Vietnam Adds Crypto-Asset Services to AML Regime With 15 Suspicious Transaction Indicators
Vietnam’s National Assembly has approved amendments that bring crypto-asset services directly into the country’s anti-money laundering framework, with the new rules due to take effect on 1 December 2026.
On 24 August, lawmakers passed legislation amending the Law on the State Bank of Vietnam, the Law on Anti-Money Laundering and the Law on Credit Institutions. The National Assembly said 473 of 476 participating deputies voted in favour, representing 94.6% of the full legislature.
Crypto services become AML reporting entities
Under the amended AML law, crypto-asset service providers are brought into the reporting framework. Reporting entities must file suspicious transaction reports with the State Bank of Vietnam where there are reasonable grounds to suspect that assets involved in a transaction are proceeds of crime.
The law also introduces a new Article 33a setting out 15 suspicious indicators for crypto-asset activity. The indicators are intended to provide a more specific statutory basis for identifying and escalating higher-risk activity in the sector.
Examples include conducting multiple high-value crypto transactions within a short period without a clear business purpose; repeatedly depositing, trading and withdrawing crypto assets shortly after establishing a customer relationship; structuring transactions into smaller amounts below applicable customer-identification or reporting thresholds; and converting crypto assets into several other crypto assets without a reasonable business or investment purpose.
The framework also addresses activity involving jurisdictions or crypto service providers presenting elevated AML/CFT risk, including circumstances involving FATF-listed jurisdictions or markets where the legal framework for crypto-related AML/CFT controls is incomplete.
Risk-based supervision also strengthened
The National Assembly said the amendments also clarify the responsibilities of ministries and supervisory bodies and reinforce risk-based inspection, examination and supervision. The Ministry of Finance is expected to have responsibility for inspecting AML compliance in the crypto-asset sector when assigned by the Government, while the State Bank of Vietnam retains the central suspicious-transaction reporting role.
The reform moves Vietnam’s crypto AML regime from a more general risk framework toward explicit statutory obligations and crypto-specific red flags. For exchanges and other crypto-asset service providers preparing for the December effective date, the practical focus will be on customer identification, transaction-monitoring rules, escalation logic and evidence supporting suspicious transaction decisions.
