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^[1]

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

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

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

At the request of the Chief Inspector of the Banking Supervision Agency;

The Governor of the State Bank of Vietnam issues 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 subjects; 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.

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 having transactions with financial institutions and organizations and individuals engaged in related non-financial business lines.

4. Other organizations and individuals related to the anti-money laundering work.

Article 3. Criteria for and methods of assessing money laundering risks of reporting subjects

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

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

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

b/ The criterion on money laundering threats arising from business activities of reporting subjects 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 subjects 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 subjects 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 subjects; 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 subjects 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 assessing money laundering risks of reporting subjects means a 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. Reporting subjects shall themselves determine weights based on the scale, scope and particular characteristics of their 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 subjects is from January 1 to December 31 of the year of assessment and updating. Reporting subjects shall complete money laundering risk assessment and updating reports of a year by March 31 of the subsequent year at the latest.

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

1. Based on results of money laundering risk assessment and updating results specified in Article 3 of this Circular, reporting subjects shall develop and issue their own money laundering risk management processes. Money laundering risk management processes must take the form of a step-by-step process in conformity accordance with the scale, scope and particular characteristics of operations of reporting subjects so as to serve the money laundering risk management. A reporting subject’s money laundering risk management process must at least include the following contents:

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

b/ Determination and assessment of the level of impact of money laundering risks on the reporting subject;

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 subject 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/ Applicable measures corresponding to customers’ money laundering risk levels, including frequency of updating and verification of know-your-customer (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 subjects 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.

4. For customers with medium-level money laundering risks, reporting subjects shall 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 subjects 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 subject 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.

Article 5. Internal anti-money laundering regulations

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

1. KYC processes and procedures cover the collection, updating and verification of information in accordance with the anti-money laundering law and contain provisions specifying identification cases and information and updated information; decentralization of the responsibility for performance of KYC based on risk levels and scale, scope and particular characteristics of operations of reporting subjects.

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

3. Provisions on information storage and confidentiality of Articles 38 and 40 of the Anti-Money Laundering Law.

4. Provisions on the application of temporary measures specified in  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. Provisions on reporting and provision of information to the State Bank of Vietnam and competent state agencies, including provisions on reporting and information provision methods and procedures to ensure compliance with law-specified reporting time limits and contents.

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 subjects 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 subject or a person authorized by the manager 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 prevention and combat);

b/ Depending on scale, scope and particular characteristics of their operations, reporting subjects 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 subjects 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 subjects and practical situation in order to evaluate their internal anti-money laundering regulations and consider amending, supplementing and replacing them as appropriate; send their internal anti-money laundering regulations to the agency of the State Bank of Vietnam performing the anti-money laundering function and tasks (below referred to as the Anti-Money Laundering Agency) within 30 days after issuing, amending, supplementing or replacing internal anti-money laundering regulations;

c/ Annually, send internal audit reports on anti-money laundering to the Anti-Money Laundering Agency within 60 days from the last day of the fiscal year, except for reporting subjects that are not required to carry out internal audit in accordance with law;

d/ Register with the Anti-Money Laundering Agency 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 or focal persons of sections 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 Agency of changes in information specified at Point d, Clause 10 of this Article within 15 days after such changes occur.

11. Reporting subjects 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 subjects shall report on high-value transactions subject to reporting under Clause 1, Article 25 of the Anti-Money Laundering Law to the Anti-Money Laundering Agency in the form of electronic data specified in Clause 1, Article 10 of this Circular or paper report specified in Appendix I to this Circular in case they have not yet established a compatible information technology system for the reporting.

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 specified in Article 26 of the Anti-Money Laundering Law, reporting subjects shall report thereon to the Anti-Money Laundering Agency. A report shall be made in the form of paper document specified in Appendix II to this Circular or electronic data if reporting subjects have established a compatible information technology system to serve the electronic data reporting under Clause 1, Article 10 of this Circular; electronic data reporting does not apply to cases of reporting to other competent state agencies under Clause 3, Article 37 of the Anti-Money Laundering Law.

2. The reporting on suspicious transactions under Article 26 of the Anti-Money Laundering Law does not depend on money amounts involved in customers’ transactions or whether such transactions have been completed or not.

3. The Anti-Money Laundering Agency shall confirm the receipt of a suspicious transaction report by sending an email or a paper document to the individual or section specified at Point b, Clause 9, Article 5 of this Circular within 5 working days after receiving such suspicious transaction report; and discuss with the reporting subject on arising problems (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 or 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.

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 Agency 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 subjects 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 code and date;

dd/ Other information as requested by the Anti-Money Laundering Agency 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.

Article 10. E-data reporting forms and time limit

1. E-data reporting forms:

a/ Reporting subjects shall establish transmission lines and connect to the communication network of the State Bank of Vietnam via the Department of Information Technology to send their reports and provide information on anti-money laundering activities;

b/ E-data reports shall be sent via transmission lines and the communication network specified at Point a of this Clause. Such reports must comply with the Anti-Money Laundering Agency’s instruction on data format and file structure;

c/ Reporting subjects 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 to detect and warn about suspicious signs for the anti-money laundering purpose.

2. E-data reporting time limit: Reporting subjects 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 subject 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 Agency. In case a reporting subject detects information or data in the report it/he/she has sent to the Anti-Money Laundering Agency 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 Agency regarding insufficiencies or errors in its/his/her report, a reporting subject 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 Agency regarding the review and supplementation of the report, the reporting subject 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 subjects shall register in writing with the Anti-Money Laundering Agency information on the person in charge of e-data reporting, including his/her full name, position, workplace address, telephone number, email address, and notify the latter of any change in such information.

Article 11. Effect

1. This Circular takes effect on July 28, 2023, except the cases specified in Clause 2 of this Article.

2. Provisions on the process of management of money laundering risks of Clause 2 of Article 5, provisions on reporting on high-value transactions subject to reporting of Article 6, provisions on reporting on electronic funds transfer transactions of Article 9, and forms of reports on suspicious transactions specified in Appendix II to this Circular will take effect on December 1, 2023. Pending the effect of Clause 2, Article 5, Articles 6 and 9, and Appendix II to this Circular, reporting subjects shall comply with provisions on risk management process, reporting on high-value transactions subject to reporting, reporting on electronic funds transfer transactions and forms of paper reports on suspicious transactions specified in Clause 2 of Article 3a, Articles 5, 7 and 10 and Form No. 1 provided in the Governor of the State Bank of Vietnam’s Circular No. 35/2013/TT-NHNN of December 31, 2013, guiding a number of regulations on anti-money laundering (which is amended and supplemented under Clause 3, Article 1 of the Governor of the State Bank of Vietnam’s Circular No. 31/2014/TT-NHNN of November 11, 2014, amending and supplementing a number of articles of Circular No. 35/2013/TT-NHNN; and Clauses 2 and 4, Article 1 of the Governor of the State Bank of Vietnam’s Circular No. 20/2019/TT-NHNN of November 14, 2019, amending and supplementing a number of articles of Circular No. 35/2013/TT-NHNN).

3. As of the effective date of this Circular as specified in Clause 1 of this Article, the following Circulars cease to be effective:

a/ The Governor of the State Bank of Vietnam’s Circular No. 35/2013/TT-NHNN of December 31, 2013, (except the provisions on reporting on high-value transactions subject to reporting, reporting on electronic funds transfer transactions and paper forms of reports on suspicious transactions of Articles 5, 7 and 10, and Form No. 1 that cease to be effective on December 1, 2023);

b/ The Governor of the State Bank of Vietnam’s Circular No. 31/2014/TT-NHNN of November 11, 2014, (except the provisions on reporting on electronic funds transfer transactions of Clause 3, Article 1 that cease to be effective on December 1, 2023);

c/ The Governor of the State Bank of Vietnam’s Circular No. 20/2019/TT-NHNN of November 14, 2019, (except the provisions on risk management process and electronic funds transfer transactions of Clauses 2 and 4, Article 1 that cease to be effective on December 1, 2023).

Article 12. Responsibilities for organization of the implementation

1. The Chief of the Office, the Chief Inspector of the Banking Supervision Agency, the Head of the Anti-Money Laundering Agency, directors of provincial-level branches of the State Bank of Vietnam, and institutional reporting subjects shall implement this Circular.

2. Any problems arising in the course of implementation of this Circular should be promptly reported to the State Bank of Vietnam (through the Anti-Money Laundering Agency) for guidance.-

For the Governor of the State Bank of Vietnam
Deputy Governor
PHAM TIEN DUNG