigned to leaders and employees.

8. Internal anti-money laundering audit covers independent and objective inspection, review and assessment of the internal control system, compliance with anti-money laundering law and internal anti-money laundering regulations; making of recommendations and proposals to improve the effectiveness and efficiency of the anti-money laundering work. Internal anti-money laundering audit may be carried out independently or in combination with other activities but shall be recorded in a separate section of audit reports. In case reporting entities are not required to carry out internal audit in accordance with law, they shall control the compliance with internal anti-money laundering regulations and anti-money laundering law.

9. Specific responsibilities of related individuals and sections in the anti-money laundering work must:

a) Assign the manager of a reporting entity or a person authorized by the senior manager as prescribed by the internal regulations to take charge of organizing, directing and inspecting the compliance with the anti-money laundering law (below referred to as person in charge of anti-money laundering);

b) Depending on scale, scope and particular characteristics of their operations, reporting entities shall establish a specialized section (team, division or department) or designate a section or person to take charge of anti-money laundering at their head offices; and assign one person or several people or a section to take charge of anti-money laundering at each of its branches and subsidiaries engaged in anti-money laundering operations (if any).

10. Reporting entities shall:

a) Annually, provide professional training and re-training in anti-money laundering operations to leaders and employees engaged in anti-money laundering work (including also employees who are assigned tasks directly related to money and asset transactions with customers);

b) Annually, review and update provisions of the anti-money laundering law, and risk management policies and processes in conformity with results of the assessment of money laundering risks at reporting entities and practical situation in order to evaluate their internal regulations and consider amending, supplementing and replacing them (if necessary); send their internal anti-money laundering regulations to the Anti-Money Laundering Department, for reporting entities in the monetary and banking sector; or to the line ministries and state management agencies, for other reporting entities;

c) Annually, send internal audit reports on anti-money laundering at the reporting entities (except for those not required to carry out internal audit in accordance with law) to the Anti-Money Laundering Department within 60 days from the last day of the fiscal year, for reporting entities in the monetary and banking sector; or to the line ministries and state management agencies, for other reporting entities. If the reporting entities are not required to carry out annual internal audit as prescribed by law, they shall send reports under this provision for the year in which the audit is conducted;

d) Register with the Anti-Money Laundering Department and line ministries and state management agencies of the reporting entities information on full names, workplace addresses, contact phone numbers and email addresses of persons in charge of anti-money laundering specified at Point a, Clause 9 of this Article and persons in charge of anti-money laundering specified at Point b, Clause 9 of this Article; email addresses of the sections specified at Point b, Clause 9 of this Article (if any);

dd) Notify in writing the Anti-Money Laundering Department and line ministries and state management agencies of the reporting entities of changes in information specified at Point d, Clause 10 of this Article within 15 days after such changes occur.

11. Reporting entities that are micro-enterprises and individuals shall issue internal anti-money laundering regulations with contents specified in Clauses 1, 2, 3 and 4 of this Article and Points a and dd, Clause 1, Article 24 of the Anti-Money Laundering Law.

Article 6. Reporting regime for high-value transactions subject to reporting

1. Reporting entities shall report on high-value transactions subject to reporting (including cash transactions conducted via cash deposit machines, automated teller machines, or automatic transaction machines) under Clause 1, Article 25 of the Anti-Money Laundering Law to the Anti-Money Laundering Department in the form of electronic data specified in Clause 1, Article 10 of this Circular or paper report specified in Appendix II to this Circular in cases where the connection with the electronic data reporting system of the Anti-Money Laundering Department has not yet been established.

2. In case customers deposit large amounts of cash in foreign currencies to buy Vietnamese dong or large cash amounts in Vietnam dong to buy foreign currencies in cash, it is only required to report on cash deposit transactions.

Article 7. Reporting regime for suspicious transactions

1. Upon detecting suspicious transactions relating to money laundering or other crimes related to money laundering; terrorist financing and financing of the proliferation of weapons of mass destruction specified in Article 26 of the Anti-Money Laundering Law, reporting entities shall report thereon to the Anti-Money Laundering Department. A report shall be made in the form of electronic data under Clause 1, Article 10 of this Circular, or paper document according to the form provided in Appendix III to this Circular in cases where the connection with the electronic data reporting system of the Anti-Money Laundering Department has not yet been established. Reporting entities shall not use the suspicious transaction report form prescribed in Appendix III to this Circular for reporting to other competent state agencies as provided in Clause 3, Article 37 of the Anti-Money Laundering Law.

2. Reporting entities shall review suspicious signs as prescribed in the Anti-Money Laundering Law, the law on counter-terrorism, the law on prevention of proliferation of weapons of mass destruction, and other suspicious signs related to money laundering, terrorist financing, and financing of proliferation of weapons of mass destruction as self-identified by reporting entities on the basis of information sources, including information provided by the Anti-Money Laundering Department and competent authorities.

The reporting on suspicious transactions under Article 26 of the Anti-Money Laundering Law, the law on counter-terrorism, and the law on prevention of proliferation of weapons of mass destruction does not depend on money amounts involved in customers’ transactions or whether such transactions have been completed or not. Reporting entities shall consider reporting suspicious transactions when unable to complete KYC procedures and there is suspicion relating to money laundering or other crimes related to money laundering; terrorist financing; financing of proliferation of weapons of mass destruction.

3. The Anti-Money Laundering Department shall confirm receipt of a suspicious transaction report within 05 working days from the date of receipt of sufficient information, dossiers, and documents as prescribed; and shall discuss with the reporting entity any arising issues (if any).

4. Organizations and individuals that provide accounting services; notary services; or legal services of lawyers or law-practicing organizations shall examine, collect and analyze information so as to report on suspicious transactions when providing accounting services; carrying out notarization procedures, preparing conditions for performance of transactions or performing on behalf of customers transactions on transfer of land use rights or ownership of houses and other assets attached to land; managing customers’ money, securities or other assets; managing customers’ bank or securities accounts; performing corporate administration and management; and participate in enterprise acquisitions on behalf of customers.

Article 8. Electronic funds transfer transactions

1. Financial institutions engaged in an electronic funds transfer transaction include:

a) The originator’s financial institution, which is the institution that creates the electronic funds transfer order and conducts funds transfer on behalf of the originator;

b) Intermediary financial institution(s), which is/are the institution(s) that receive(s) and forward(s) the electronic funds transfer order on behalf of the originator’s financial institution and the beneficiary’s financial institution or on behalf of other intermediary financial institutions;

c) The beneficiary’s financial institution, which is the institution that receives the electronic funds transfer order directly from the originator’s financial institution or via intermediary financial institutions and make payments to the beneficiary.

2. Domestic financial institutions being originators’ financial institutions in electronic funds transfer transactions may conduct electronic funds transfer transactions only when electronic funds transfer orders contain sufficient and accurate information as specified in regulations on cashless payment and foreign exchange management.

3. Domestic financial institutions being intermediary financial institutions that are engaged in electronic funds transfer transactions shall:

a) Take measures to identify electronic funds transfer transactions that contain insufficient and inaccurate information as specified in regulations on cashless payment and foreign exchange management;

b) Apply appropriate handling measures such as refusing or suspending transactions or applying post-transaction control measures or considering and reporting suspicious transactions for electronic funds transfer transactions that contain insufficient and inaccurate information as specified in regulations on cashless payment and foreign exchange management.

4. Domestic financial institutions being beneficiaries’ financial institutions in electronic funds transfer transactions shall:

a) Take measures to identify electronic funds transfer transactions that contain insufficient and inaccurate information as specified in regulations on cashless payment and foreign exchange management;

b) Apply appropriate handling measures such as refusing or suspending transactions or applying post-transaction control measures or considering and reporting suspicious transactions for electronic funds transfer transactions that contain insufficient and inaccurate information as specified in regulations on cashless payment and foreign exchange management.

5. Financial institutions engaged in an electronic funds transfer transaction including originator’s financial institutions, intermediary financial institutions, and beneficiary’s financial institutions, shall ensure electronic funds transfer transaction data maintained throughout the transaction process, including information for identifying and distinguishing between international electronic funds transfer transactions and domestic electronic funds transfer transactions.

6. For transactions involving two or more originators or two or more beneficiaries, the originator’s financial institution and the beneficiary’s financial institution shall be responsible for maintaining full customer information in the transaction; the originator’s financial institution shall be responsible for providing full information on the originators and beneficiaries of such transaction to the beneficiary’s financial institution and for providing such information to intermediary financial institutions participating in the transaction upon request.

Article 9. Reporting on electronic funds transfer transactions

1. Reporting subjects shall collect information specified in Clause 3 of this Article and report thereon in the form of e-data to the Anti-Money Laundering Department under Clause 1, Article 10 of this Circular when conducting:

a) An electronic funds transfer transaction in which all the engaged financial institutions specified in Clause 1, Article 8 of this Circular are located in Vietnam (below referred to as domestic electronic funds transfer transaction) and which is valued at VND 500,000,000 (five hundred million) or more or a foreign-currency equivalent;

b) An electronic funds transfer transaction in which one of the engaged financial institutions specified in Clause 1, Article 8 of this Circular is located in a country or territory outside Vietnam (below referred to as international electronic funds transfer transaction) and which is valued at USD 1,000 (one thousand) or more or a foreign-currency equivalent.

2. Reporting entities that are intermediary financial institutions in electronic funds transfer transactions are not required to report under Clause 1 of this Article.

3. A report on an electronic funds transfer transaction must at least contain the following information:

a) Information on the originator’s and beneficiary’s financial institutions, including transaction names of the financial institutions or branches where the transaction is carried out; head office addresses (or bank codes, for domestic electronic funds transfer transactions; the Society for Worldwide Interbank Financial Telecommunication (SWIFT) codes, for international electronic fund transfers), the receiving and transferring countries;

b) Information on the individual customer engaged in the electronic funds transfer transaction: full name, date of birth; people’s identity card number, citizen identity card number, personal identification number or passport number; entry visa serial number (if any); registered permanent residence address or another current place of residence (if any); citizenship (as stated in transaction documents);

c) Information on the institutional customer engaged in the electronic funds transfer transaction: full and abbreviated transaction names (if any); head office address; enterprise establishment license number or identification number or tax identification number; the country where its head office is located;

d) Information on the transaction: account numbers (if any); money amount, currency, the amount converted into Vietnam dong (if the currency used in the transaction is a foreign currency); reasons and purposes of the transaction; transaction date; transaction code or unique reference number in case there is no account number, identification number of the originator sent by the originator’s financial institution or intermediary financial institution to ensure traceability of the transaction;

dd) Other information as requested by the Anti-Money Laundering Department serving the state management of anti-money laundering activities in each period.

4. Information on date of birth; people’s identity card number, citizen identity card number, personal identification number or passport number; visa serial number (if any) specified at Point b, Clause 3 of this Article; enterprise establishment license number or identification number or tax identification number specified at Point c, Clause 3 of this Clause is not required for:

a) Beneficiaries in international electronic funds transfer transactions from Vietnam to foreign countries/territories;

b) Originators in international electronic funds transfer transactions from foreign countries/territories to Vietnam.

5. Electronic funds transfer transactions not subject to reporting include:

a) Funds transfer transactions originating from transactions using debit cards, credit cards or pre-paid cards to make payments for goods and services;

b) Funds transfer transactions and payments between financial institutions in which both originators and beneficiaries are financial institutions acting on their own behalf.

Article 10. E-data reporting forms and time limit

1. E-data reporting forms:

a) Reporting entities shall send e-data reports according to the Anti-Money Laundering Department’s instruction on data format and file structure via the transmission lines and the communication network;

b) Reporting entities licensed to conduct electronic funds transfer transactions shall build appropriate information technology systems for e-data reporting; and develop software systems to screen and filter customers according to blacklists, warning lists and lists of political influencers specified in Clauses 9 and 10, Article 3 and Clause 1, Article 17 of the Anti-Money Laundering Law, and supervise transaction in order to detect and warn about suspicious signs for the purpose of anti-money laundering, prevention of financing terrorism or financing the proliferation of weapons of mass destruction.

2. E-data reporting time limit: Reporting entities shall send reports on high-value transactions subject to reporting and reports on electronic funds transfer transactions before 16:00 hour of the working day immediately following the date of transaction. If the date of report sending falls on a public holiday, New Year festival or weekend, such a report shall be sent on the working day following such public holiday, New Year festival or weekend.

3. Modification and supplementation of e-data reports:

a) In case a reporting entity detects the report it/he/she has sent contains insufficient information, it/he/she shall send a written explanation and a supplemented report within 1 working day after obtaining a written confirmation of the Anti-Money Laundering Department. In case a reporting entity detects information or data in the report it/he/she has sent to the Anti-Money Laundering Department is/are erroneous, it/he/she shall send a written explanation in paper form or via email, modify the report and send the modified report within 1 working day after such errors are detected;

b) Upon the receipt of a notice of the Anti-Money Laundering Department regarding insufficiencies or errors in its/his/her report, a reporting entity shall send a written explanation in paper form or via email, supplement or modify the report and send the supplemented or modified report to the latter within 7 working days after receiving such notice;

c) Upon the receipt of a notice of the Anti-Money Laundering Department regarding the review and supplementation of the report, the reporting entity shall inform the latter and send a written explanation and the modified or supplemented report to the latter after obtaining its written confirmation.

4. Reporting entities shall register in writing with the Anti-Money Laundering Department the following information on their officers in charge of electronic reporting: his/her full name, position, workplace address, telephone number, email address, and notify the latter of any change in such information.

Article 11. Value of foreign-currency or Vietnam-dong cash, precious metals, gems and negotiable instruments subject to customs declaration at border gates upon persons’ exit or entry, and papers to be produced to border-gate customs offices by persons on exit who carry foreign-currency or Vietnam-dong cash, precious metals and gems

1. The value of precious metals (except gold) and gems is VND 400,000,000 (four hundred million), specifically:

a) Precious metals (except gold) include silver, platinum, silver or platinum fine-art articles and jewelries; and alloys containing silver or platinum;

b) Gems include diamond, ruby, sapphire and emerald.

2. Value of negotiable instruments: VND 400,000,000 (four hundred million).

3. Value of foreign-currency or Vietnam-dong cash and gold subject to customs declaration at border gates upon persons’ exit or entry shall comply with applicable regulations of the State Bank of Vietnam on carrying foreign-currency or Vietnam-dong cash, and gold upon exit or entry.

4. Papers to be produced to border-gate customs offices by persons on exit, who carry foreign-currency or Vietnam-dong cash, precious metals and gems subject to customs declaration:

a) In case a person carries precious metals (excluding gold) and gems upon exit:

(i) Invoices of enterprises or organizations licensed to trade in precious metals (excluding gold) and gems; and other papers proving the lawful origin of precious metals (excluding gold) and gems in case of having no invoices from such enterprises or organizations;

(ii) Papers to be produced to border-gate customs offices must be originals or certified copies in accordance with law;

(iii) Where invoices or papers proving the lawful origin are in a foreign language, a certified Vietnamese translation shall be required in accordance with law.

b) In case a person carries foreign-currency, Vietnam-dong cash, or gold at a value threshold subject to customs declaration at border gates, the relevant documents to be produced to the customs offices shall comply with the applicable regulations of the State Bank of Vietnam on carrying foreign-currency, Vietnam-dong cash, and gold upon exit or entry.

Article 12. Implementation responsibility

The Chief of Office, Director of the Anti-Money Laundering Department, Heads of units affiliated to the State Bank, and institutional reporting entities shall implement this Circular.

Article 13. Effect

1. This Circular takes effect from November0 1, 2025, except for provisions in Clauses 2 and 3 of this Article.

2. Reporting entities shall continue to comply with applicable provisions on internal regulations and risk management process in accordance until the end of December 31, 2025.

From January 01, 2026, reporting entities shall complete the modification and updating of internal regulations and risk management process in compliance with this Circular.

3. Provisions specified at Point b, Clause 1, Article 10 of this Circular take effect from January 01, 2026.

4. Circular No. 09/2023/TT-NHNN dated July 28, 2023, of the Governor of the State Bank, guiding the implementation of a number of articles of the Anti-Money Laundering Law, ceases to be effective from the effective date of this Circular./.