On September 22, 2025, the State Bank of Vietnam (“SBV”) introduced Circular No. 27/2025/TT-NHNN, a pivotal regulatory instrument providing detailed guidance for the implementation of Vietnam’s Law on Anti-Money Laundering (AML). The Circular will take effect on November 1, 2025, marking a significant enhancement in Vietnam’s framework for financial transparency and risk management in line with FATF (Financial Action Task Force) standards.
Under the new regulation, domestic electronic transfers of VND 500 million (approx. USD 18,900) or more, and cross-border electronic transfers of USD 1,000 or more, must be reported to the SBV. This reporting obligation also extends to suspicious transactions, regardless of amount, and applies to a wide spectrum of financial institutions, including commercial banks, payment intermediaries, and other AML reporting entities.
In addition, Circular 27 specifies the value thresholds and documentation requirements for individuals carrying large amounts of cash, negotiable instruments, precious metals, or gemstones across Vietnam’s borders. The threshold for precious metals (excluding gold) and gemstones is capped at VND 400 million, mirroring the same limit for negotiable instruments.
From a compliance standpoint, the Circular introduces a comprehensive and risk-based AML approach by requiring financial institutions to:
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Assess money laundering risks using prescribed criteria and methodologies;
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Categorize customers by levels of money laundering risk;
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Establish internal control systems and internal regulations on AML compliance; and
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Develop IT infrastructure and automated systems capable of screening transactions against international and domestic blacklists.
To accommodate implementation challenges, the Circular provides a transitional period: reporting entities may continue applying existing AML internal regulations and risk management procedures until December 31, 2025. By January 1, 2026, full compliance with Circular 27’s updated provisions will become mandatory, including technological upgrades and procedural adjustments to ensure automated monitoring and reporting.
Substantively, Circular 27 aims to close long-standing regulatory gaps exposed during Vietnam’s mutual evaluation processes and in practice by the banking sector. It enhances the legal alignment between domestic AML measures and international obligations under frameworks such as the United Nations Convention against Transnational Organized Crime and the FATF Recommendations.
The reform has several key implications for financial institutions and cross-border investors:
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Enhanced Compliance Burden – Financial institutions must reassess their transaction monitoring systems, customer due diligence (CDD) policies, and data management protocols to comply with higher scrutiny thresholds.
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Stronger Regulatory Oversight – The SBV will have expanded authority to monitor reporting accuracy and timeliness, imposing administrative sanctions for delayed or incomplete submissions.
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Increased Transparency in Capital Flows – By requiring detailed reporting for large-value domestic and international transfers, Vietnam reinforces its commitment to transparency, particularly as it seeks to elevate its status in international financial markets.
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Reputational and Strategic Impact – Compliance with Circular 27 will contribute positively to Vietnam’s national AML/CFT risk profile, supporting efforts to avoid grey-listing by FATF and improving the country’s attractiveness to foreign investors seeking a stable, transparent financial environment.
In conclusion, Circular 27/2025/TT-NHNN represents a decisive step toward modernizing Vietnam’s AML regime. It balances regulatory tightening with a phased implementation approach, ensuring both regulatory robustness and operational feasibility for financial institutions. As the November 1 effective date approaches, businesses and financial intermediaries should prioritize internal audits, staff training, and system upgrades to ensure readiness and compliance with the new standards.
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Prepared by Lexora Partner – Legal Insights and Regulatory Updates
https://lexorapartner.com.vn
