Legal expert Tuyet Nhi provides the following response:
On August 24, 2026, the National Assembly of Vietnam adopted Law No. 23/2026/QH16 on amendments to the Law on the State Bank of Vietnam, the Law on Prevention and Combat of Money Laundering, and the Law on Credit Institutions.
Clause 9 Article 2 of Law No. 23/2026/QH16 adds Article 33a after Article 33 of the Law on Prevention and Combat of Money Laundering 2022, prescribing the following suspicious indicators in the field of crypto-assets:
(1) Dividing a crypto-asset transaction into multiple transactions with values below the prescribed customer identification or reporting threshold, or conducting multiple high-value crypto-asset transactions within a short period without a clear business purpose.
(2) The occurrence of any of the following circumstances inconsistent with the customer’s profile and characteristics: successively depositing, trading, and withdrawing crypto-assets within a very short period immediately after establishing the customer relationship; making a high-value initial deposit immediately after opening a crypto-asset account; or conducting transactions of an unusually high value or frequency through a crypto-asset account that has remained inactive for an extended period.
(3) Immediately transferring crypto-assets to multiple crypto-asset service providers in countries or territories included in lists published by the Financial Action Task Force for the prevention of money laundering, terrorist financing, and proliferation financing; in countries or territories that have not promulgated, or have promulgated an incomplete, legal framework for the prevention of money laundering, terrorist financing, and proliferation financing in relation to crypto-assets; or to crypto-asset service providers included in crypto-asset-related lists published by the Financial Action Task Force, where there is no reasonable connection with the customer’s place of residence or place of operation.
(4) Converting crypto-assets into multiple different types of crypto-assets without a reasonable business or investment purpose, or converting crypto-assets into fiat currency under unfavorable pricing conditions while accepting losses or transaction fees that are unusually high compared with the conditions of the blockchain network at the time of the transaction.
(5) Multiple accounts or wallet addresses with no apparent connection transferring crypto-assets to the same wallet address, or one account successively transferring crypto-assets of equivalent value to multiple different wallet addresses within a short period.
(6) Conducting transactions involving crypto-assets with enhanced anonymity features, using transaction mixing services, or repeatedly converting crypto-assets recorded on a public and transparent distributed ledger into crypto-assets with enhanced anonymity features, thereby disrupting transaction traceability.
(7) Conducting crypto-asset transactions from wallet addresses or crypto-asset service providers identified or warned by competent authorities as being connected with darknet websites trading in illegal goods or services; extortion, fraud, or illegal online gambling; stolen assets; or other criminal activities.
(8) A customer accesses the platform of a crypto-asset service provider through a tool that enables the concealment of the customer’s identity or Internet Protocol address; or multiple crypto-asset accounts registered under different identities show signs of being operated from the same device or Internet Protocol address.
(9) A customer refuses or delays the provision of customer identification documents or information on the source of assets; provides documents showing signs of forgery or inconsistent information; or cannot reasonably explain the purpose of a transaction, the source of assets, or the relationship with the counterparty.
(10) A customer’s crypto-asset wallet address appears in public information sources in connection with illegal activities, or deposited or withdrawn crypto-assets have a transaction history involving cross-chain bridges assessed as high-risk.
(11) A customer shows signs of allowing another person to use their name, being exploited as an intermediary, or being a victim of fraud. This includes cases in which a customer has limited knowledge of crypto-assets but conducts transactions at a frequency and value inconsistent with their profile and characteristics, or conducts transactions under a third party’s instructions.
(12) A customer’s assets originate primarily from initial crypto-asset offerings that lack transparency or show signs of fraud, or the crypto-assets originate directly from a transaction mixing service or a crypto-asset service provider with inadequate anti-money laundering controls.
(13) Conducting transactions with a crypto-asset service provider whose valid legal status cannot be established, including a provider operating in a country or territory that does not have a legal framework for crypto-assets according to the crypto-asset-related lists published by the Financial Action Task Force; is not included in the list of entities licensed by the competent authority of the host country; or has been warned, suspended, or had its operating license revoked by a competent authority.
(14) Notes accompanying a crypto-asset transaction show signs of being connected with illegal activities; or a customer frequently changes important identification and authentication information in a manner inconsistent with normal usage, conducts transactions from an Internet Protocol address inconsistent with the information previously provided by the customer, or repeatedly opens crypto-asset accounts from the same Internet Protocol address.
(15) A customer conducts transactions through a crypto-asset service provider headquartered or operating in a country or territory included in lists published by the Financial Action Task Force for the prevention of money laundering, terrorist financing, and proliferation financing; in a country or territory that has not promulgated, or has promulgated an incomplete, legal framework for the prevention of money laundering, terrorist financing, and proliferation financing in relation to crypto-assets; or through a crypto-asset service provider included in crypto-asset-related lists published by the Financial Action Task Force.
See more details in Law No. 23/2026/QH16, effective as of December 1, 2026.
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