Circular 09/2023/TT-NHNN guiding the Anti-Money Laundering Law

CIRCULAR

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

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Pursuant to the Law on the State Bank of Vietnam dated June 16, 2010;

Pursuant to the Anti-Money Laundering Law dated November 15, 2022;

Pursuant to the Government’s Decree No. 102/2022/ND-CP dated December 12, 2022, defining the functions, tasks, powers and organizational structure of the State Bank of Vietnam;

At the proposal of the Chief of the Banking Supervision Agency;

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 the criteria for, and methods of the assessment of money laundering risks of reporting subjects; process of management of money laundering risks and classification of customers based on levels of money laundering risks; internal regulations on anti-money laundering; reporting regime on high-value transactions subject to reporting; reporting regime on suspicious transactions; electronic money transfer transactions; reporting regime on electronic money transfer transactions; forms and time limits for reporting electronic data.

Article 2. Subjects of application

1. Financial institutions.

2. Organizations and individuals engaged in related non-financial sectors and trades.

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 sectors and trades.

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 subjects

1. Criteria for the assessment of money laundering risks of reporting subjects include money laundering risks and the appropriateness of policies and internal regulations on anti-money laundering at reporting subjects.

2. Money laundering risk criteria include the criterion of money laundering risk from the reporting subject’s business environment and the criterion of money laundering risk from the reporting subject’s business activities, specifically as follows:

a) The criterion of money laundering risk from the business environment of the reporting subject includes the risk of money laundering from the industry or field; the country or territory where the reporting subject operates according to the results of the national risk assessment on money laundering and is determined by the reporting subject;

b) The criterion of money laundering risk from business activities of the reporting subject includes the risk of money laundering from customers; the risk of money laundering from products and services provided to customers; the risk of money laundering from the methods of distributing products and services.

3. Criteria of the appropriateness of policies and internal regulations on anti-money laundering at the reporting subject include the comprehensiveness of policies and internal regulations on anti-money laundering and the effectiveness of the implementation of such internal policies and regulations, specifically as follows:

a) Comprehensiveness of policies and internal regulations on anti-money laundering at the reporting subject, including adequacy of policies and internal regulations on anti-money laundering; the degree of conformity with legal provisions on anti-money laundering; the level of conformity with the level of risk of money laundering of the reporting subject; the periodic re-evaluation of such internal policies and regulations to be consistent with changes in legal regulations and operational practices;

b) The effectiveness of the implementation of policies and internal regulations on anti-money laundering at the reporting subject, including the effectiveness of anti-money laundering measures; the level of understanding and compliance with the rules and professional standards of leaders and employees with responsibilities relating to money laundering prevention and combat; effective level of management of anti-money laundering.

4. The method of the assessment of money laundering risks of reporting subjects is the scoring method. The scoring method is implemented on the basis of scoring for each criterion specified in Clauses 2 and 3 of this Article. To be specific:

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

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

c) The weight of each criterion specified in Clauses 2 and 3 of this Article is the percentage (%) determined on the basis of the importance of each criterion in the prevention and combat of money laundering.  The reporting subject shall determine its own weight based on the size, scope and characteristics of its operation;

d) The point of money laundering risk shall be determined based on calculating the total points of each money laundering risk criterion specified at Point a of this Clause after multiplying by the weight specified at Point c of this Clause.  The risk of money laundering is low; low medium; medium; high-medium; or high, if the point is less than or equal to 1; greater than 1 and less than or equal to 2; greater than 2 and less than or equal to 3; greater than 3 and less than or equal to 4; or greater than 4 and less than or equal to 5, respectively;

dd) The point of the appropriateness of the policies and internal regulations on anti-money laundering shall be determined based on the calculation of the total points of each criterion of the appropriateness of the internal policies and regulations on money laundering prevention and combat specified at Point b of this Clause after multiplying by the weight specified at Point c of this Clause.  The appropriateness of the policies and internal regulations on anti-money laundering is high; high-medium; medium; low medium; or low if the point is less than or equal to 1; greater than 1 and less than or equal to 2; greater than 2 and less than or equal to 3; greater than 3 and less than or equal to 4; or greater than 4 and less than or equal to 5, respectively;

e) The money laundering risk point shall be determined by averaging the money laundering risk point and the point of the appropriateness of policies and internal regulations on anti-money laundering. The smaller the point, the lower the money laundering risk level:  the risk level of money laundering is low; low medium; medium; high-medium; or high, if the point is less than or equal to 1; greater than 1 and less than or equal to 2; greater than 2 and less than or equal to 3; greater than 3 and less than or equal to 4; or greater than 4 and less than or equal to 5, respectively.

5. The period for collecting information and data for assessment and updating of risk of money laundering of the reporting subject starts from January 1 to December 31 of the year of assessment and update. The reporting subject must complete the assessment report, update the risk of money laundering by March 31 of the following year.

Article 4. Process of management of money laundering risks and classification of customers based on levels of money laundering risks

1. Based on the results of assessment and updating of money laundering risks under Article 3 of this Circular, the reporting subject shall formulate and promulgate the process of management of money laundering risks at the reporting subject. The money laundering risk management process must be presented in a step-by-step manner appropriate to the size, scope and characteristics of the reporting subject to manage money laundering risks. The money laundering risk management process includes at least the following contents:

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

b) Determining and evaluating the impact of money laundering risks on the reporting subject;

c) Classifying customers according to low, medium and high risks of money laundering based on the following factors:  customers; products or services customer is using or intend to use; geographical location where the customer resides or has its head office and other factors determined and classified by the reporting subject according to the arising reality and specified in the risk management process;

d) Process to identify and assess the level of risk of money laundering before providing new products and services; existing products and services applying innovative technology;

dd) Risk management process to perform, refuse, suspend, conduct post-transaction control or review and report on suspicious transactions, for electronic money transfer transactions that are incorrect or are not complete as required;

e) Measures to be applied corresponding to the customer's levels of money laundering risk, including the frequency of updating and verifying customer identification information, the level of monitoring of customer transactions by money laundering risk levels, customer identification measures at a simplified level and enhanced measures specified in Clauses 2 and 5 of this Article.

2. For customers with low risk of money laundering, after first establishing relationships with customers, when applying customer identification 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, the reporting subject may choose to apply one or all of the following simplified-level customer identification measures:

a) Not collecting information about the purpose and nature of business relationships if through established types of transactions or business relationships, the purpose and nature of business relationships can be determined;

b) Reducing the frequency of updating customer identification information compared to customers with medium risk of money laundering;

c) Reducing the level of monitoring of customers’ transactions compared to customers with medium risk of money laundering.

3. The reporting subject may not apply simplified-level customer identification measures in case of suspicion of money laundering.

4. For customers with medium risk of money laundering, the reporting subject must apply measures to identify the customer 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 medium risk of money laundering, in addition to measures to identify the customers in accordance with the Anti-Money Laundering Law and the Government's Decree detailing a number of articles of the Anti-Money Laundering Law, the reporting subject must apply enhanced measures, including:

a) Obtaining approval of the management authority at least one level higher than the approving authority applicable to customers with medium risk of money laundering, regarding the establishment or continuation of the business relationship with high-risk customers;

b) Additionally collecting, updating and verifying information of individual customers to serve the assessment and management of customer risk, including at least the following information:  Average monthly income of the customer in (at least) the last 6 months before the time of assessment; contact information of the agency, organization or establishment owner where the customer works or earns major income (if any); information related to the source of money or the source of assets in the customer's transaction;

c) Additionally collecting, updating and verifying information of institutional customers to serve the assessment and management of customer risk, including at least the following information: the production, business or service line that generates major income; the total turnover in the last 2 years before the time of assessment; information related to the source of money or the source of assets in the customer's transaction;

d) Additionally collecting, updating and verifying other information (if any) serving the assessment and management of customer risks;

d) Enhancedly supervising the customer's transactions conducted through the reporting subject, business relationship by application of control measures and selection of transaction samples to inspect, ensuring that the customer’s transactions conform with the nature or purposes of business relationship between the customer and the reporting subject, and the customer's business activities; promptly detecting abnormal transactions and considering reporting suspicious transactions;

e) Increasing the frequency of updating customer identification information compared to customers with medium risk of money laundering.

Article 5. Internal regulations on anti-money laundering

Contents of internal regulations on anti-money laundering of the reporting subject 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. Process and procedures for customer identification must include the collection, update and verification of information in accordance with the law on anti-money laundering and include provisions on cases of identification, identifying and updating information; decentralization of responsibility for identifying customers according to the level of risk and the size, scope and characteristics of the reporting subject.

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

3. Regulations on information storage and confidentiality shall comply with Articles 38 and 40 of the Anti-Money Laundering 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. Regulations on personnel recruitment must include regulations to identify and select personnel to be recruited to meet job position requirements; training in basic knowledge on anti-money laundering within 6 months from the date of being recruited.

7. Contents of professional training in anti-money laundering must cover at least regulations and internal regulations on anti-money laundering; responsibility for failure to observe the law and internal regulations on anti-money laundering; methods and tricks employed by money launderers; money laundering risks related to products, services and tasks which leaders and employees are assigned to provide or perform.

8. Contents of internal audit for anti-money laundering must include examination, review and assessment of the internal control system in an independent and objective manner, observance of internal regulations and the law on anti-money laundering; and recommendation of measures to improve the effectiveness and efficiency of anti-money laundering activities; independently or in combination with other contents, but must be a separate content in the audit report. In case the reporting subject is not required to conduct internal audit as prescribed by law, the reporting subject must ensure the implementation of control over the compliance with internal regulations and the law on anti-money laundering.

9. Contents of responsibilities of individuals and departments involved in the performance of money laundering prevention and combat must ensure:

a) Assign a manager of the reporting subject or the person authorized by the manager to be responsible for organizing, directing and inspecting the compliance with the law on anti-money laundering (hereinafter referred to as the person responsible for the prevention and combat of money laundering);

b) Depending on the scale, scope and characteristics of activities, the reporting subject must establish a specialized department (group, division, department) or designate a division or appoint a person in charge of money laundering prevention and combat at the head office; assign one or several persons or departments to be responsible for the prevention and combat of money laundering at the branch or subsidiary of the reporting subject related to the prevention and combat of money laundering (if any).

10. Reporting subjects shall:

a) On an annual basis, conduct anti-money laundering training and retraining for leaders and employees related to money laundering prevention and combat (including employees assigned tasks directly related to money an asset transaction with customers);

b) On an annual basis, review and update the provisions of the law on anti-money laundering, policies and procedures of risk management in accordance with the results of the risk assessment on money laundering at the reporting subject and actual situation of implementation to evaluate internal regulations and consider amending, supplementing and replacing accordingly; send internal regulations on anti-money laundering to the agency performing the functions and tasks of preventing and combating money laundering under the State Bank of Vietnam (hereinafter referred to as the agency performing the functions and tasks of preventing and combating money laundering) within 30 days from the date of promulgation or amendment, supplementation or replacement of internal regulations on anti-money laundering;

c) On an annual basis, send an internal audit report on anti-money laundering activities at the reporting subject to the agency performing the function and task of preventing and combating money laundering within 60 days from the end of the fiscal year, except for reporting subjects who are not required to conduct internal audit as prescribed by law;

d) Register information about the full name, working address, phone number, and email address to contact when necessary of the person responsible for the prevention and combat of money laundering as prescribed at Point a, Clause 9 of this Article and the person responsible for the prevention and combat of money laundering or the focal point of the department as prescribed at Point b, Clause 9 of this Article; the email address of the department specified at Point b, Clause 9 of this Article (if any) for the agency performing the function and task of preventing and combating money laundering;

dd) Notify in writing to the agency performing the function and task of preventing and combating money laundering when the information specified at Point d, Clause 10 of this Article changes within 15 days from the date of change of information.

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

Article 6. Reporting regime on high value transactions subject to reporting

1. The reporting subject is responsible for reporting high value transactions subject to reporting in accordance with Clause 1, Article 25 of the Anti-Money Laundering Law to agencies performing the functions and tasks of preventing and combating money laundering by electronic data as prescribed in Clause 1, Article 10 of this Circular or a paper report according to Appendix I to this Circular when a compatible information technology system has not yet been established to serve the report.

2. In case a customer pays a large cash amount in foreign currency for exchange of Vietnam dong or pays a large cash amount in Vietnam dong for exchange of foreign currencies, reporting subjects shall report on cash-payment transactions only.

Article 7. Reporting regime on suspicious transactions

1. The reporting subject is responsible for reporting to the agency performing the function and task of preventing and combating money laundering when detecting suspicious transactions as prescribed in Article 26 of the Anti-Money Laundering Law.  The report shall be made in writing in accordance with Appendix II to this Circular or by electronic data when a compatible information technology system is established for electronic data reporting as prescribed in Clause 1, Article 10 of this Circular and shall not be applied in case of reporting to other competent state agencies as prescribed in Clause 3, Article 37 of the Anti-Money Laundering Law.

2. The reporting of suspicious transactions under Article 26 of the Anti-Money Laundering Law shall not depend on the amount of transaction money of the customer, whether the transaction has been completed or not.

3. Agencies performing the function and task of preventing and combating money laundering shall be responsible for confirming receipt of suspicious transaction reports by sending an email to an individual's or department's email address as prescribed at Point b, Clause 9, Article 5 of this Circular or in writing within 5 working days from the date of receipt of the suspicious transaction report; and discuss with the reporting subject the arising problems (if any).

4. Organizations and individuals providing accounting services; providing notarization services; providing legal consulting services of lawyers, law-practicing organizations must consider, collect and analyze information to report suspicious transactions when conducting business in accounting services; carrying out notarization procedures, preparing conditions on behalf of customers to perform transactions or perform transactions on behalf of customers of transferring land use rights, ownership of houses and other land-attached assets; managing customers' money, securities or other assets; managing customers' accounts at banks and securities companies; operating and managing the company; participating in the purchase and sale of businesses on behalf of customers.

Article 8. Electronic money transfer transactions

1. Financial institutions participating in electronic money transfer transactions include:

a) Creating financial institution means an organization that creates an electronic money transfer order and conducts the transfer on behalf of the creator;

b) An intermediary financial institution means an organization that receives and transmits an electronic money transfer order on behalf of the creating financial institution and the beneficiary financial institution or on behalf of another intermediary financial institution;

c) Beneficiary financial institution means an organization that receives an electronic money transfer order directly from the creating financial institution or through an intermediary financial institution and makes payments to the beneficiaries.

2. A domestic financial institution being a financial institution that creates an electronic money transfer transaction may only conduct an electronic money transfer transaction when the electronic money transfer order has complete and accurate information as prescribed by the law on non-cash payment and foreign exchange management.

3. A domestic financial institution that is an intermediary financial institution participating in an electronic money transfer transaction must:

a) Take measures to identify electronic money transfer transactions with incomplete and inaccurate information in accordance with the law on non-cash payment and foreign exchange management;

b) Take appropriate action including rejecting or suspending transactions or applying post-transaction controls or reviewing and reporting suspicious transactions for electronic money transfers with incomplete or inaccurate information in accordance with the law on non-cash payment and foreign exchange management.

4. A domestic financial institution that is a beneficiary financial institution participating in an electronic money transfer transaction must:

a) Take measures to identify incomplete and inaccurate electronic money transfer transactions in accordance with the law on non-cash payment and foreign exchange management;

b) Take appropriate action including rejecting or suspending transactions or applying post-transaction controls or reviewing and reporting suspicious transactions for electronic money transfers with incomplete or inaccurate information in accordance with the law on non-cash payment and foreign exchange management.

Article 9. Reporting regime on electronic money-transfer transactions

1. The reporting subject shall be responsible for collecting information in Clause 3 of this Article and reporting it to the agency performing the function and task of preventing and combating money laundering using electronic data as prescribed in Clause 1, Article 10 of this Circular when performing an electronic money transfer transaction in the following cases:

a) An electronic money transfer transaction where all financial institutions participating in the electronic money transfer transaction specified in Clause 1, Article 8 of this Circular are located in Vietnam (hereinafter referred to as the domestic electronic money transfer transaction) with an electronic money transfer transaction value of VND 500,000,000 (five hundred million) or more or in a foreign currency of equivalent value;

b) An electronic money transfer transaction where at least one of the financial institutions participating in the electronic money transfer transaction specified in Clause 1, Article 8 of this Circular is located in a country or territory other than Vietnam (hereinafter referred to as the international electronic money transfer transaction) with an electronic money transfer transaction value of USD 1,000 (one thousand) or more or in a foreign currency of equivalent value.

2. In case the reporting subject is an intermediary financial institution in the electronic money transfer transaction, it is not required to make a report as prescribed in Clause 1 of this Article.

3. The electronic money transfer report must contain at least the following information:

a) Information about the creating financial institution and the beneficiary, including transaction name of the organization or transaction branch; head office address (or bank code for domestic electronic money transfer transaction, SWIFT code for international electronic money transfer transaction); receiving and transferring countries;

b) Information about individual customers participating in electronic money transfer transactions includes full name, date of birth, date of birth; people’s identity card number or citizen identity number or personal identification number or passport number; entry visa number (if any); registered address of permanent residence or other current place of residence (if any); citizenship (according to transaction documents);

c) Information about institutional customers participating in electronic money transfer transactions includes full and abbreviated transaction names (if any); head office address; establishment license number or business identification number or tax identification number; the country where the head office is located;

d) Information on transactions: account number (if any); amount of money; currency; the amount to be converted into Vietnam dong (if the transaction currency is a foreign currency); transaction reasons and purposes; trading code; trading date;

dd) Other information at the request of agencies performing the function and task of preventing and combating money laundering to serve the state management of money laundering prevention and combat in each period.

4. Information on date of birth, number of people's identity card or citizen identity number or personal identification number or passport number, entry visa number (if any) specified at Point b, Clause 3 of this Article; establishment license number or enterprise code or tax identification number as prescribed at Point c, Clause 3 of this Article is optional for:

a) Beneficiaries in international electronic money transfer transactions from Vietnam to abroad;

b) Creators in international electronic money transfer transactions from other countries to Vietnam.

5. Electronic money transfer transactions not required to be reported include:

a) Money transfer transactions following transactions using debit cards, credit cards or prepaid cards for goods and service payment;

b) Money transfer and payment transactions among financial institutions of which both creators and beneficiaries are financial institutions.

Article 10. Reporting forms and time limits for electronic data reporting

1. Electronic data reporting forms:

a) The reporting subject shall establish a transmission line, connect the communication network with the State Bank of Vietnam through the Information Technology Department to send reports and information on prevention and combat of money laundering;

b) Electronic data reports shall be transmitted via transmission lines or communication networks specified at Point a of this Clause.  Electronic data reports must conform to the data format and file structure under the guidance of agencies performing the function and task of preventing and combating money laundering;

c) Reporting subjects permitted to conduct electronic money transfer must build an appropriate information technology system in service of electronic data reporting and must have a software system to scan and filter by blacklist, warning list, list of individuals with political influence specified in Clause 9, Clause 10, Article 3 and Clause 1, Article 17 of the Anti-Money Laundering Law, detecting and warning suspicious signs for the purpose of anti-money laundering.

2. Time limits for electronic data reporting: The reporting subject must send a report on a high value transaction subject to reporting, or electronic money transfer report before 16:00 of the day immediately following the day when a transaction occurs. If the day on which the report is sent is a holiday, Tet or weekend, the day for sending a report is the working day following such holiday, Tet or weekend.

3. Editing and supplementing electronic data reports:

a) When the reporting subject detects that the report is missing, he/she/it must provide a written explanation and send an additional report within 1 working day after receiving the written certification of the agency performing the function and task of preventing and combating money laundering. When the reporting subject detects that the reported information and data sent to the agency performing the function and task of preventing and combating money laundering contain errors, he/she/it must have a written explanation or an email to explain, edit and resend the report within 1 working day from the date of detection;

b) When the reporting subject receives a notice from the agency performing the function and task of preventing and combating money laundering of the report's error or deficiency, he/she/it must have a written explanation or an email to explain, supplement or edit and resend the report within 7 working days from the date of receiving the notice;

c) When the reporting subject receives a notice from a competent state agency as prescribed by law on the review and supplementation of the report, the reporting subject must notify such to the agency performing the function and task of preventing and combating money laundering and have a written explanation, send the modified or supplemented report after having written certification of the agency performing the function and task of preventing and combating money laundering.

4. Reporting subjects shall register in writing with the agency performing the function and task of preventing and combating money laundering the following information on their officers in charge of electronic reporting: full name, position, address of workplace, telephone number and email address, and shall notify in writing any change in such information or replacement of these officers.

Article 11. Effect

1. This Circular takes effect from July 28, 2023, except for provisions in Clause 2 of this Article.

2. Regulations on money laundering risk management process in Clause 2, Article 5; reporting regime on high value transactions subject to reporting in Article 6, reporting regime on electronic money-transfer transactions in Article 9 and the suspicious transaction report forms in Appendix II to this Circular take effect from December 1, 2023. During the period in which the regulations of Clause 2, Article 5; Article 6; Article 9; Appendix II to this Circular have not yet taken effect, the reporting subjects shall continue to comply with the regulations on risk management process, report on high value transactions subject to reporting, report on electronic money transfer transactions, paper form of suspicious transaction report in Clause 2, Article 3a; Article 5; Article 7; Article 10; Form No. 01 of Circular No. 35/2013/TT-NHNN dated December 31, 2013, of the Governor of the State Bank of Vietnam, guiding a number of provisions on anti-money laundering (amended and supplemented under Clause 3, Article 1 of Circular No. 31/2014/TT-NHNN dated November 11, 2014, of the Governor of the State Bank of Vietnam, amending and supplementing a number of articles of Circular No. 35/2013/TT-NHNN and Clauses 2 and 4, Article 1 of Circular No. 20/2019/TT-NHNN dated November 14, 2019, of the Governor of the State Bank of Vietnam, amending and supplementing a number of articles of Circular No. 35/2013/TT-NHNN).

3. The following Circulars cease to be effective on the date this Circular takes effect under Clause 1 of this Article:

a) Circular No. 35/2013/TT-NHNN dated December 31, 2013, of the Governor of the State Bank of Vietnam, except for regulations on reporting high value transactions subject to reporting, electronic money transfer transactions, paper suspicious transaction report forms specified in Articles 5, 7, 10 and Form No. 01 which cease to be effective from December 1, 2023;

b) Circular No. 31/2014/TT-NHNN dated November 11, 2014, of the Governor of the State Bank of Vietnam, except for regulations on reporting electronic money-transfer transactions specified in Clause 3, Article 1, which cease to be effective from December 1, 2023;

c) Circular No. 20/2019/TT-NHNN dated November 14, 2019, of the Governor of the State Bank of Vietnam, except for regulations on risk management process and electronic money-transfer transactions specified in Clauses 2 and 4, Article 1, which cease to be effective from December 1, 2023.

Article 12. Implementation responsibility

1. The Chief of the Office, Chief of the Banking Supervision Agency, heads of agencies performing the function and task of preventing and combating money laundering, heads of units under the State Bank of Vietnam and reporting shall organize the implementation of this Circular.

2. Any difficulties arising in the course of implementation should be reported to the State Bank of Vietnam (via agencies performing the function and task of preventing and combating money laundering) for instructions./.