State Bank of Vietnam issues updated anti-money laundering implementing rules effective 1 November 2025 with transition to 2026 for internal controls and electronic reporting

The State Bank of Vietnam has issued new implementing guidance under Vietnam’s Anti-Money Laundering Law, updating and partially replacing provisions previously set out in its 2023 framework to address practical implementation issues for reporting entities and supervisors and to support commitments linked to Vietnam’s FATF action plan. The circular sets requirements across 13 articles covering (among other areas) criteria and methods for money laundering risk assessment by reporting entities, risk management processes and customer risk classification, internal anti-money laundering rules, reporting of large-value and suspicious transactions, electronic funds transfer transactions and related reporting, and the format and deadlines for electronic data submissions. It also addresses thresholds and documentation for customs at border checkpoints when carrying cash foreign currency, cash Vietnamese dong, negotiable instruments, precious metals, and gemstones above prescribed limits. The circular takes effect from 1 November 2025, with transitional provisions allowing reporting entities to continue applying existing internal rules and risk management processes through 31 December 2025. From 1 January 2026, reporting entities must have completed updates to internal rules and risk management processes, implemented information technology systems to support electronic data reporting, and deployed software to screen against blacklists, watchlists and politically exposed person lists referenced in the Anti-Money Laundering Law, alongside transaction monitoring to detect and flag suspicious indicators linked to money laundering, terrorist financing and proliferation financing.