The State Bank of Vietnam (SBV) has issued Circular No. 27/2025/TT-NHNN, introducing updated guidelines for the implementation of several provisions of the Anti-Money Laundering Law. The new circular, announced on September 15, 2025, will take effect on November 1, 2025, marking a major step in Vietnam’s ongoing efforts to align its financial regulations with international anti-money laundering (AML) standards.
The regulation applies broadly to financial institutions, businesses in non-financial sectors, and individuals, including foreign organizations and foreign nationals engaged in transactions with Vietnamese entities. It replaces Circular No. 09/2023/TT-NHNN, establishing more structured requirements for risk assessment, customer due diligence, and transaction reporting.
Comprehensive Risk Assessment Framework
Under the new circular, entities must assess money laundering risks using a standardized set of criteria that consider both environmental factors and business activities. The assessment operates on a five-point scale, where lower scores denote reduced risk levels.
Each reporting entity is required to submit its annual risk assessment report by March 31 of the following year, ensuring continuous evaluation of exposure to money laundering activities.
Customer Classification and Risk Management
Financial and non-financial organizations must implement risk-based management procedures, classifying customers into low, medium, or high-risk categories. Those identified as high-risk will be subject to enhanced due diligence and ongoing monitoring. The SBV emphasized that this system is crucial for detecting suspicious behavior and preventing illicit transactions from entering the financial system.
Internal AML Regulations
Entities covered by the Circular are required to establish internal AML regulations, detailing procedures for customer identification, transaction monitoring, and data retention. These internal rules must be reviewed and updated annually to reflect evolving compliance practices and legislative changes.
Reporting Obligations
The Circular reiterates mandatory reporting to the Anti-Money Laundering Department for large-value and suspicious transactions, as well as domestic and cross-border electronic fund transfers exceeding prescribed limits. The aim is to enhance transparency in financial flows and strengthen the traceability of high-value transactions.
Thresholds for Cross-Border Declarations
To further safeguard against money laundering through the movement of valuable assets, the Circular sets a VND 400 million threshold for precious metals, gemstones, and negotiable instruments that must be declared upon exit from Vietnam. Travellers are required to present original or certified documents supporting the declared value.
Implementation Timeline
The SBV has directed all reporting entities to update their internal AML procedures by January 1, 2026, ensuring full compliance with the new framework before enforcement begins.
With Circular No. 27/2025/TT-NHNN, Vietnam is reinforcing its regulatory infrastructure at a time when global scrutiny of financial transparency is intensifying. The move also supports the country’s commitment to meeting Financial Action Task Force (FATF) recommendations and bolstering its reputation as a responsible player in the international financial system.
By FCCT Editorial Team
