Vietnamese
LuatVietnam summarizes a number of notable new provisions of Circular No. 25/2025/TT-NHNN on the opening and use of payment accounts.
- 1. Abolishment of some rights and responsibilities of the Central Banking Department of the State Bank and SBV branches
- 2. Adjustment of dossiers for opening payment accounts
- 3. Payment account names must be designated in accordance with identity documents or enterprise registration
- 4. Payment account holders must meet in person to open payment accounts
- 5. Supplementing regulations on the opening of payment accounts by foreign investors who are non-residents conducting indirect investment activities in Vietnam
- 6. Supplementing signs of suspected fraudulent or scam accounts
1. Abolishment of some rights and responsibilities of the Central Banking Department of the State Bank and SBV branches
Article 2 of Circular No. 25/2025/TT-NHNN abolishes the rights and responsibilities of the Central Banking Department of the State Bank and the State Bank branches specified in Clause 3, Article 9 of Circular No. 17/2024/TT-NHNN as follows:
Abolishing the right and responsibility that at the written request of a competent state regulator in judicial execution of a decision on administrative sanction, judgment enforcement decision, tax collection decision or other payment obligations in accordance with laws
Abolishing the right and responsibility that upon receiving the written request from a competent authority in accordance with applicable laws
In addition, to conform with the new organizational structure, Circular No. 25 also replaces the phrase “State Bank Branches” with the phrase “SBV Regional Branches”.
2. Adjustment of dossiers for opening payment accounts
Article 3 of Circular No. 25/2025/TT-NHNN adjusts the dossiers for opening payment accounts in Article 12 of Circular No. 17/2024/TT-NHNN as follows:
Documents, information, and data on identity papers of individual customers:
+ 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;”
=> The identity card (Chứng minh nhân dân) is no longer accepted for opening payment accounts.
+ For an individual who is a foreign national: 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;
=> Previously, only a passport was accepted. Now, other identity documents issued by competent foreign authorities may also be provided.
Documents, information, and data of institutional customers:
+ Supplementing the requirement to provide documents, information, and data of the chief accountant (or person in charge of accounting) (if any).
+ 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).
+ 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.
3. Payment account names must be designated in accordance with identity documents or enterprise registration
Article 4 of Circular No. 25/2025/TT-NHNN has added Point c1 after Point c, Clause 1, Article 13 of Circular No. 17/2024/TT-NHNN on the designation of payment account names as follows:
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;
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.
4. Payment account holders must meet in person to open payment accounts
Article 5 of Circular No. 25/2025/TT-NHNN has added more detailed provisions on checking the legality and validity; cross-checking to ensure the correctness and accuracy of documents, information, and data provided by customers; and verifying customer identification information.
Specifically, with respect to payment account holders being individuals:
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;
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;
With respect to payment account holders being organizations:
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;
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 that displayed on his/her identity document.
5. Supplementing regulations on the opening of payment accounts by foreign investors who are non-residents conducting indirect investment activities in Vietnam
Article 6 of Circular No. 25/2025/TT-NHNN has added Article 15a after Article 15 of Circular No. 17/2024/TT-NHNN on the opening and use of payment accounts by foreign investors who are non-residents to conduct indirect investment activities in Vietnam as follows:
A foreign investor (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.
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:
+ 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;
+ 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.
+ 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.
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.
6. Supplementing signs of suspected fraudulent or scam accounts
According to Article 9 of Circular No. 25/2025/TT-NHNN, the sign that “payment accounts have payment transactions but the customer cannot be contacted” has been added to the set of criteria for identifying payment accounts showing signs of suspected fraud, scam, or violations of law in Article 19 of Circular No. 17/2024/TT-NHNN.
These are some of the notable new provisions of Circular No. 25/2025/TT-NHNN on payment accounts that individuals and enterprises should take note of.
