Circular No. 27/2025/TT-NHNN on guidelines for implementation of a number of articles of the Law on Anti-Money Laundering

 

CIRCULAR

ON GUIDELINES FOR IMPLEMENTATION OF A NUMBER OF ARTICLES OF THE LAW ON ANTI-MONEY LAUNDERING

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 Law on Anti-Money Laundering No. 14/2022/QH15;

Pursuant to the Law on Counter-Terrorism No. 28/2013/QH13;

Pursuant to the Customs Law No. 54/2014/QH13 amended by Law No. 90/2025/QH15;

Pursuant to Decree No. 26/2025/ND-CP of the Government defining functions, tasks, powers, and organizational structure of the State Bank of Vietnam;

At the request of the Director of the Department of Anti-Money Laundering;

The Governor of the State Bank of Vietnam hereby promulgates the Circular on guidelines for implementation of a number of articles of the Law on Anti-Money Laundering.

Article 1. Scope

This Circular provides for money laundering risk factors and assessment methods for reporting entities; procedures for money laundering risk management and customer risk rating by money laundering risk level; internal AML (anti-money laundering) policies and procedures; large cash transaction reporting regime; suspicious transaction reporting (STR) regime; wire transfer transactions; reporting regime for wire transfer transactions; format and deadline for electronic reporting; the threshold value and documents to be presented to customs authorities at border checkpoints upon carrying foreign currencies in cash, Vietnam dong in cash, negotiable instruments, precious metals, and gemstones exceeding the prescribed limit.

Article 2. Regulated entities

1. Financial institutions.

2. Organizations and individuals conducting designated non-financial businesses and professions.

3. Vietnamese organizations and individuals, foreign organizations, foreign nationals, and international organizations that have transactions with financial institutions or organizations and individuals conducting designated non-financial businesses and professions.

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

Article 3. Risk factors and assessment methods for reporting entities

1. Money laundering risk factors for reporting entities include money laundering risk factors and factors concerning the appropriateness of internal AML policies and procedures at reporting entities.

2. Money laundering risk factors include money laundering risk factors arising from the business environment of reporting entities and those arising from business activities of reporting entities, specifically as follows:

a) Money laundering risk factors arising from the business environment of reporting entities include risks from the industry, sector, countries, and territories where the reporting entities operate, as identified in the national money laundering risk assessment and by self-assessment of the reporting entities;

b) Money laundering risk factors arising from business activities of reporting entities include risks from customers; risks from products and services provided to customers; and risks from methods of distributing products and services.

3. Factors concerning the appropriateness of internal AML policies and procedures at reporting entities include the comprehensiveness of internal AML policies and procedures and the effectiveness of the implementation of such policies and procedures, specifically as follows:

a) The comprehensiveness of internal AML policies and procedures at reporting entities includes the adequacy of such policies and procedures; their conformity with AML legal provisions; their conformity with the money laundering risk level of reporting entities; and the periodic review of such policies and procedures to ensure consistency with changes in legal provisions and practical operations;

b) The effectiveness of the implementation of internal AML policies and procedures at reporting entities includes the effectiveness of implementing AML measures; the level of awareness and compliance with professional rules and standards of managers and staff with relevant responsibilities in AML; and the effectiveness of AML management activities.

4. The method for assessing money laundering risk of reporting entities is the scoring method. The scoring method is conducted on the basis of assigning scores to each factor specified in Clause 2 and Clause 3 of this Article, specifically as follows:

a) Scores for each factor prescribed in Clause 2 of this Article shall be determined on a scale from 1 to 5 on the principle that the lower the score, the lower the money laundering risk;

b) Scores for each factor prescribed in Clause 3 of this Article shall be determined on a scale from 1 to 5 on the principle that the lower the score, the higher the appropriateness of internal AML policies and procedures;

c) The weight of each factor prescribed in Clauses 2 and 3 of this Article shall be the percentage (%) determined on the basis of the importance of each factor in AML activities. Reporting entities shall self-determine the weight based on their size, scope, and business characteristics;

d) The money laundering risk score shall be determined based on the calculation of the total score of each money laundering risk factor specified at Point a of this Clause after multiplying with the weight specified at Point c of this Clause. The money laundering risk shall be low if the score is less than or equal to 1; low-to-medium 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-to-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 of the appropriateness of internal AML policies and procedures shall be determined based on the calculation of the total score of each factor on appropriateness of internal AML policies and procedures specified at Point b of this Clause after multiplying with the weight specified at Point c of this Clause. The appropriateness of internal AML policies and procedures shall be high if the score is less than or equal to 1; medium-to-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; low-to-medium 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 of money laundering risk and the score of the appropriateness of internal AML policies and procedures. The lower the score, the lower the money laundering risk: the risk shall be low if the score is less than or equal to 1; low-to-medium 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-to-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 information and data collection period for assessment and updating of money laundering risk of reporting entities shall be from January 1 to December 31 of the assessment year. Reporting entities must complete the risk assessment and update report no later than March 31 of the following year.

6. Reporting entities being branches of foreign organizations may choose to conduct risk assessment and update according to the factors, methods, and information and data collection period prescribed in this Article or according to the regulations of such foreign organizations. In case of choosing to conduct risk assessment and update in accordance with the regulations of foreign organizations, reporting entities must notify the State Bank of Vietnam and ministries or regulatory agencies in charge of their respective sectors, and shall be held accountable to ensure that �the applied factors and methods comply with the recommendations of the Financial Action Task Force (FATF) on AML; and must present the results of assessment and update of money laundering risk and report to competent regulatory agencies as prescribed in Clause 7 of this Article.

7. Reporting entities must report the results of assessment and update of money laundering risk prescribed in Clause 2 Article 15 of the Law on Anti-Money Laundering to the State Bank of Vietnam and ministries or regulatory agencies in charge of their respective sectors using the corresponding form in Appendix I enclosed with this Circular.

Article 4. Procedures for money laundering risk management and customer risk rating by money laundering risk level

1. Based on the results of assessment and update of money laundering risk as prescribed in Article 3 of this Circular, reporting entities shall formulate and promulgate procedures for money laundering risk management at reporting entities. Procedures for money laundering risk management must be approved by senior managers that have authority under the law of reporting entities or by persons authorized by such senior managers, and must be presented step by step in line with the size, scope, and characteristics of operations of reporting entities for money laundering risk management. Procedures for money laundering risk management must include at least the following:

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

b) Identifying and assessing the level of impact of money laundering risk at reporting entities;

c) Customer risk rating by money laundering risk levels of low, medium, and high based on the following factors: customers; products and services that customers are using or intend to use; geographic locations where customers reside or have their head offices; and other factors self-identified by reporting entities in line with actual circumstances and specified in risk management procedures;

d) Procedures for identifying and assessing money laundering risk before providing new products or services, or existing products and services applying innovative technology;

dd) Risk management procedures for executing, refusing, suspending, controlling after transaction, or considering and reporting suspicious transactions of wire transfer transactions with inaccurate or incomplete information as required;

e) Risk management procedures in cases where products or services are provided to customers before completion of verification of customer due diligence (CDD) information as required by law, including specific conditions under which customers may use products or services before completion of verification of CDD information;

g) Measures applied corresponding to customer money laundering risk levels, including updating CDD information, frequency of updating CDD information, verifying CDD information, monitoring customer transactions according to money laundering risk levels, simplified CDD measures, and enhanced CDD measures as prescribed in Clauses 2 and 5 of this Article.

2. For customers with low money laundering risk, after the initial establishment of a relationship, when applying CDD measures in accordance with the Law on Anti-Money Laundering and the Government�s Decree on elaboration of a number of articles of the Law on Anti-Money Laundering, reporting entities may choose to apply one or all of the following simplified CDD measures:

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

b) Reducing the frequency of updating CDD information compared with customers having medium money laundering risk;

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

3. Reporting entities shall not apply simplified CDD measures in cases of suspicion related to money laundering, terrorist financing, financing of proliferation of weapons of mass destruction, or in high-risk scenarios or situations suspected of being related to money laundering, terrorist financing, or financing of proliferation of weapons of mass destruction as identified by reporting entities.

4. For customers with medium money laundering risk, reporting entities must apply CDD measures in accordance with the Law on Anti-Money Laundering and the Government�s Decree on elaboration of a number of articles of the Law on Anti-Money Laundering.

5. For customers with high money laundering risk, in addition to applying CDD measures in accordance with the Law on Anti-Money Laundering and the Government�s Decree on elaboration of a number of articles of the Law on Anti-Money Laundering, reporting entities must apply enhanced CDD measures, including:

a) Approval of a management level at least one level higher than the level of approval applied to customers with medium money laundering risk for establishing or continuing a business relationship with high-risk customers;

b) Collecting, updating, and additionally verifying information of individual customers for the purpose of customer risk assessment and management, including at least the following: the customer�s average monthly income for at least 6 months prior to the assessment date; contact information of the agency, organization, or employer where the customer works or has the main source of income (if any); information related to the source of funds or assets in the customer�s transactions;

c) Collecting, updating, and additionally verifying information of organizational customers for the purpose of customer risk assessment and management, including at least the following: industries, business lines, and services generating main revenue; total revenue in the 2 most recent years prior to the assessment date; information related to the source of funds or assets in the customer�s transactions;

d) Collecting, updating, and additionally verifying other information (if any) serving the purpose of customer risk assessment and management;

dd) Enhanced monitoring of customer transactions conducted through reporting entities and business relationships by applying control measures and sampling transactions for review to ensure that customer transactions are consistent with the purposes and nature of the customer�s business relationship with the reporting entity and the customer�s business activities; promptly detecting suspicious indicators and considering suspicious transaction reporting (STR);

e) Increasing the frequency of updating customer due diligence (CDD) information compared with customers having medium money laundering risk.

6. Reporting entities shall identify beneficiaries of life insurance contracts immediately after such beneficiaries are designated by policyholders and must verify beneficiary information at the time of payout. Beneficiary information of life insurance contracts shall be one of the factors for reviewing and categorizing customers by money laundering risk levels.

Article 5. Internal AML policies and procedures

Internal AML policies and procedures of reporting entities as specified at Points b, c, e, g, h, i, k Clause 1 Article 24 of the Law on Anti-Money Laundering shall include the following:

1. Risk-based customer due diligence (CDD) procedures, including collecting, updating, and verifying information in accordance with AML law, delegating responsibility for CDD according to risk level and in line with the size, scope, and business characteristics of reporting entities, with the following contents:

a) Cases requiring CDD and the collection and updating of CDD information, including cases of CDD for customers without accounts or with accounts but having no transactions for 6 consecutive months prior to conducting one or more transactions for deposit, withdrawal, or transfer with a total value of 400,000,000 VND or equivalent in foreign currency or more in a day, except for account closure, interest withdrawal, credit card repayment, repayment of credit granted by financial institutions, periodic or scheduled payments registered with financial institutions, or withdrawals of interest from securities or bond investments;

b) Verification of CDD information as prescribed in Articles 12, 13, and 14 of the Law on Anti-Money Laundering; verification of CDD information shall include verification of beneficial owner information of customers from reliable sources;

c) Regulations on CDD information for authorized representatives or legal representatives of customers (if any), including cases where such representatives enter into legal arrangements on behalf of customers;

d) Regulations on CDD information where customers are organizations as prescribed in Article 10 of the Law on Anti-Money Laundering. Reporting entities shall collect information about founders as prescribed. If information on founders cannot be collected due to divestment, death, non-existence, or unavailability, reporting entities must specify the reasons for not being able to collect such information in the course of CDD or updating customer information;

dd) Regulations on CDD for customers participating in legal arrangements, CDD information shall include: full and abbreviated transaction name (for trustee organizations) or name of trustee (for individual trustees); head office address for trustee organizations, nationality address for individual trustees; registration/license information issued by foreign competent authorities (if any); field of operation; settlor, beneficiaries, related parties (if any), and individuals with ultimate control over the trust;

e) Regulations on ongoing monitoring of business relationships with customers on a risk basis by: closely monitoring transactions consistent with customer risk levels throughout the establishment and maintenance of business relationships to ensure that transactions are consistent with collected CDD information, understanding of the customer�s business activities, and the source of funds or assets in customer transactions; and reviewing and assessing CDD records to ensure that customer information and documentation are regularly updated, particularly for high-risk customers;

g) Regulations on timelines for completion of CDD verification and for review and update of CDD records, consistent with customer risk levels and applicable law in each period to ensure feasibility and avoid disrupting business activities.

2. Procedures for money laundering risk management at reporting entities must include the contents prescribed in Clause 1 Article 4 of this Circular.

3. Regulations on storage, retention period, and confidentiality of information as prescribed in Articles 38 and 40 of the Law on Anti-Money Laundering and other relevant laws, including the responsibility for storing information, records, documents, analysis, and assessment results of reporting entities (if any) for transactions below the reportable threshold, to promptly provide to competent regulatory agencies in accordance with law.

4. Regulations on the application of temporary measures as prescribed in Article 44 of the Law on Anti-Money Laundering and the Government�s Decree on elaboration of a number of articles of the Law on Anti-Money Laundering.

5. Regulations on reporting regime and provision of information to the State Bank of Vietnam and competent regulatory agencies, including regulations on methods and procedures of reporting and providing information to ensure reporting timelines and contents in accordance with law.

6. Regulations on recruitment of personnel must include provisions for identifying and selecting personnel meeting job requirements; and training in basic AML knowledge within 6 months from the date of recruitment.

7. Training and professional development in AML must include: provisions of law and internal AML policies and procedures; responsibilities for non-compliance with AML law and internal AML policies and procedures; money laundering methods and schemes; money laundering risks related to products and services; duties assigned to managers and staff.

8. Internal audit in AML must include: independent and objective review, inspection, and evaluation of the internal control system, compliance with internal policies and legal provisions on AML; recommendations and proposals to improve the effectiveness and efficiency of AML activities. Internal audit in AML may be carried out independently or combined with other contents but must be a separate section in the audit report. In cases where reporting entities are not required to perform internal audit under the law, reporting entities must ensure compliance monitoring with internal policies and AML law.

9. Responsibilities of individuals and units related to AML must ensure:

a) Assigning one manager of reporting entities or a person authorized by senior management under internal regulations to be responsible for organizing, directing, and inspecting compliance with AML law (hereinafter referred to as the AML officer);

b) Depending on the size, scope, and business characteristics, reporting entities must establish a specialized AML unit (team, division, department) or designate a unit or a person in charge of AML at the head office; assign one or more persons or units in charge of AML at branches or subsidiaries of reporting entities involved in AML operations (if any).

10. Reporting entities shall:

a) Annually provide AML training and professional development for managers and staff involved in AML (including staff directly engaged in customer cash or asset transactions);

b) Annually review and update AML law, policies, and risk management procedures consistent with money laundering risk assessment results at reporting entities and actual implementation to evaluate internal policies and consider amendments, replacements if necessary; within 10 days from the issuance, amendment, replacement of internal AML policies and procedures, send such internal AML policies and procedures to the Department of Anti-Money Laundering for reporting entities in the monetary and banking sector; and send them to ministries or regulatory agencies in charge of respective sectors for other reporting entities;

c) Annually send internal AML audit reports of reporting entities (except reporting entities not required to perform internal audit by law) within 60 days from the end of the fiscal year to the Department of Anti-Money Laundering for reporting entities in the monetary and banking sector; and to ministries or regulatory agencies in charge of respective sectors for other reporting entities. In cases where reporting entities are not required to perform annual internal audit by law, reporting entities shall send reports in accordance with this provision for the audited year;

d) Register information on the full name, work address, phone number, and email address for contact of the AML officer as prescribed at Point a Clause 9 of this Article and the AML person in charge as prescribed at Point b Clause 9 of this Article; and the email address of the unit as prescribed at Point b Clause 9 of this Article (if any) to the Department of Anti-Money Laundering and ministries or regulatory agencies in charge of respective sectors of reporting entities;

dd) Notify in writing to the Department of Anti-Money Laundering and ministries or regulatory agencies in charge of respective sectors of reporting entities when information prescribed at Point d Clause 10 of this Article changes, within 15 days from the date of change.

11. Reporting entities being micro-enterprises or individuals shall issue internal AML policies and procedures with the contents prescribed in Clauses 1, 2, 3, and 4 of this Article and Points a and dd Clause 1 Article 24 of the Law on Anti-Money Laundering.

Article 6. Large value transaction reporting regime

1. Reporting entities must report large value transactions (including cash transactions conducted via cash deposit/withdrawal machines or automated teller machines) as prescribed in Clause 1 Article 25 of the Law on Anti-Money Laundering to the Department of Anti-Money Laundering by electronic data as prescribed in Clause 1 Article 10 of this Circular, or by written reports in paper form according to Appendix II enclosed with this Circular if not yet connected to the electronic reporting system of the Department of Anti-Money Laundering.

2. In cases where customers deposit large cash foreign currencies to purchase Vietnam dong, or deposit large cash Vietnam dong to purchase foreign currencies, only the cash deposit transactions shall be reported.

Article 7. Suspicious transaction reporting (STR) regime

1. Reporting entities must report to the Department of Anti-Money Laundering upon detecting suspicious transactions related to: money laundering or other crimes related to money laundering; terrorist financing; financing of proliferation of weapons of mass destruction as prescribed in Article 26 of the Law on Anti-Money Laundering. Reports must be made by electronic data as prescribed in Clause 1 Article 10 of this Circular, or by written reports in paper form according to the corresponding form in Appendix III enclosed with this Circular if not connected to the electronic reporting system of the Department of Anti-Money Laundering. Reporting entities shall not use the STR reporting form prescribed in Appendix III of this Circular for reporting to other competent regulatory agencies as prescribed in Clause 3 Article 37 of the Law on Anti-Money Laundering.

2. Reporting entities must review suspicious indicators prescribed in the Law on Anti-Money Laundering, laws on counter-terrorism, laws on counter-proliferation of weapons of mass destruction, and other suspicious indicators 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 sources notified by the Department of Anti-Money Laundering and competent authorities.

Reporting of STR as prescribed in Article 26 of the Law on Anti-Money Laundering, laws on counter-terrorism, and laws on counter-proliferation of weapons of mass destruction shall not depend on transaction amounts or on whether such transactions have been completed. Reporting entities shall consider reporting STR when unable to complete CDD procedures and there is suspicion related to money laundering, other crimes related to money laundering, terrorist financing, or financing of proliferation of weapons of mass destruction.

3. The Department of Anti-Money Laundering shall acknowledge receipt of STR within 5 working days from the date of receipt of complete information, records, and documents as prescribed; and shall discuss with reporting entities arising issues (if any).

4. Organizations and individuals conducting accounting services; providing notarization services; providing legal services by lawyers or law-practicing organizations must review, collect, and analyze information to report STR when conducting accounting services; carrying out notarization procedures, preparing conditions for customers to conduct transactions or conducting transactions on behalf of customers for transfer of land use rights, ownership of houses, or other property on land; managing money, securities, or other assets of customers; managing customer accounts at banks or securities companies; operating or managing companies; participating in buying and selling enterprises on behalf of customers.

Article 8. Wire transfer transactions

1. Financial institutions involved in wire transfer transactions include:

a) The ordering financial institution is the institution that originates the wire transfer order and executes the transfer on behalf of the originator;

b) The intermediary financial institution is the institution that receives and transmits the wire transfer order on behalf of the ordering financial institution and the beneficiary financial institution or on behalf of another intermediary financial institution;

c) The beneficiary financial institution is the institution that receives the wire transfer order directly from the ordering financial institution or via an intermediary financial institution and makes payment to the beneficiary.

2. Domestic financial institutions acting as ordering financial institutions in wire transfer transactions shall only execute wire transfer transactions when wire transfer orders contain complete and accurate information in accordance with laws on non-cash payment and foreign exchange management.

3. Domestic financial institutions acting as intermediary financial institutions in wire transfer transactions must ensure:

a) Having measures to identify wire transfer transactions with incomplete or inaccurate information in accordance with laws on non-cash payment and foreign exchange management;

b) Applying appropriate measures, including refusal or suspension of transactions, applying post-transaction controls, or considering and reporting suspicious transactions (STR) for wire transfer transactions with incomplete or inaccurate information in accordance with laws on non-cash payment and foreign exchange management.

4. Domestic financial institutions acting as beneficiary financial institutions in wire transfer transactions must ensure:

a) Having measures to identify wire transfer transactions with incomplete or inaccurate information in accordance with laws on non-cash payment and foreign exchange management;

b) Applying appropriate measures, including refusal or suspension of transactions, applying post-transaction controls, or considering and reporting suspicious transactions (STR) for wire transfer transactions with incomplete or inaccurate information in accordance with laws on non-cash payment and foreign exchange management.

5. Financial institutions involved in wire transfer transactions, including ordering, intermediary, and beneficiary financial institutions, must ensure that payment information is maintained throughout the transaction process, including information to identify and distinguish international wire transfers and domestic wire transfers.

6. For transactions with 2 or more originators or 2 or more beneficiaries, ordering financial institutions and beneficiary financial institutions must maintain complete customer information in the transactions; the ordering financial institution must provide complete information on originators and beneficiaries in such transactions to the beneficiary financial institution and provide such information to intermediary financial institutions involved in the transaction upon request.

Article 9. Wire transfer transaction reporting regime

1. Reporting entities must collect information as prescribed in Clause 3 of this Article and report to the Department of Anti-Money Laundering by electronic data as prescribed in Clause 1 Article 10 of this Circular when conducting wire transfer transactions in the following cases:

a) Domestic wire transfers where all financial institutions involved in the wire transfer transactions as prescribed in Clause 1 Article 8 of this Circular are located in Vietnam with a transaction value of 500,000,000 VND or more, or equivalent in foreign currency;

b) Wire transfers where at least one of the financial institutions involved in the wire transfer transactions as prescribed in Clause 1 Article 8 of this Circular is located in countries or territories outside Vietnam (hereinafter referred to as international wire transfers), with a transaction value of 1,000 USD or more, or equivalent in other foreign currencies.

2. In cases where reporting entities act as intermediary financial institutions in wire transfer transactions, reporting is not required as prescribed in Clause 1 of this Article.

3. Wire transfer transaction reports must at least contain the following information:

a) Information about ordering and beneficiary financial institutions, including transaction name of the institution or branch; head office address (or bank code for domestic wire transfers, SWIFT code for international wire transfers); country of receipt and remittance;

b) Information about individual customers participating in wire transfer transactions: �full name, date of birth; identity card number or citizen identity card number or personal identification number or passport number; entry visa number (if any); registered permanent residence address or other current address (if any); nationality (according to transaction documents);

c) Information about organizational customers participating in wire transfer transactions: full and abbreviated transaction name (if any); head office address; establishment license number or enterprise code or tax code; country of head office;

d) Information about the transaction: account number (if any); transaction amount; currency; amount converted into VND (if transaction currency is foreign currency); reason and purpose of the transaction; transaction date; transaction code or unique reference number if no account number is available; identifier of the originator sent by the ordering or intermediary financial institution to ensure traceability of the transaction;

dd) Other information as required by the Department of Anti-Money Laundering to serve AML state management in each period.

4. Information on date of birth, identity card number, citizen identity card number, personal identification number, passport number, entry visa number (if any) prescribed in Point b Clause 3 of this Article; and establishment license number, enterprise code, or tax code prescribed in Point c Clause 3 of this Article shall not be mandatory for:

a) Beneficiaries in international wire transfers from Vietnam to overseas;

b) Originators in international wire transfers from overseas to Vietnam.

5. The following wire transfer transactions shall not be subject to reporting:

a) Wire transfers arising from debit card, credit card, or prepaid card transactions for payment of goods and services;

b) Wire transfers and payments between financial institutions where both the originator and the beneficiary are financial institutions conducting transactions on their own behalf.

Article 10. Form and deadline for electronic data reporting

1. Form of electronic data reporting:

a) Reporting entities shall submit electronic data reports in the correct data format and file structure via communication lines and networks in accordance with the guidance of the Department of Anti-Money Laundering;

b) Reporting entities permitted to conduct wire transfer transactions must establish appropriate information technology systems serving electronic data reporting, and must have software systems to screen and filter against blacklists, warning lists, and politically exposed person (PEP) lists as prescribed in Clauses 9 and 10 Article 3 and Clause 1 Article 17 of the Law on Anti-Money Laundering, and monitor transactions to detect and alert suspicious indicators consistent with AML, counter-terrorist financing, and counter-proliferation of weapons of mass destruction.

2. Deadline for electronic data reporting: reporting entities must submit reports on large value transactions and wire transfer transactions subject to reporting before 16:00 of the next working day immediately after the date of transaction occurrence. If the reporting day falls on a public holiday, Tet holiday, or weekend, the reporting day shall be the next working day immediately after such holiday or weekend.

3. Amendments to electronic data reports:

a) When reporting entities detect missing reports, they must provide a written explanation and submit the supplementary report within 1 working day after receiving written confirmation from the Department of Anti-Money Laundering. When reporting entities detect errors in information or data already submitted to the Department of Anti-Money Laundering, they must provide a written explanation or email, make corrections, and resubmit the report within 1 working day from the date of detection;

b) When reporting entities receive a notification from the Department of Anti-Money Laundering about deficiencies or errors in reports, they must provide a written explanation or email, supplement or correct, and resubmit the report no later than 7 working days from the date of receipt of the notification;

c) When reporting entities receive a notification from competent regulatory agencies under the law regarding review and supplementation of reports, reporting entities must notify the Department of Anti-Money Laundering and provide a written explanation, and submit corrected or supplemented reports after receiving written confirmation from the Department of Anti-Money Laundering.

4. Reporting entities must register in writing with the Department of Anti-Money Laundering the person in charge of electronic data reporting, including information on full name, position, work address, phone number, and email address, and must notify in writing when such information changes.

Article 11. Value thresholds of foreign currencies in cash, Vietnam dong in cash, precious metals, gemstones, and negotiable instruments required to be declared to customs at border gates when individuals exit or enter Vietnam, and documents to be presented to customs at border gates when individuals exit carrying foreign currencies in cash, Vietnam dong in cash, precious metals, or gemstones required to be declared to customs

1. Value thresholds for precious metals (excluding gold) and gemstones: 400,000,000 VND, including:

a) Precious metals (excluding gold), including silver, platinum, silver and platinum handicrafts and jewelry; alloys containing silver and platinum;

b) Gemstones, including diamonds, rubies, sapphires, and emeralds.

2. Value thresholds for negotiable instruments: �400,000,000 VND.

3. Value thresholds for foreign currencies in cash, Vietnam dong in cash, and gold required to be declared to customs at border gates when exiting or entering Vietnam shall comply with current regulations of the State Bank of Vietnam on carrying foreign currencies in cash, Vietnam dong in cash, and gold when exiting or entering Vietnam.

4. Documents to be presented to customs at border gates when individuals exit carrying foreign currencies in cash, Vietnam dong in cash, precious metals, or gemstones required to be declared to customs:

a) In cases where individuals exit carrying precious metals (excluding gold) or gemstones:

(i) Invoices issued by enterprises or organizations licensed to trade in precious metals (excluding gold) or gemstones; or other documents proving lawful origin of such precious metals (excluding gold) or gemstones in cases where no invoices issued by licensed enterprises or organizations are available;

(ii) Documents presented to customs at border gates must be originals or certified copies in accordance with law;

(iii) If invoices or documents proving origin are in foreign languages, they must be accompanied by certified Vietnamese translations in accordance with law.

b) In cases where individuals exit carrying foreign currencies in cash, Vietnam dong in cash, or gold exceeding the declaration thresholds at border gates, relevant documents presented to customs shall be implemented in accordance with current regulations of the State Bank of Vietnam on carrying foreign currencies in cash, Vietnam dong in cash, and gold when exiting or entering Vietnam.

Article 12. Responsibilities for implementation

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

Article 13. Entry into force

1. This Circular comes into force as of November 1, 2025, except as prescribed in Clauses 2 and 3 of this Article.

2. Reporting entities shall continue to implement internal AML policies and procedures for risk management in accordance with current regulations until December 31, 2025.

As from January 1, 2026, reporting entities shall complete adjustment and update of internal AML policies and procedures for risk management to fully comply with this Circular.

3. Provisions at Point b Clause 1 Article 10 of this Circular come into force as of January 1, 2026.

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

 

 

APPENDIX I

FORM OF MONEY LAUNDERING RISK ASSESSMENT RESULTS
(Enclosed with Circular No. 27/2025/TT-NHNN dated September 15, 2025 of the Governor of the State Bank of Vietnam)

A. APPLICABLE TO FINANCIAL INSTITUTIONS

MONEY LAUNDERING RISK ASSESSMENT REPORT
YEAR ��

Full name of the reporting entity: �������������������������.

Abbreviated name: �������������������������������.

Address: House No., street:�������������� Ward/Commune:���������������� Province/City:

Country:

Phone number:

Fax:

I. Money laundering risk assessment results

1. Assessment of money laundering risk factors

The reporting entity shall determine the weight of each factor based on its scale, scope, and business characteristics.

The score for each factor is determined on a scale from 1 to 5, on the principle that the lower the score, the lower the money laundering risk.

1.1. Money laundering risk arising from the reporting entity�s business environment

a. Assessment of money laundering risk by sector/industry based on the national money laundering risk assessment

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

b. Assessment of money laundering risk by country/territory in which the reporting entity operates, based on the national money laundering risk assessment

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

c. Assessment of money laundering risk from the business environment as identified internally by the reporting entity (if any)

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

1.2. Money laundering risk arising from the reporting entity�s business activities

a. Assessment of money laundering risk arising from customers

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

b. Assessment of money laundering risk arising from products and services provided to customers

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

c. Assessment of money laundering risk arising from product and service delivery channels

�����������������������������������������

�����������������������������������������

�����������������������������������������

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

1.3. Consolidated results of money laundering risk factor assessment

Accordingly, the reporting entity�s money laundering risk level is: High/Medium-to-high/Medium/Low-to-medium/Low

LOW if A <= 1;

LOW-TO-MEDIUM if 1 < A <= 2;

MEDIUM if 2 < A <= 3;

MEDIUM-TO-HIGH if 3 < A <= 4;

HIGH if 4 < A <= 5.

2. Assessment of the adequacy of internal AML policies and procedures at the reporting entity

The reporting entity shall determine the weight of each factor based on its scale, scope, and business characteristics.

The score for each factor in this section is determined on a scale from 1 to 5, on the principle that the lower the score, the higher the adequacy of internal AML policies and procedures.

2.1. Assessment of the comprehensiveness of internal AML policies and procedures

a. Assessment of the completeness of internal AML policies and procedures

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

b. Level of adequacy with AML legislation

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

c. Level of adequacy with the reporting entity�s money laundering risk level

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

d. Periodic review of internal AML policies and procedures

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

2.2. Effectiveness of implementing internal AML policies and procedures

a. Effectiveness of AML measures

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

b. Understanding and adherence to AML-related professional principles and standards by management and staff with AML responsibilities

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

c. Effectiveness of AML management

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

2.3. Consolidated results of assessing the adequacy of internal AML policies and procedures at the reporting entity

Thus, the adequacy level of the reporting entity�s internal AML policies and procedures is assessed as: High/Medium-to-high/Medium/Low-to-medium/Low

HIGH if B <= 1;

MEDIUM-HIGH if 1 < B <= 2;

MEDIUM if 2 < B <= 3;

LOW-MEDIUM if 3 < B <= 4;

LOW if 4 < B <= 5.

3. Consolidated money laundering risk score

II. POST-RISK ASSESSMENT PLAN

Risk management and supervision measures for money laundering risk that the reporting entity has implemented and will implement (this section is to be completed by the reporting entity based on the annual results of money laundering risk assessment and measurement, as well as relevant AML legislation).

�����������������������������������������

�����������������������������������������

�����������������������������������������

�����������������������������������������

 

 

B. APPLICABLE TO DESIGNATED NON-FINANCIAL BUSINESSES AND PROFESSIONS (DNFBPs)

MONEY LAUNDERING RISK ASSESSMENT REPORT
YEAR ��

Full name of the reporting entity: �������������������������..

Business sector: ��������������������������������.

Abbreviated name: ������������������������������������

Address: ��������������������������������������

Phone number: ������������������������������������..

Fax: ���������������������������������������.

I. Results of the money laundering risk assessment

1. Assessment of money laundering risk factors

The reporting entity shall determine the weight of each factor based on its scale, scope, and business characteristics.

The score for each factor is determined on a scale from 1 to 5, on the principle that the lower the score, the lower the money laundering risk.

1.1. Money laundering risk from the industry, sector, and countries/territories in which the reporting entity operates

a. Assessment of money laundering risk by sector/industry based on the national money laundering risk assessment

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

b. Assessment of money laundering risk by country/territory in which the reporting entity operates, based on the national money laundering risk assessment

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

1.2. Money laundering risk from customers/products and services/distribution channels

a. Assessment of money laundering risk arising from customers

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

b. Assessment of money laundering risk from products/services provided to customers

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

c. Assessment of money laundering risk arising from product and service delivery channels

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

1.6. Consolidated results of money laundering risk factor assessment

Money laundering risk level of the reporting entity: High/Medium-to-high/Medium/Low-to-medium/Low

LOW if A <= 1;

LOW-TO-MEDIUM if 1 < A <= 2;

MEDIUM if 2 < A <= 3;

MEDIUM-TO-HIGH if 3 < A <= 4;

HIGH if 4 < A <= 5.

2. Assessment of the adequacy of internal AML policies and procedures at the reporting entity

2.1. Assessment of the comprehensiveness of internal AML policies and procedures

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

2.2. Effectiveness of implementing internal AML policies and procedures

– Detailed analysis:

�����������������������������������������

�����������������������������������������

�����������������������������������������

2.3. Consolidated results of assessing the adequacy of internal AML policies and procedures at the reporting entity

Thus, the adequacy level of the reporting entity�s internal AML policies and procedures is assessed as: High/Medium-to-high/Medium/Low-to-medium/Low

HIGH if B <= 1;

MEDIUM-HIGH if 1 < B <= 2;

MEDIUM if 2 < B <= 3;

LOW-MEDIUM if 3 < B <= 4;

LOW if 4 < B <= 5.

3. Consolidated money laundering risk score

II. POST-RISK ASSESSMENT PLAN

Risk management and supervision measures for money laundering risk that the reporting entity has implemented and will implement (this section is to be completed by the reporting entity based on the annual results of money laundering risk assessment and measurement, as well as relevant AML legislation).

�����������������������������������������

�����������������������������������������

�����������������������������������������

�����������������������������������������

 

 

APPENDIX II

FORM FOR REPORTING LARGE-VALUE TRANSACTIONS
(Issued together with Circular No. 27/2025/TT-NHNN dated September 15, 2025 of the Governor of the State Bank of Vietnam)

Full name of the reporting entity:

Address:������������������������������������������������������������������������������������������� ;Phone number:

Transaction date: dd/mm/yyyy

 

Guidance:

(1) Transaction type code

C. Customer conducts a cash deposit into an account, or uses cash to purchase goods or services provided by the reporting entity, or performs cash transactions under economic contracts notarized, prepared, or executed on behalf of the customer by the reporting entity.

D. Customer conducts a cash withdrawal from an account or receives cash from the reporting entity.

(2) Full name (for individual customers); full name and abbreviation (if any) (for organizational customers).

(3) Permanent address for individual customers; head office address for organizational customers.

(4) Customer�s country/nationality (2 characters under ISO-3166).

(5) Date of birth of the individual customer.

(6) Identity card number or citizen identification number or personal identification number or passport number for individual customers.

(7) Enterprise code or tax code or establishment license number or establishment decision number for organizational customers.

(8) Type of goods or services provided by the reporting entity to the customer (e.g., apartment, land lot, gold bar, jewelry gold, etc.) that the customer purchases using cash.

(9) Quantity and unit of measure of the goods or services purchased using cash provided by the reporting entity to the customer (e.g., 100m2, 10 grams, 5 lottery tickets, gaming tokens, etc.).

(10) Transaction amount.

(11) Transaction currency code (3 characters under ISO-4217).

(12) For foreign currency transactions, the amount shall be converted into Vietnamese dong according to the reporting entity�s accounting buying and accounting selling exchange rates.

(13) Customer�s account number used in the transaction.

(14) Specify the location where the customer�s transaction with the reporting entity occurred.

(15) Specify the customer�s reason or purpose for conducting the transaction using cash to purchase goods or services provided by the reporting entity; for cash deposits, cash withdrawals, or cash received from the reporting entity, specify the transaction description.

(16) Transaction code (if any). For contracts or legal agreements, specify the contract number or legal agreement number.

(17) Additional information regarding nationality, other identification documents (if any), or other relevant information (if any).

(18) General Director/Director or an authorized person for reporting entities that are organizations; the individual or an authorized representative for reporting entities that are individuals.

Notes:

– Report each customer transaction where the total daily transaction value (for each transaction type code C or D) meets or exceeds the prescribed threshold.

– Where a customer deposits large-value foreign currency in cash to purchase Vietnamese dong, or deposits large-value Vietnamese dong in cash to purchase foreign currency in cash, only the cash deposit transaction shall be reported.

– Complete all fields in full detail. If information is not available, enter �None�.

 

APPENDIX III

FORMS OF SUSPICIOUS TRANSACTION REPORTS
(Issued together with Circular No. 27/2025/TT-NHNN dated September 15, 2025 of the Governor of the State Bank of Vietnam)

Form No. 01

Applicable to reporting entities that are credit institutions or branches of foreign banks operating in Vietnam

 

 

GUIDANCE ON COMPLETING THE SUSPICIOUS TRANSACTION REPORT:

All fields marked with (*) are mandatory and must not be left blank. Report number: formatted as abcd/yyyy, In particular: abcd is the sequential number within the financial year and yyyy is the financial year (e.g., 0010/2023).

Section I:

(1b): Reporting entity code: specified in Circular No. 17/2015/TT-NHNN dated October 21, 2015 of the Governor of the State Bank of Vietnam on the banking code system used in banking operations (as amended).

(1dd): The reporting entity shall enter the name of the transaction location for in-person transactions, or the name of the account-managing unit for online transactions. If multiple transaction locations are involved, enter the one closest in time to the suspicious transaction being reported.

(1h): Specify one official email address of the reporting entity used for receiving communications from the Anti-money Laundering Department – State Bank of Vietnam.

(2): Enter full information of the person responsible for AML and the report preparer at the unit.

(2.1a): Enter the full name (including middle name) of the person responsible for AML in lowercase with diacritics.

(2.2a): Enter the full name (including middle name) of the report preparer in lowercase with diacritics.

Section II:

If selecting �Customer holding an account at the credit institution�, all fields marked with (*) are mandatory.

If selecting �Other� (cases where the credit institution does not yet have complete information required for individuals or organizations conducting the suspicious transaction),� enter the information collected by the credit institution.

(1): Applicable to individual customers (may be left blank or removed if the customer is an organization.) Where multiple individuals conducted the suspicious transaction, insert additional detailed fields for each individual. If there are 10 or more individuals, a detailed table may be created, but all information required in this Section must be included.

(1a): Enter full name (including middle name) of the individual conducting the transaction in lowercase with diacritics.

(1b): Enter date of birth.

(1c): Determine the customer�s age based on the year of birth as of the reporting date.

(1d): If the customer�s gender cannot be determined as male or female, select �Other�.

(1h): Enter information for customers holding Vietnamese nationality.

(1i):

– Enter this information when the individual customer holding Vietnamese nationality has a current residential address different from the permanent residence address.

– Enter the address information of customers in accordance with Point b, c, d, dd Clause 1 Article 10 of the Law on Anti-money Laundering.

(1k): One or multiple personal identification documents may be selected. Enter complete details for each corresponding document.

(1m): List all existing accounts of the individual or organization at the bank. If multiple accounts exist, insert additional rows and include full details for each account (Account number/Bank/Currency/Account type/Account opening date/Account status).

(2): Applicable to organizational customers (May be left blank or removed if the customer is an individual.) Where multiple organizations conducted the suspicious transaction, insert additional detailed fields for each organization.

(2.1b): Leave blank if the organization has no foreign-language name.

(2.1l): List all existing accounts of the individual or organization at the bank. If multiple accounts exist, insert additional rows and include full details for each account (Account number/Bank/Currency/Account type/Account opening date/Account status).

(2.2) : If there are multiple legal representatives, insert additional fields and enter information for each legal representative.

(2.2a): Enter full name (including middle name) of the legal representative in lowercase with diacritics.

(2.2b): Enter date of birth.

(2.2e): Enter information for customers holding Vietnamese nationality.

(2.2g):

– Enter this information when the individual customer holding Vietnamese nationality has a current residential address different from the permanent residence address.

– Enter the address information of customers in accordance with Point b, c, d, dd Clause 1 Article 10 of the Law on Anti-money Laundering.

(2.2h): One or multiple personal identification documents may be selected. Enter complete details for each corresponding document.

(2.3) : One or multiple personal identification documents may be selected. Enter full details for each corresponding document.

(2.3a): Enter the full name (including middle name) of the authorized person in lowercase with diacritics.

(2.3b): Specify the authorized person�s relationship with the account holder� (e.g., employee, manager, accountant).

(2.3c): One or multiple personal identification documents may be selected. Enter complete details for each corresponding document.

(3): Where multiple beneficial owners exist, the reporting entity shall insert additional fields and enter full details (from a to l) for each beneficial owner.

Section III:

– Not mandatory where the reporting entity has no information on individuals or organizations related to the suspicious transaction (counterparties).

– Where the reporting entity has information on individuals or organizations related to the suspicious transaction: only fill in the fields for which information is available; it is not mandatory to complete all information fields.

(1l), (2k): List all existing accounts of the individual or organization at the bank. Where more than one account exists, additional information fields must be inserted, ensuring complete details for each account under �Account number/Bank/Currency/Account type/Account opening date/Account status�.

Section IV:

(1a): Where applicable, two conditions must be satisfied:

– Awareness that the transaction is conducted at the request of a defendant, accused person, or convicted person, based on notification from a competent state authority;

– And a reasonable basis to suspect that the assets involved in the transaction are owned by, originate from, or fall under the ownership or control of such defendant, accused person, or convicted person.

(1b1): Where applicable, specify the provision (Article and Clause) of the Law on Anti-money Laundering associated with the suspicious indicators. If multiple suspicious indicators exist, list all relevant Articles and Clauses.

(1b2): Where applicable, specify the suspicious indicators related to money laundering.

(1c): Where applicable, there must be grounds to suspect or detect that the parties related to the transaction are on a Blacklist, or a reasonable basis to suspect that the assets involved in the transaction relate to other suspicious indicators of terrorist financing as self-identified by the reporting entity.

(1d): Where applicable, there must be grounds to suspect or detect that the parties related to the transaction are on a Blacklist, or a reasonable basis to suspect that the assets involved in the transaction relate to other suspicious indicators of proliferation financing of weapons of mass destruction as self-identified by the reporting entity.

(2.1): Select one of the two cases: (a) or (b).

(2.2): Mandatory where (2.1)� is (a):

(a):� Transaction period: from the first date stated in the cash-flow tables under Section 2.2(d) to the last date stated in those cash-flow tables.

(b): Total transaction amount in original currency: the total amount stated in the cash-flow tables under Section 2.2(d) by currency.

(c): Total transaction amount converted into VND: the total amount stated in the cash-flow tables under Section 2.2(d) in Vietnamese Dong.

(d): Cash-flow tables are mandatory where the transaction has been executed.

Notes when completing cash-flow tables (inflow/outflow):

– Only enter transactions identified as suspicious transactions.

– Where the report concerns a suspicious account (all transactions arising on the account are suspicious), consolidate information to list the 20 counterparties with the largest transaction value, and summarise the remaining counterparties by total number of counterparties, total number of corresponding accounts, and total transaction amount.

(3): Provide the clearest, most specific and detailed description possible of the indicators, factors, and unusual circumstances leading the reporting entity to suspect that the transaction and/or the parties involved may relate to money laundering or other criminal activity. (Include an overview of the customer and their transactions; then highlight the suspicious indicators, factors, and unusual circumstances.)

(5) : Assessment of potential predicate offences related to the suspicious transaction (multiple offences may be selected). This assessment is an evaluative, predictive exercise based on the suspicious indicators described in the report, intended to provide initial information to competent state authorities.

(6) : Date of detection of the suspicious transaction in accordance with Clause 2 Article 37 of the Law on Anti-money Laundering.

Section V: Provide a detailed description of actions taken in relation to handling the suspicious transaction report, consistent with the guidance.

Section VI: Relevant records and documents must be listed in a document inventory, specifying:� serial number; type of record/document associated with the concerned organization or individual; number of pages; and document status (copy, certified copy, or electronic file).

Signature Section:

REPORT PREPARER: Under the Law on Anti-money Laundering, the reporting unit responsible for the report must be the reporting entity (head office). Therefore, the Report Preparer shall be a staff member of the head office. Where the reporting entity authorizes a branch or transaction office to prepare the report, the Report Preparer may be a staff member of that branch/transaction office; however, this must be stated in the internal AML policies, and the reporting entity (head office) remains responsible for the report.

REVIEWER: Head of department or head of the unit directly reviewing the suspicious transaction report.

LEGAL REPRESENTATIVE: The legal representative or the person legally authorized by the legal representative for a reporting entity that is an organization. For a reporting entity that is an individual, this shall be the individual or the individual�s authorized person. The authorized person must be as provided in Clause 9a Article 5 of this Circular or a person belonging to the dedicated unit (team, division, department) or responsible person at the head office under Clause 9b Article 5 of this Circular.

Notes:

(i) This form applies to reporting entities submitting suspicious transaction reports to the Anti-money Laundering Department – State Bank of Vietnam. It must not be sent to any other competent authority.

(ii) All individuals and organizations named in the same suspicious transaction report must have a connection with one another, which must be reflected in the section describing and analyzing the reasons for the suspicious transaction.