On Sep. 15, 2025, VIE GVT issued circular to finalize Guidelines for the implementation of certain provisions of the Anti-money laundering Law, effective from Nov. 1, 2025.
Document dated Sep. 15, 2025, received from VIE GVT Sep. 19, summarized Sep. 23.
On May 8, VIE CB proposed anti-money laundering reg guide changes.
VIE CB published draft circular amending, supplementing certain provisions of circular 09/2023/TT-NHNN providing guidance on execution of the Anti-money laundering law.
Follows VIE CB Jul. 2023 issued new circular on anti-money laundering law, #181605.
Risk Assessment and Management
Covers anti-money laundering, counter-terrorism financing, prevention of financing of weapons of mass destruction; reporting entities must submit risk assessment results and updates re money laundering risks to VIE CB and state management agencies.
Entities must develop and issue risk management processes for money laundering at their organizations; risk management processes must be approved by senior management and structured according to scale, scope, and operational characteristics.
Risk management processes include risk scope and objective identification, level of impact assessment, customer classification by risk levels, and identification processes.
Customer Due Diligence
Reporting entities must establish customer identification procedures including verification of customer information; in addition, for electronic fund transfers, the reporting entities must create reference numbers allowing transaction traceability.
Customer identification required when customers participate in legal agreements.
Procedures for identifying beneficial owners of legal entities through alternative methods; risk management procedures must be applied before providing products or services to customers; enhanced measures required for managing certain risks.
Namely, those regarding incomplete or inaccurate electronic fund transfer information.
In addition, the draft covers internal policies and procedures, large transaction reporting, suspicious transaction reporting, electronic fund transfers, IT system requirements, and new reporting forms for risk assessment, suspicious transactions.
Consultation End
The consultation is open for an unspecified period.
Sep. 2025 VIE GVT Implementation Guideline
On Sep. 15, 2025, VIE GVT issued circular to finalize Guidelines for the implementation of certain provisions of the Anti-money laundering Law, effective from Nov. 1, 2025.
Document dated Sep. 15, 2025, received from VIE GVT Sep. 19, summarized Sep. 23.
