LEGAL UPDATE RELATING TO FINANCE AND CREDIT  (MONTHLY LEGAL UPDATE – 10&11/2025)

LEGAL UPDATE RELATING TO FINANCE AND CREDIT (MONTHLY LEGAL UPDATE – 10&11/2025)

1. LEGAL DOCUMENTS ARE ISSUED IN 10, 11/2025

1.2. Circular No. 23/2025/TT-NHNN amendments to Circular No. 30/2019/TT-NHNN dated December 27, 2019 of governor of state bank of vietnam prescribing reserve requirements to be satisfied by credit institutions and foreign bank branches.

  • Name of legal document: Circular N 23/2025/TT-NHNN issued on August 12, 2025, by the State Bank of Vietnam on the amendments to Circular No. 30/2019/TT-NHNN dated December 27, 2019 of governor of state bank of Vietnam prescribing reserve requirements to be satisfied by credit institutions and foreign bank branches (hereinafter referred to as “Circular 23/2025/TT-NHNN”).
  • Effective Date: 01/10/2025.

The content should be noted: Regulations on reduction in reserve ratios.

Specifically, Article 2 of Circular No. 23/2025/TT-NHNN stipulates: Article 2. Amendments to Article 7 of Circular No. 30/2019/TT-NHNN

Article 7 is amended as follows:

Article 7. Reduction in reserve ratios

  1. The reserve ratio imposed on an assisting credit institution as defined in clause 39 Article 4 of the Law on Credit Institutions (hereinafter referred to as “assisting credit institution”) shall be reduced by 50% according to the plan for recovery of the credit institution placed under special control approved by a competent authority (hereinafter referred to as “approved recovery plan”).
  2. The reserve ratio imposed on a credit institution that receives mandatory transfer of a commercial bank placed under special control as prescribed in the Law on Credit Institutions (hereinafter referred to as “transferee”) shall be reduced by 50% according to the plan for mandatory transfer of a commercial bank placed under special control approved by a competent authority (hereinafter referred to as “approved mandatory transfer plan”).
  3. The rate of reduction in reserve ratio granted to each of the credit institutions prescribed in clauses 1 and 2 of this Article shall be calculated according to the reserve ratio imposed on that credit institution as prescribed in clause 1 Article 6 of this Circular, regardless of types of reservable deposits.”

1.2. Decision No. 3440/QD-NHNN on the promulgation of newly issued, amended, supplemented, replaced, or abolished administrative procedures in the foreign exchange operations sector implemented at the single-window division under the functional management scope of the State Bank of Vietnam.

  • Name of legal document: Decision No. 3440/TT-NHNN issued on October 12, 2025, by the State Bank of Vietnam on the promulgation of newly issued, amended, supplemented, replaced, or abolished administrative procedures in the foreign exchange operations sector implemented at the single-window division under the functional management scope of the State Bank of Vietnam (hereinafter referred to as “Decision No. 3440/QD-NHNN”).
  • Effective date: 12/10/2025.

The content should be noted: Regulations on the procedure for licensing commercial banks to produce gold bars.

Specifically, Clause 1.11, Article 1, Part II of Decision No. 3340/QD-NHNN stipulates: “1.11. Requirements and Conditions:

– For Commercial Banks:

a) Must possess a License for gold bar trading/business;

b) Must have a charter capital of VND 50,000 billion or more;

c) Must not have been penalized for administrative violations related to gold business operations or, if penalized for administrative violations related to gold business operations, must have completed all remedial measures in accordance with the Decision on administrative violation penalties and the time-bound recommendations in the inspection and examination conclusions of competent State agencies (if any);

d) Must have internal regulations on gold bar production, including fundamental contents such as the raw material import process; the gold bar production process; the production monitoring process; and the product quality control process.”

1.3. Circular No. 21/2025/TT-NHNN prescribing credit rating of credit institutions and foreign bank branches.

  • Name of legal document: Circular No. 21/2025/TT-NHNN issued on July 31, 2025, by the State Bank of Vietnam on the prescribing credit rating of credit institutions and foreign bank branches (hereinafter referred to as “Circular 21/2025/TT-NHNN”).
  • Effective Date: 01/11/2025.

The content should be noted: Regulations on the rating criteria system.

Specifically, Article 6 of Circular No. 21/2025/TT-NHNN stipulates: “Article 6. Credit rating criteria system

  1. The system of criteria used for the credit rating of credit institutions and FBBs shall include:a) Capital (C);b) Asset quality (A);c) Management and administration (M);d) Business efficiency (E);đ) Liquidity (L);e) Sensitivity to market risk (S).
  2. Credit institutions and FBBs may be scored according to criteria and subgroup of indicators prescribed in Article 7, 8, 9, 10, 11 and 12 hereof.”

    1.4. Circular No. 27/2025/TT-NHNN on guidelines for implementation of a number of articles of the law on anti-money laundering.

    • Name of legal document: Circular N 27/2025/TT-NHNN issued on September 15, 2025, by the State Bank of Vietnam on the guidelines for implementation of a number of articles of the law on anti-money laundering (hereinafter referred to as “Circular 27/2025/TT-NHNN”).
    • Effective Date: 15/11/2025.

    The content should be noted: Procedures for money laundering risk management.

    Specifically, Clause 1 of Article 4 of Circular No. 27/2025/TT-NHNN stipulates: Article 4. Procedures for money laundering risk management

    1. Based on the results of assessment and update of money laundering risk as prescribed in Article 3 of this Circular, reporting entities shall formulate and promulgate procedures for money laundering risk management at reporting entities. Procedures for money laundering risk management must be approved by senior managers that have authority under the law of reporting entities or by persons authorized by such senior managers, and must be presented step by step in line with the size, scope, and characteristics of operations of reporting entities for money laundering risk management. Procedures for money laundering risk management must include at least the following:a) Defining the scope and objectives of money laundering risk management activities;b) Identifying and assessing the level of impact of money laundering risk at reporting entities;c) Customer risk rating by money laundering risk levels of low, medium, and high based on the following factors: customers; products and services that customers are using or intend to use; geographic locations where customers reside or have their head offices; and other factors self-identified by reporting entities in line with actual circumstances and specified in risk management procedures;d) Procedures for identifying and assessing money laundering risk before providing new products or services, or existing products and services applying innovative technology;đ) Risk management procedures for executing, refusing, suspending, controlling after transaction, or considering and reporting suspicious transactions of wire transfer transactions with inaccurate or incomplete information as required;e) Risk management procedures in cases where products or services are provided to customers before completion of verification of customer due diligence (CDD) information as required by law, including specific conditions under which customers may use products or services before completion of verification of CDD information;g) Measures applied corresponding to customer money laundering risk levels, including updating CDD information, frequency of updating CDD information, verifying CDD information, monitoring customer transactions according to money laundering risk levels, simplified CDD measures, and enhanced CDD measures as prescribed in Clauses 2 and 5 of this Article.”

      1.5. Circular No. 29/2025/TT-NHNN on providing guidance for credit institutions and foreign bank branches on granting loans for agriculture and rural development.

      • Name of legal document: Circular N 29/2025/TT-NHNN issued on September 30, 2025, by the State Bank of Vietnam on providing guidance for credit institutions and foreign bank branches on granting loans for agriculture and rural development (hereinafter referred to as “Circular 29/2025/TT-NHNN”).
      • Effective date: 15/11/2025.

      The content should be noted: Regulations on the debt rescheduling for borrowers facing difficulties due to objective and force majeure reasons.

      Specifically, Article 3 of Circular No. 29/2025/TT-NHNN stipulates: Article 3. Debt rescheduling for borrowers facing difficulties due to objective and force majeure reasons

      1. In cases where customers face difficulties due to objective and force majeure reasons as defined in Clause 12 of Article 3 and Clause 1 of Article 12 of Decree No. 55/2015/ND-CP, which is amended by Decree No. 116/2018/ND-CP and Decree No. 156/2025/ND-CP, and specifically determined on each occasion by the credit institution and the borrower(hereinafter referred to as specific objective and force majeure reasons), the credit institution shall consider rescheduling outstanding principal and/or interest and maintaining debt group classification of rescheduled debts (principal and/or interest) under the applicable regulations at the most recent time before debt rescheduling under this Circular, based on the borrower’s proposal, the financial capacity of the credit institution, and compliance with the following conditions:a) There exists an outstanding principal incurred before or during the occurrence of the specific objective and force majeure reasons;b) The outstanding principal and/or interest of each repayment period of the debt to be rescheduled is either undue or overdue by up to 10 (ten) days from the agreed repayment due date;c) The credit institution determines that the borrower is facing difficulties and unable to repay the principal and/or interest on time as agreed due to specific objective and force majeure reasons, and is capable of fully repaying the principal and/or interest after the debt is rescheduled;d) A debt may be rescheduled an unlimited number of times; however, the duration granted for each rescheduling for the same specific objective and force majeure reason must not exceed:i) 12 months from the due date of each outstanding principal and interest of the rescheduled short-term debts;ii) 36 months from the due date of each outstanding principal and interest of the rescheduled medium-term and long-term debts;The due date of each outstanding debt rescheduled under this point shall be based on the repayment term and periods most recently agreed upon before it is rescheduled for the first time under this Circular for the same specific objective and force majeure reason.
      1. Debts that have been rescheduled under other laws and satisfy the regulations herein may be considered by the credit institution for debt rescheduling in accordance herewith.”

      1.6. Circular No. 33/2025/TT-NHNN on amendment to Circular No. 17/2014/TT-NHNN on classification, packaging, delivery of precious metal and precious jewels.

      • Name of legal document: Circular N 33/2025/TT-NHNN issued on September 30, 2025, by the State Bank of Vietnam on the guidelines for implementation of a number of articles of the law on anti-money laundering (hereinafter referred to as “Circular 33/2025/TT-NHNN”).
      • Effective Date: 15/11/2025.

      The content should be noted: Amendments to the regulations on the documents required upon delivery of precious metals and precious jewels.

      Specifically, Article 10 of Circular No. 33/2025/TT-NHNN stipulates: Article 10. Amendment to Clause 1 Article 15

      “1. The following documents shall be required upon delivery of precious metal and precious jewels:

      a) Storage withdrawal order of competent authorities, SBV, credit institutions;

      b) Notice of storage withdrawal;

      c) Power of attorney of receiving persons, receiving entities (when receiving on behalf);

      d) ID Card or electronic ID Card or passport of receiving persons.”

      1.7      Circular No. 30/2025/TT-NHNN on  amendments to certain articles of the Circular No. 15/2024/TT-NHNN on provision of cashless payment services.

      • Name of legal document: Circular N 30/2025/TT-NHNN issued on September 30, 2025, by the State Bank of Vietnam on amendments to certain articles of the Circular No. 15/2024/TT-NHNN on provision of cashless payment services.
      • Effective date: 18/11/2025.

      The content should be noted: Regulations on the procedures and conditions for cash deposit and withdrawal via the National Inter – bank Electronic Payment System.

      Specifically, Clause 1 of Article 3 of Circular No. 30/2025/TT-NHNN stipulates: Article 1. Amendments to some points and clauses of Article 7

      1. Point a Clause 2 Article 7 is amended as follows:“a) Where a credit institution deposits or withdraws cash via the National Inter – bank Electronic Payment System, the credit institution or the branch of the credit institution shall send list of officials authorized to conduct cash transactions with SBV’s regional branch and written authorization produced by each official and signed by legal representative of the credit institution (Appendix No. 1 attached hereto) to SBV’s regional branch.  The written authorization must specify information on the authorized individual, term of authorization, detail of authorization pertaining to cash transactions and transport;”.”
      1. LEGAL DOCUMENTS ARE EFFECTIVE IN 09, 10/2025

      2.1.      Circular No. 31/2025/TT-NHNN on the operations conducted by subsidiaries or associate companies of credit institutions in the field of debt and collateral management.

      • Name of legal document: Circular N 31/2025/TT-NHNN issued on September 30, 2025, by the State Bank of Vietnam on the operations conducted by subsidiaries or associate companies of credit institutions in the field of debt and collateral management.
      • Effective date: 01/12/2025.

      The content should be noted: Regulations on the operations conducted by debt management companies.

      Specifically, Article 4 of Circular No. 31/2025/TT-NHNN stipulates: “Article 4. Operations conducted by debt management companies

      A debt management company is allowed to conduct the following operations:

      1. Debt management and settlement as authorized by the authorizing party as prescribed in Article 6 of this Circular.
      2. Management of debt collateral as authorized by the authorizing party as prescribed in Article 6 of this Circular.
      3. Utilization of collateral as authorized by the authorizing party through leasing of part of the authorizing party’s business building which is not yet used in accordance with regulations of Article 139 of the Law on Credit Institutions.
      4. Debt purchase and sale as prescribed in Article 7 of this Circular.
      5. Purchase of bad debt collateral as prescribed in Article 8 of this Circular.
      6. Settlement of bad debts and disposal of collateral of other bad debts according to the restructuring plan approved by the competent authority.
      7. Valuation of collateral of debts during implementation of the operations specified in clauses 1, 2, 4, 5 and 6 of this Article.”
      LEGAL UPDATE RELATING TO FINANCE AND CREDIT  (MONTHLY LEGAL UPDATE – 10&11/2025)

      LEGAL UPDATE RELATING TO FINANCE AND CREDIT (MONTHLY LEGAL UPDATE – 09/2025)

      1.     LEGAL DOCUMENTS ARE EFFECTIVE IN 09/2025

      1.1. Circular No.14/2025/TT-NHNN stipulates the capital adequacy ratio applicable to commercial banks and branches of foreign banks

      • Name of legal document: Circular No. 14/2025/TT-NHNN, issued on June 30, 2025, by the State Bank of Vietnam, provides regulations on the capital adequacy ratio applicable to foreign banks (hereinafter referred to as “Circular No. 14/2025/TT-NHNN”).
      • Effective date: 15/09/2025.

      The content should be noted: Banks regulate transactions by mitigating credit risks

      Specifically, Clauses 1 and 2, Article 25 of Circular No. 14/2025/TT-NHNN stipulates: Article 25. Credit Risk Mitigation

      Banks are allowed to adjust the value of receivables or transactions downward using the credit risk mitigation measures specified in Clause 2 of this Article.

      Credit risk mitigation as mentioned in Clause 1 of this Article shall be implemented through one or a combination of the following measures:

      a) Collateral;

      b) On-balance sheet netting;

      c) Third-party guarantees;

      d) Credit derivatives.”.

      2.     LEGAL DOCUMENTS ARE ISSUED IN 08/2025

      2.1. Decision No. 2916a/QĐ-NHNN of 2025 announcing the amended and supplemented administrative procedures in the field of establishment and operation of banks, implemented at the One-Stop Shop under the scope of management functions

      • Name of legal document: Decision No. 2916a/QĐ-NHNN of 2025 announcing the amended and supplemented administrative procedures in the field of bank establishment and operation, to be implemented at the One-Stop Shop within the scope of management functions (hereinafter referred to as “Decision No. 2916a/QĐ-NHNN”).
      • Consolidated date: 02/08/2025.

      The content should be noted: Amendments and supplements to the procedures for approving the expected appointment of personnel for the appointment of the General Director (Director) of foreign bank branches

      Specifically, Section 1, Part I of the amended and supplemented administrative procedures the field of establishment and operation of banks under the management of the State Bank of Vietnam promulgated together with Decision No. 2916a/QD-NHNN stipulates: PART I. LIST OF ADMINISTRATIVE PROCEDURES

      1. List of amended and supplemented administrative procedures under the management of the State Bank of Vietnam

      No.

      Procedure Code

      Procedure Name

      Legal Document Regulating Amendments/Supplements

      Field

      Implementing Agency

      Administrative procedures carried out at the State Bank of Vietnam and its Regional Branches

      1

      1.003151

      Procedure for approval of the expected appointment of General Director (Director) of a foreign bank branch

      Circular No. 20/2025/TT-NHNN dated July 31, 2025

      Bank establishment and operations

      State Bank of Vietnam (Department of Banking Supervision and Inspection); Regional Branches of the State Bank

      2.2. Consolidated Document No. 16/VBHN‑NHNN of 2025 consolidating the Circular regulating refinancing for credit institutions after credit institutions have lent to Vietnam Airlines Corporation ‑ Joint Stock Company, and restructuring of repayment terms, maintaining loan classification, and provisioning for risk in respect of debts of Vietnam Airlines Corporation ‑ Joint Stock Company due to the impacts of the COVID‑19 pandemic

      • Name of legal document: Consolidated Document No. 16/VBHN-NHNN issued on September 15, 2025, by the State Bank of Vietnam, stipulating regulations on refinancing for credit institutions after such institutions have provided loans to Vietnam Airlines Corporation – Joint Stock Company, and on the restructuring of repayment terms, maintenance of debt classification, and risk provisioning for debts of Vietnam Airlines Corporation – Joint Stock Company due to the impacts of the COVID-19 pandemic.
      • Effective date: 06/08/2025.

      The content should be noted: Consolidating Circular No. 04/2021/TT-NHNN dated April 5, 2021, of the Governor of the State Bank of Vietnam, stipulating regulations on refinancing for credit institutions after such institutions have granted loans to Vietnam Airlines Corporation – Joint Stock Company, and on the restructuring of repayment terms, maintenance of debt classification, and risk provisioning for debts of Vietnam Airlines Corporation – Joint Stock Company due to the impacts of the COVID-19 pandemic, which took effect from April 5, 2021; Circular No. 42/2024/TT-NHNN dated July 22, 2024, of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 04/2021/TT-NHNN dated April 5, 2021, on the same subject, which took effect from July 22, 2024; and Circular No. 16/2025/TT-NHNN dated July 11, 2025, of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 04/2021/TT-NHNN dated April 5, 2021, on the same subject, which took effect from July 11, 2025.

      2.3. Consolidated Document No.17/VBHN-NHNN of 2025 consolidating the Circular guiding foreign exchange management for border trade activities between Vietnam and China

      • Name of legal document: Consolidated Document No. 17/VBHN-NHNN issued on August 11, 2025, by the State Bank of Vietnam, consolidating the Circular providing guidance on foreign exchange management for border trade activities between Vietnam and China.
      • Consolidated date: 11/08/2025.

      The content should be noted: Consolidating Circular No. 19/2018/TT-NHNN dated August 28, 2018, of the Governor of the State Bank of Vietnam providing guidance on foreign exchange management for border trade activities between Vietnam and China, which took effect on October 12, 2018; Circular No. 55/2024/TT-NHNN dated December 18, 2024, of the Governor of the State Bank of Vietnam amending Clause 4, Article 2 of Circular No. 19/2018/TT-NHNN dated August 28, 2018, providing guidance on foreign exchange management for border trade activities between Vietnam and China, which took effect on February 1, 2025; and Circular No. 17/2025/TT-NHNN dated July 30, 2025, of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 19/2018/TT-NHNN dated August 28, 2018, providing guidance on foreign exchange management for border trade activities between Vietnam and China, which took effect on September 15, 2025.

      2.4. Circular 81/2025/TT-BTC regulating the management and use of payment accounts of the State Treasury opened at the State Bank of Vietnam and commercial banks

      • Name of legal document: Circular 81/2025/TT-BTC of the Ministry of Finance issued on August 13, 2025 regulating the management and use of payment accounts of the State Treasury opened at the State Bank of Vietnam and commercial banks (hereinafter referred to as “Circular 81/2025/TT-BTC”).
      • Consolidated date: 13/08/2025.

      The content should be noted: Regulations on commercial banks where the State Treasury opens payment accounts

      Specifically, Article 4 of Circular No. 81/2025/TT-BTC stipulates: Article 4. Commercial banks where the State Treasury opens current accounts

      1. The State Treasury shall open a payment account at a commercial bank, ensuring that such commercial bank is not subject to compulsory transfer or special control under a decision of the State Bank of Vietnam; capable of electronic bilateral payment according to professional requirements and technical specifications published on the State Treasury’s web portal.
      2. Before opening a payment account with each commercial bank, the State Treasury and the commercial bank shall reach an agreement on electronic bilateral payment according to the principal contents in the Appendix issued together with this Circular. In particular, the electronic bilateral payment with each commercial bank under the model of a distributed payment account or a centralized payment account model is based on the ability to meet the professional requirements and technical specifications of that commercial bank according to each model.”.

      2.5. Consolidated Document No. 18/VBHN-NHNN of 2025 consolidating the Circular on the implementation of mandatory reserve requirements for credit institutions and foreign bank branches

      • Name of legal document: Consolidated Document No. 18/VBHN-NHNN issued on August 19, 2025, by the State Bank of Vietnam, regulating the implementation of mandatory reserve requirements for credit institutions and foreign bank branches.
      • Consolidated date: 19/08/2025.

      The content should be noted: Consolidation of Circular No. 30/2019/TT-NHNN dated December 27, 2019, issued by the Governor of the State Bank of Vietnam, regulating the implementation of mandatory reserve requirements for credit institutions and foreign bank branches, effective from March 1, 2020, and Circular No. 23/2025/TT-NHNN dated August 12, 2025, issued by the Governor of the State Bank of Vietnam, amending and supplementing certain provisions of Circular No. 30/2019/TT-NHNN dated December 27, 2019, regulating the implementation of mandatory reserve requirements for credit institutions and foreign bank branches, effective from October 1, 2025.

      2.6. Circular No. 25/2025/TT-NHNN amending Circular No. 17/2024/TT-NHNN on the opening and use of payment accounts at payment service providers

      • Name of legal document: Circular No. 25/2025/TT-NHNN issued on August 30, 2025, by the State Bank of Vietnam, amending Circular No. 17/2024/TT-NHNN on the opening and use of payment accounts at payment service providers (hereinafter referred to as “Circular No. 25/2025/TT-NHNN”).
      • Consolidated date: 31/08/2025.

      The content should be noted: Amending and supplementing regulations on dossiers of opening payment accounts for individuals who are Vietnamese citizens.

      Specifically, Clause 1, Article 3 of Circular No. 25/2025/TT-NHNN stipulates:Article 3. Amendments and supplements to several points and clauses of Article 12

      1. To amend and supplement Point a, Clause 2, Article 12 as follows: “a) In case an individual is a Vietnamese citizen: Citizen identity card, identity card or electronic identity card or birth certificate for a person under 14 years old who does not have an identity card;”.
      LEGAL UPDATE RELATING TO FINANCE AND CREDIT  (MONTHLY LEGAL UPDATE – 10&11/2025)

      LEGAL UPDATE RELATING TO FINANCE AND CREDIT (MONTHLY LEGAL UPDATE – 08/2025)

      1.     LEGAL DOCUMENTS ARE EFFECTIVE IN 08/2025

      1.1. Decree No. 135/2025/ND-CP on the financial regime applicable to credit institutions, branches of foreign banks, and the financial supervision and evaluation of the efficiency of state capital investment in wholly state-owned credit institutions and state-invested credit institutions

      • Name of legal document: Decree No. 135/2025/ND-CP issued on 12/06/2025 by the Government on the financial regime applicable to credit institutions, branches of foreign banks, and the financial supervision and evaluation of the efficiency of state capital investment in wholly state-owned credit institutions and state-invested credit institutions (referred to as the “Decree No. 135/2025/ND-CP”).
      • Effective date: 01/08/2025.

      The content should be noted: Responsibilities of credit institutions and foreign bank branches for capital safety assurance.

      Specifically, Article 7 of Decree No. 135/2025/ND-CP stipulates: Article 7. Capital safety assurance

      Credit institutions and branches of foreign banks shall comply with regulations on capital safety assurance as follows:

      1. Manage and use capital and assets, distribute profits, and implement financial management and accounting regimes in accordance with the Law on Credit Institutions, this Decree, and other relevant laws;
      2. Comply with regulations on operational safety in accordance with the Law on Credit Institutions and other relevant laws;
      3. Purchase asset insurance for assets required to be insured;
      4. Participate in deposit insurance and the safety assurance fund for the system of people’s credit funds as prescribed by the Law on Credit Institutions;
      5. Handle asset losses in accordance with Article 9 of this Decree;
      6. Recognize risk provisions as business expenses in accordance with the Law on Credit Institutions and other relevant laws;
      7. Other capital preservation measures as prescribed by law.”

      1.2. Circular No. 20/2025/TT-NHNN elaborating applications and procedures for approving list of expected personnel of commercial banks, foreign bank branches, and non-bank credit institutions

      • Name of legal document: Circular No. 20/2025/TT-NHNN issued on 31/07/2025 by the State Bank of Vietnam elaborating applications and procedures for approving list of expected personnel of commercial banks, foreign bank branches, and non-bank credit institutions (referred to as the “Circular No. 20/2025/TT-NHNN”).
      • Effective date: 10/08/2025.

      The content should be noted: Effective period of written approval for list of expected personnel.

      Specifically, Article 5 of Circular No. 20/2025/TT-NHNN stipulates: Article 5. Effective period of written approval for list of expected personnel

      Written approval issued by SBV for list of expected personnel of banks and non-bank credit institutions shall remain effective for 6 months from the date of signing. Where election and assignment of personnel of banks and non-bank credit institutions have not been completed within the aforementioned time limit, written approval issued by SBV for expected personnel of banks and non-bank credit institutions shall expire by default.”

      2.     LEGAL DOCUMENTS ARE ISSUED IN 07/2025

      2.1. Consolidated Document No. 12/VBHN-NHNN operational network of commercial banks

      • Name of legal document: Consolidated Document No. 12/VBHN-NHNN issued on 10/07/2025 by the the State Bank of Vietnam operational network of commercial banks.
      • Consolidated date: 10/07/2025.

      The content should be noted: This document consolidates:

      Circular No. 32/2024/TT-NHNN dated June 30, 2024 of the Governor of the State Bank of Vietnam operational network of commercial banks, effective from August 15, 2024 and Circular No. 08/2025/TT-NHNN dated June 6, 2025 of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 43/2015/TT-NHNN dated December 31, 2015 of the Governor of the State Bank of Vietnam regulating the organization and operation of postal transaction offices under Lien Viet Post Joint Stock Commercial Bank, Circular No. 29/2024/TT-NHNN dated June 28, 2024 of the Governor of the State Bank of Vietnam regulating people’s credit funds and Circular No. 32/2024/TT-NHNN Decree dated June 30, 2024 of the Governor of the State Bank of Vietnam operational network of commercial banks, effective from July 1, 2025

      2.2. Decision No. 2866/QD-NHNN on maximum outstanding balance for a borrower at a peer-to-peer lending solution and all peer-to-peer lending solutions participating in the Controlled Testing Mechanism

      • Name of legal document: Decision No. 2866/QD-NHNN issued on 22/07/2025 by the State Bank of Vietnam on maximum outstanding balance for a borrower at a peer-to-peer lending solution and all peer-to-peer lending solutions participating in the Controlled Testing Mechanism (referred to as the “Decision No. 2866/QD-NHNN”).
      • Effective date: 22/07/2025.

      The content should be noted: The maximum outstanding balance of a borrower at one and all peer-to-peer lending solutions participating in the Controlled Testing Mechanism prescribed in Decree No. 94/2025/ND-CP.

      Specifically, Article 1 of Decision No. 2866/QD-NHNN stipulates: Article 1. The maximum outstanding balance of a borrower at one and all peer-to-peer lending solutions participating in the Controlled Testing Mechanism prescribed in Decree No. 94/2025/ND-CP dated April 29, 2025 of the Government regulating the Controlled Testing Mechanism in the banking sector is as follows:

      1. At one peer-to-peer lending solution participating in the Controlled Testing Mechanism: VND 100 million (VND 100,000,000).
      2. At all peer-to-peer lending solutions participating in the Controlled Testing Mechanism: VND 400 million (VND 400,000,000).”

      2.3. Consolidated Document No. 13/VBHN-NHNN regulating the system of bank codes used in banking activities and operations

      • Name of legal document: Consolidated Document No. 13/VBHN-NHNN issued on 23/07/2025 by the the State Bank of Vietnam regulating the system of bank codes used in banking activities and operations.
      • Consolidated date: 23/07/2025.

      The content should be noted: This document consolidates: Circular No. 17/2015/TT-NHNN dated October 21, 2015 of the Governor of the State Bank of Vietnam regulating the system of bank codes used in banking activities and operations, effective from July 1, 2016; Circular No. 18/2023/TT-NHNN dated December 28, 2023 of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 17/2015/TT-NHNN dated October 21, 2015 of the Governor of the State Bank of Vietnam regulating the system of bank codes used in banking activities and operations, effective from July 1, 2024; and Circular No. 11/2025/TT-NHNN dated June 26, 2025 of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 17/2015/TT-NHNN dated October 21, 2015 of the Governor of the State Bank of Vietnam regulating the banking code system used in banking activities and operations, effective from June 26, 2025./.

      LEGAL UPDATE RELATING TO FINANCE AND CREDIT  (MONTHLY LEGAL UPDATE – 10&11/2025)

      LEGAL UPDATE RELATING TO FINANCE AND CREDIT (MONTHLY LEGAL UPDATE – 07/2025)

      1.     LEGAL DOCUMENTS ARE EFFECTIVE IN 07/2025

      1.1. Decree No. 94/2025/ND-CP stipulating the regulatory sandbox mechanism in the banking sector

      • Name of legal document: Decree No. 94/2025/ND-CP issued on 29/04/2025 by the Government stipulating the regulatory sandbox mechanism in the banking sector.
      • Effective date: 01/07/2025.

      The content should be noted:

      • Firstly, stipulating the duration, geographical scope, and scope of the pilot.

      Specifically, Article 6 of Decree No. 94/2025/ND-CP stipulates: Article 6. Duration, geographical scope, and scope of the pilot

      1. The maximum duration for testing Fintech solutions is 2 years, depending on the specific solution and field, starting from the date the State Bank of Vietnam issues the Certificate of Participation in the Regulatory Sandbox. The testing period may be extended as stipulated in Article 20 of this Decree.

      The term of the Certificate of Participation in the Regulatory Sandbox shall not exceed the duration (if any) of the Establishment License or the Business Registration Certificate of the organization participating in the sandbox.

      1. Geographical scope:

      The implementation of Fintech pilot solutions is limited to the territory of Vietnam and shall not be conducted across borders.

      1. Scope of the pilot:a) Organizations participating in the Regulatory Sandbox may only provide Fintech solutions within the scope defined in the Certificate of Participation in the Regulatory Sandbox;b) Depending on the Fintech solution and the specific proposal submitted by the organization in the sandbox registration dossier, and based on the opinions of relevant ministries, the State Bank of Vietnam shall determine the scope of the Fintech solution’s pilot in the Certificate of Participation in the Regulatory Sandbox;c) Peer-to-peer (P2P) lending companies may only provide P2P lending solutions within the pilot scope specified in the Certificate of Participation in the Regulatory Sandbox issued by the State Bank of Vietnam in accordance with this Decree. P2P lending companies participating in the sandbox are not allowed to engage in business activities not listed in the Certificate of Participation in the Regulatory Sandbox. They may not provide self-guarantees for customer loans, act as borrowers themselves, or offer P2P lending solutions to pawnshops.”
      • Secondly, stipulating the conditions and criteria for participating in the Regulatory Sandbox.

      Specifically, Article 8 of Decree No. 94/2025/ND-CP stipulates:Article 8. Conditions and criteria for participating in the Regulatory Sandbox

      1. Credit institutions not under special control pursuant to the Law on Credit Institutions, and branches of foreign banks, may be considered for issuance of a Certificate of Participation in the Regulatory Sandbox when their Fintech solutions meet the following criteria:a) The solution involves technical and operational content that is not yet clearly or specifically regulated under current legal provisions;b) The solution is innovative, provides benefits and added value to users in Vietnam, especially those that support and promote financial inclusion;c) The solution has a developed risk management framework to minimize negative impacts on the banking and financial-monetary-foreign exchange systems; has contingency plans to address risks during the pilot; and has plans in place to protect consumer rights;d) The solution has been fully reviewed and evaluated by the participating organization in terms of operations, functionality, usability, and usefulness;e) The solution is feasible for market deployment after successful completion of the pilot phase.
      2. Fintech companies may be considered for issuance of a Certificate of Participation in the Regulatory Sandbox when their Fintech solutions meet the criteria in Clause 1 of this Article and satisfy the following conditions:a) Be a legal entity established and operating lawfully in Vietnam; not undergoing division, separation, consolidation, merger, transformation, dissolution, or bankruptcy in accordance with the law;
      3. b) The legal representative and General Director (Director) must possess a university degree or higher in economics, business administration, law, or information technology, and have at least 2 years of experience as a manager or executive in an organization in the finance or banking sector, and must not be subject to any legal prohibitions.
      4. Organizations participating in the Regulatory Sandbox must ensure that they continuously meet all conditions during their participation in the sandbox.”

      1.2.  Circular No. 03/2025/TT-NHNN on opening and use of VND-denominated accounts for conducting foreign indirect investment in Viet Nam

      • Name of legal document: Circular No. 03/2025/TT-NHNN issued on 29/04/2025 by the State Bank of Vietnam on opening and use of VND-denominated accounts for conducting foreign indirect investment in Viet Nam (referred to as the “Circular No. 03/2025/TT-NHNN”).
      • Effective date: 16/06/2025.

      The content should be noted: Obligations of authorized banks.

      Specifically, Article 7 of Circular No. 03/2025/TT-NHNN stipulates: “Article 7. Obligations of authorized banks

      1. Examine and retain relevant documents and records in accordance with actual transactions to ensure that the provision of foreign exchange services is performed for proper purposes and in compliance with legal regulations. Be held accountable under the law for the adequacy and validity of dossiers for opening indirect investment accounts.
      2. Issue internal regulations on dossiers, procedures, and processes for opening and using indirect investment accounts, and publicly notify such regulations to foreign investors for compliance. Internal regulations must at least include the following contents:a) Regulations on dossiers, procedures, and processes for opening indirect investment accounts;b) Regulations on agreements on the opening and use of indirect investment accounts;c) Regulations on the use of indirect investment accounts;d) Regulations on dispute settlement and complaint handling, and forms for requests for such settlement or complaints;dd) Regulations on risk management in the opening and use of indirect investment accounts in accordance with Article 5 and Article 6 of this Circular.
      3. Authorized banks shall be fully responsible under the law for the opening, closure, and execution of collection and payment transactions via indirect investment accounts for foreign investors.
      4. Comply with the regulations of law on anti-money laundering and combating the financing of terrorism and proliferation of weapons of mass destruction.
      5. Strictly comply with and guide clients in complying with the provisions on the opening and use of indirect investment accounts as stipulated in this Circular and other relevant legal regulations.”

      2.     LEGAL DOCUMENTS ARE ISSUED IN 06/2025

      2.1. Consolidated Document No. 05/VBHN-NHNN prescribing operation of payment agents

      • Name of legal document: Consolidated Document No. 05/VBHN-NHNN issued on 10/06/2025 by the the State Bank of Vietnam prescribing operation of payment agents.
      • Consolidated date: 10/06/2025.

      The content should be noted: This document consolidates: The Circular No. 07/2024/TT-NHNN dated June 21, 2024 of the Governor of the State Bank of Vietnam prescribing operation of payment agents, which has been effective since July 01, 2024 and the Circular No. 06/2025/TT-NHNN dated May 30, 2025 on amendments to clause 7 Article 7 of the Circular No. 07/2024/TT-NHNN dated June 21, 2024 of the Governor of the State Bank of Vietnam prescribing operation of payment agents, which comes into force from July 01, 2025.

      2.2. Consolidated Document No. 07/VBHN-NHNN stipulating the delivery, receipt, preservation and transport of cash, precious assets and valuable papers

      • Name of legal document: Consolidated Document No. 07/VBHN-NHNN issued on 20/06/2025 by the the State Bank of Vietnam stipulating the delivery, receipt, preservation and transport of cash, precious assets and valuable papers.
      • Consolidated date: 20/06/2025.

      The content should be noted: This document consolidates: The Circular No. 01/2014/TT-NHNN dated January 6, 2014, of the Governor of the State Bank of Vietnam stipulating the delivery, receipt, preservation and transport of cash, precious assets and valuable papers, and took effect on February 20, 2014; the Circular No. 12/2017/TT-NHNN dated August 31, 2017, of the Governor of the State Bank of Vietnam, amends and supplements certain articles of Circular No. 01/2014/TT-NHNN dated January 6, 2014, stipulating the delivery, receipt, preservation and transport of cash, precious assets and valuable papers, and took effect on October 16, 2017; the Circular No. 14/2019/TT-NHNN dated August 30, 2019, of the Governor of the State Bank of Vietnam, amends and supplements certain articles of circulars regulating the periodic reporting regime of the State Bank of Vietnam, and took effect on October 15, 2019; Circular No. 19/2021/TT-NHNN dated November 24, 2021, of the Governor of the State Bank of Vietnam, amends and supplements certain articles of Circular No. 01/2014/TT-NHNN dated January 6, 2014, stipulating the delivery, receipt, preservation and transport of cash, precious assets and valuable papers, and took effect on January 8, 2022; and the Circular No. 05/2025/TT-NHNN dated May 19, 2025, of the Governor of the State Bank of Vietnam, amends and supplements certain articles of Circular No. 01/2014/TT-NHNN dated January 6, 2014, stipulating the delivery, receipt, preservation and transport of cash, precious assets and valuable papers, and took effect on May 19, 2025.

      LEGAL UPDATE RELATING TO FINANCE AND CREDIT  (MONTHLY LEGAL UPDATE – 10&11/2025)

      LEGAL UPDATE RELATING TO FINANCE AND CREDIT (MONTHLY LEGAL UPDATE – 06/2025)

      1.     LEGAL DOCUMENTS ARE EFFECTIVE IN 04/2025

      1.1.  Circular No. 02/2025/TT-NHNN regulations on the issuance of domestic certificates of deposit by credit institutions and foreign bank branches

      • Name of legal document: Circular No. 02/2025/TT-NHNN issued on 29/04/2025 by the State Bank of Vietnam regulations on the issuance of domestic certificates of deposit by credit institutions and foreign bank branches (referred to as the “Circular No. 02/2025/TT-NHNN”).
      • Effective date: 16/06/2025.

      The content should be noted:

      • Firstly, stipulating the interest rate of certificates of deposit.

      Specifically, Article 6 of Circular No. 02/2025/TT-NHNN stipulates: Article 6. Interest rate

      The interest rate of certificates of deposit is determined by the issuing credit institution or foreign bank branch, in accordance with the interest rate regulations of the State Bank of Vietnam (hereinafter referred to as the State Bank) from time to time.

      The method for calculating interest on certificates of deposit shall comply with the regulations of the State Bank.”

      • Secondly, stipulating the face value of certificates of deposit.

      Specifically, Article 8 of Circular No. 02/2025/TT-NHNN stipulates:Article 8. Face value of certificates of deposit

      The face value of a certificate of deposit is VND 100,000 (one hundred thousand Vietnamese dong) or a multiple thereof. The specific face value shall be decided by the issuing credit institution or foreign bank branch, or agreed upon between the credit institution/foreign bank branch and the purchaser.”

      1.2.  Circular No. 03/2025/TT-NHNN on opening and use of VND-denominated accounts for conducting foreign indirect investment in Viet Nam

      • Name of legal document: Circular No. 03/2025/TT-NHNN issued on 29/04/2025 by the State Bank of Vietnam on opening and use of VND-denominated accounts for conducting foreign indirect investment in Viet Nam (referred to as the “Circular No. 03/2025/TT-NHNN”).
      • Effective date: 16/06/2025.

      The content should be noted: Obligations of authorized banks.

      Specifically, Article 7 of Circular No. 03/2025/TT-NHNN stipulates: “Article 7. Obligations of authorized banks

      1. Examine and retain relevant documents and records in accordance with actual transactions to ensure that the provision of foreign exchange services is performed for proper purposes and in compliance with legal regulations. Be held accountable under the law for the adequacy and validity of dossiers for opening indirect investment accounts.
      2. Issue internal regulations on dossiers, procedures, and processes for opening and using indirect investment accounts, and publicly notify such regulations to foreign investors for compliance. Internal regulations must at least include the following contents:a) Regulations on dossiers, procedures, and processes for opening indirect investment accounts;b) Regulations on agreements on the opening and use of indirect investment accounts;c) Regulations on the use of indirect investment accounts;d) Regulations on dispute settlement and complaint handling, and forms for requests for such settlement or complaints;dd) Regulations on risk management in the opening and use of indirect investment accounts in accordance with Article 5 and Article 6 of this Circular.
      3. Authorized banks shall be fully responsible under the law for the opening, closure, and execution of collection and payment transactions via indirect investment accounts for foreign investors.
      4. Comply with the regulations of law on anti-money laundering and combating the financing of terrorism and proliferation of weapons of mass destruction.
      5. Strictly comply with and guide clients in complying with the provisions on the opening and use of indirect investment accounts as stipulated in this Circular and other relevant legal regulations.”
      LEGAL UPDATE RELATING TO FINANCE AND CREDIT  (MONTHLY LEGAL UPDATE – 10&11/2025)

      LEGAL UPDATE RELATING TO FINANCE AND CREDIT (MONTHLY LEGAL UPDATE – 05/2025)

      1.       LEGAL DOCUMENTS ARE ISSUED IN 04/2025

      2.1. Decree No. 94/2025/ND-CP stipulating the regulatory sandbox mechanism in the banking sector

      • Name of legal document: Decree No. 94/2025/ND-CP issued on 29/04/2025 by the Government stipulating the regulatory sandbox mechanism in the banking sector.
      • Effective date: 01/07/2025.

      The content should be noted:

      • Firstly, stipulating the duration, geographical scope, and scope of the pilot.

      Specifically, Article 6 of Decree No. 94/2025/ND-CP stipulates: Article 6. Duration, geographical scope, and scope of the pilot

      1. The maximum duration for testing Fintech solutions is 2 years, depending on the specific solution and field, starting from the date the State Bank of Vietnam issues the Certificate of Participation in the Regulatory Sandbox. The testing period may be extended as stipulated in Article 20 of this Decree.

      The term of the Certificate of Participation in the Regulatory Sandbox shall not exceed the duration (if any) of the Establishment License or the Business Registration Certificate of the organization participating in the sandbox.

      1. Geographical scope:

      The implementation of Fintech pilot solutions is limited to the territory of Vietnam and shall not be conducted across borders.

      1. Scope of the pilot:a) Organizations participating in the Regulatory Sandbox may only provide Fintech solutions within the scope defined in the Certificate of Participation in the Regulatory Sandbox;b) Depending on the Fintech solution and the specific proposal submitted by the organization in the sandbox registration dossier, and based on the opinions of relevant ministries, the State Bank of Vietnam shall determine the scope of the Fintech solution’s pilot in the Certificate of Participation in the Regulatory Sandbox;c) Peer-to-peer (P2P) lending companies may only provide P2P lending solutions within the pilot scope specified in the Certificate of Participation in the Regulatory Sandbox issued by the State Bank of Vietnam in accordance with this Decree. P2P lending companies participating in the sandbox are not allowed to engage in business activities not listed in the Certificate of Participation in the Regulatory Sandbox. They may not provide self-guarantees for customer loans, act as borrowers themselves, or offer P2P lending solutions to pawnshops.”
      • Secondly, stipulating the conditions and criteria for participating in the Regulatory Sandbox.

      Specifically, Article 8 of Decree No. 94/2025/ND-CP stipulates:Article 8. Conditions and criteria for participating in the Regulatory Sandbox

      1. Credit institutions not under special control pursuant to the Law on Credit Institutions, and branches of foreign banks, may be considered for issuance of a Certificate of Participation in the Regulatory Sandbox when their Fintech solutions meet the following criteria:a) The solution involves technical and operational content that is not yet clearly or specifically regulated under current legal provisions;b) The solution is innovative, provides benefits and added value to users in Vietnam, especially those that support and promote financial inclusion;c) The solution has a developed risk management framework to minimize negative impacts on the banking and financial-monetary-foreign exchange systems; has contingency plans to address risks during the pilot; and has plans in place to protect consumer rights;d) The solution has been fully reviewed and evaluated by the participating organization in terms of operations, functionality, usability, and usefulness;e) The solution is feasible for market deployment after successful completion of the pilot phase.
      2. Fintech companies may be considered for issuance of a Certificate of Participation in the Regulatory Sandbox when their Fintech solutions meet the criteria in Clause 1 of this Article and satisfy the following conditions:a) Be a legal entity established and operating lawfully in Vietnam; not undergoing division, separation, consolidation, merger, transformation, dissolution, or bankruptcy in accordance with the law;b) The legal representative and General Director (Director) must possess a university degree or higher in economics, business administration, law, or information technology, and have at least 2 years of experience as a manager or executive in an organization in the finance or banking sector, and must not be subject to any legal prohibitions.
      3. Organizations participating in the Regulatory Sandbox must ensure that they continuously meet all conditions during their participation in the sandbox.”

      2.2.  Circular No. 02/2025/TT-NHNN regulations on the issuance of domestic certificates of deposit by credit institutions and foreign bank branches

      • Name of legal document: Circular No. 02/2025/TT-NHNN issued on 29/04/2025 by the State Bank of Vietnam regulations on the issuance of domestic certificates of deposit by credit institutions and foreign bank branches (referred to as the “Circular No. 02/2025/TT-NHNN”).
      • Effective date: 16/06/2025.

      The content should be noted:

      • Firstly, stipulating the interest rate of certificates of deposit.

      Specifically, Article 6 of Circular No. 02/2025/TT-NHNN stipulates: Article 6. Interest rate

      The interest rate of certificates of deposit is determined by the issuing credit institution or foreign bank branch, in accordance with the interest rate regulations of the State Bank of Vietnam (hereinafter referred to as the State Bank) from time to time.

      The method for calculating interest on certificates of deposit shall comply with the regulations of the State Bank.”

      • Secondly, stipulating the face value of certificates of deposit.

      Specifically, Article 8 of Circular No. 02/2025/TT-NHNN stipulates:Article 8. Face value of certificates of deposit

      The face value of a certificate of deposit is VND 100,000 (one hundred thousand Vietnamese dong) or a multiple thereof. The specific face value shall be decided by the issuing credit institution or foreign bank branch, or agreed upon between the credit institution/foreign bank branch and the purchaser.”

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