New SBV Circular raises the bar for compliance and risk management
On 15 September 2025, the State Bank of Vietnam (SBV) issued Circular No. 27/2025/TT-NHNN (“Circular 27”) guiding the implementation of key provisions of the Law on Anti-Money Laundering (the “AML Law”).
Taking effect on 1 November 2025, Circular 27 replaces Circular No. 09/2023/TT-NHNN and marks a major leap forward in Vietnam’s evolving anti-money laundering (AML) regime. The Circular sharpens compliance expectations, enhances the risk-based approach, and reaffirms Vietnam’s commitment to the Financial Action Task Force (FATF) standards on combating money laundering, terrorist financing, and Weapons of Mass Destruction proliferation financing. Reporting entities under Vietnam’s AML regime include financial institutions and certain designated non-financial businesses and professions, such as legal professionals, accountants, property agents, precious metal / gemstone dealers and other corporate services providers.
By addressing persistent implementation gaps under the previous framework, Circular 27 delivers on Action No. 5 of the National Action Plan—a cornerstone in Vietnam’s broader strategy to strengthen financial system integrity and align with global best practices.
Key Changes in Circular 27
- Risk Assessment: Introduces a unified scoring methodology for identifying and quantifying money laundering risks.
- Customer Due Diligence (CDD): Establishes clearer risk-based tiers and enhanced verification requirements.
- Reporting Obligations: Tightens large-value, suspicious, and wire transfer reporting thresholds.
- Internal Compliance: Expands mandates on AML governance, internal audits, and staff training.
- Cross-Border Declarations: Introduces new reporting thresholds for cash, gold, and precious assets.
1. Risk Assessment and Scoring Methodology
Article 3 of Circular 27 introduces a standardized, data-driven approach to AML risk evaluation. Reporting entities must assess risks across:
- External factors: industry, geography, and sectoral exposure;
- Operational factors: customer types, products, services, and distribution channels; and
- Internal factors: the design and effectiveness of internal AML systems.
Each risk factor is rated on a 1–5 scale, defining low, medium, and high-risk profiles. Foreign branches may adopt parent-company models if they comply with FATF standards.
All reporting entities must submit their annual AML risk assessment results to the SBV by 31 March of the following year.
2. Customer Risk Ratings and Due Diligence
Article 4 of Circular 27 enhances customer due diligence (CDD) by requiring reporting entities to classify customers as low, medium, or high risk—with corresponding measures:
- Simplified CDD for low-risk clients;
- Standard CDD for regular clients; and
- Enhanced CDD for high-risk clients, including:
- Senior management approval prior to onboarding;
- Verification of income sources and business activities; and
- More frequent transaction monitoring and data updates.
Circular 27 also requires that institutions define clear conditions for providing services before CDD verification is completed, effectively tightening pre-onboarding controls.
3. Internal AML Policies and Procedures
Under Article 5, Circular 27 demands greater depth and accountability within internal AML frameworks. Notable provisions include:
- Conducting CDD when customers without accounts—or with accounts inactive for six months – make transactions of VND 400 million or more per day;
- Verification of beneficial owners using reliable, independent sources;
- Expanding KYC requirements to include founders, trustees, beneficiaries, and ultimate controllers of trusts; and
- Continuous monitoring of customer activities, with priority scrutiny for high-risk profiles.
These changes elevate the AML function from procedural compliance at the time of onboarding to one of ongoing strategic risk management within financial institutions.
4. Reporting Obligations
Articles 6, 7, and 9 refine reporting requirements to ensure faster, more transparent data flows to regulators:
- Large-Value Transactions: Reporting applies to substantial cash deposits and VND–foreign currency exchanges.
- Suspicious Transactions (STRs): Must be reported immediately upon suspicion, regardless of transaction amount.
- Wire Transfers:
- Domestic transfers ≥ VND 500 million;
- International transfers ≥ USD 1,000;
(excluding card payments and interbank settlements).
5. Cross-Border Cash and Asset Declarations
Article 11 introduces new rules governing the cross-border movement of cash, precious metals, gemstones, and negotiable instruments.
- Threshold: Declaration required for amounts valued at VND 400 million or more.
- Coverage: Gold, silver, platinum, jewelry, diamonds, rubies, sapphires, emeralds, and related alloys.
- Documentation: Original invoices or lawful origin certificates; compliance with SBV’s existing currency and gold transport regulations is mandatory.
These measures close long-standing gaps in monitoring high-value physical asset flows.
6. Key Takeaways for Reporting Entities
Circular 27 represents a shift from tick-the-box compliance toward dynamic, risk-based governance. The implications are significant for financial institutions, FinTech’s, and designated non-financial businesses and professions. By 1 January 2026, reporting entities should:
- Recalibrate AML risk scoring systems and internal controls;
- Upgrade CDD and STR reporting tools to capture new thresholds;
- Conduct targeted staff training on enhanced verification and monitoring; and
- Engage early with regulators to align on compliance expectations.
For further insights on Circular 27 and AML developments in Vietnam, please contact DFDL.
The information provided here is for information purposes only and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.
