Law No. 23/2026/QH16: Suspicious indicators for crypto assets
Vietnam Strengthens Anti-Money Laundering Requirements for Crypto-Assets
Vietnam is taking another important step towards strengthening oversight of crypto-asset transactions.
Law No. 23/2026/QH16, effective 1 December 2026, introduces 15 specific indicators of suspicious crypto-asset transactions and strengthens anti-money laundering (AML) compliance requirements.
In our latest DN Legal – Did You Know?, we examine the implications for crypto-asset service providers and the practical steps businesses need to take.
What should businesses prepare?
🔹 Customer due diligence — review customer identification, verification and beneficial ownership procedures, including the identification of higher-risk customers.
🔹 Transaction monitoring — update systems to detect the 15 suspicious indicators, including transaction splitting, unusual wallet activity, rapid transfers and dealings with high-risk jurisdictions.
🔹 Suspicious transaction reporting — establish clear procedures for investigating unusual transactions, documenting assessments and escalating reportable transactions to the State Bank of Vietnam.
🔹 Internal compliance controls — update AML policies, train relevant personnel and ensure adequate recordkeeping and audit trails.
Understanding the USD 1,000 threshold
Under Vietnam’s existing crypto-asset pilot framework, customer identification requirements apply to occasional transactions valued at USD 1,000 or more (or the equivalent).
This threshold is relevant to when customer identification must be undertaken, not whether a transaction is suspicious.
Businesses must therefore distinguish between two separate obligations:
* Customer identification: applying the prescribed identification and verification requirements, including the relevant transaction threshold.
* Suspicious transaction reporting: assessing transactions for potential money laundering and reporting where there are reasonable grounds to suspect that the assets involved are proceeds of crime, regardless of transaction value.
Importantly, the presence of a suspicious indicator does not automatically require a report. It triggers the need for appropriate assessment.
The key takeaway: Compliance cannot rely on transaction values alone. Businesses need effective customer due diligence, risk-based monitoring and documented decision-making procedures.
Our Legal Update examines the new requirements, the 15 suspicious indicators and practical compliance recommendations.
Read the full DN Legal Legal Update attached below.
DN Legal | International Perspective. Deep Local Knowledge.
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