The issuance of Government Resolution No. 05/2025/NQ-CP, effective from September 9, 2025, marks a decisive step in Vietnam’s efforts to regulate the emerging cryptocurrency market within a structured legal framework. This Resolution, which provides the basis for the pilot implementation of cryptocurrency trading activities, clearly integrates compliance obligations with Vietnam’s laws on anti-money laundering (AML), counter-terrorism financing (CTF), and the non-proliferation of weapons of mass destruction (WMD). The approach reflects the Government’s dual objective: fostering financial innovation while safeguarding national security and economic integrity.
Vietnam’s move comes amid a surge in cryptocurrency transactions, with the Vietnam Blockchain and Digital Assets Association citing data from Chainalysis indicating over USD 220 billion in transaction volume in 2025—a 55 percent increase compared to the previous year. However, the dominance of cross-border trading on unregulated international platforms has created significant enforcement challenges, particularly in taxation, financial transparency, and the prevention of illicit financial flows. As Senior Lieutenant Colonel Nguyen Thanh Chung of the Ministry of Public Security’s Department for Cybersecurity and High-Tech Crime Prevention has observed, cryptocurrencies have increasingly been exploited for illegal fundraising and money laundering schemes. Their anonymity and cross-border characteristics allow criminal entities to create a shadow financial system beyond the reach of conventional state control, posing real risks to social order, fiscal stability, and the effectiveness of monetary policy under the State Bank of Vietnam.
Statistical evidence reinforces these concerns. Between December 2019 and May 2024, nearly 20,000 fraud cases were detected involving over 17,000 individuals, resulting in total losses exceeding VND 12 trillion (approximately USD 455 million). A majority of the illicit proceeds from these cases were converted into digital assets via peer-to-peer exchanges such as Binance, HTX, and OKX. The vast transaction volumes—reaching trillions of Vietnamese dong daily—illustrate the scale and sophistication of this underground economy. Compounding the risks are unauthorized exchanges operating without compliance to the Cybersecurity Law or the Personal Data Protection Law, thereby exposing users to both financial loss and data breaches. Against this backdrop, Resolution 05/2025/NQ-CP establishes a legal pathway for domestic, licensed exchanges, ensuring that cryptocurrency transactions are subject to regulatory oversight, AML/CTF controls, and consumer protection mechanisms.
From a regulatory perspective, Vietnam’s approach is also consistent with its obligations as a member of the global financial compliance community. Since June 2023, the Financial Action Task Force (FATF) has placed Vietnam on its “Gray List” due to deficiencies in the AML/CTF framework, including gaps in monitoring virtual asset service providers (VASPs). In response, the State Bank of Vietnam (SBV), through its Anti-Money Laundering Department, has been actively implementing FATF recommendations by enhancing legal enforcement, improving the capacity of supervisory agencies, and requiring VASPs to develop risk-based compliance programs. The National Risk Assessment Report on Money Laundering for 2018–2022 identified four key areas of exposure—wallet service providers, virtual asset management, stablecoins, and tokenized assets—all of which were rated as high or medium-high risk. This empirical basis informed the drafting of Resolution 05 and the forthcoming Digital Technology Industry Law, both of which impose stringent due diligence, record-keeping, and reporting requirements on crypto service providers.
The Vietnamese government’s regulatory model thus reflects a balanced paradigm—one that recognizes the potential of blockchain technology for economic innovation, yet insists on strict alignment with AML/CTF obligations and FATF standards. Experts view the pilot mechanism as both an incubator for innovation and a legal filter to eliminate risky, non-compliant models from the market. By establishing a transparent and rule-based system for cryptocurrency operations, Vietnam aims to strengthen investor confidence, enhance state capacity to monitor virtual financial flows, and align its legal framework with international best practices in digital asset governance. In essence, Resolution 05/2025/NQ-CP signifies a pivotal shift from a reactive stance toward a proactive, compliance-oriented regulatory regime that positions Vietnam as a credible and responsible participant in the evolving global cryptocurrency ecosystem.
