On the afternoon of August 24, with 473/476 deputies voting in favor (94.6%), the National Assembly passed a law amending and supplementing several articles of the Law on the State Bank of Vietnam, the Law on Anti-Money Laundering, and the Law on Credit Institutions. The law takes effect on December 1, 2026, from which point crypto asset service providers will officially be classified as reporting entities under anti-money laundering legislation, obligated to report suspicious transactions to the State Bank of Vietnam.

At the core of the legislation is a set of 15 suspicious indicators codified into law for the first time, focusing on asset movement patterns and the concealment of fund sources. The most closely scrutinized behavioral patterns include:

  • Splitting transactions into multiple amounts below the reporting threshold; conducting numerous large transactions within a short timeframe without a clear purpose.
  • Depositing, trading, and then withdrawing assets consecutively immediately after opening an account.
  • Converting crypto into fiat currency under unfavorable price conditions, accepting unusual losses or fees.
  • Transacting through mixers, using privacy-enhancing tools, and repeatedly switching between transparent and privacy assets; using wallets with transaction histories involving high-risk bridges.
  • Multiple accounts under different names sharing the same device or IP address; executing transactions to countries on the FATF warning list without a reasonable justification.

National Assembly deputies also highlighted two accompanying requirements: these 15 indicators must be continuously updated in response to emerging technologies and new criminal tactics, and organizations must possess sufficient data, technology, and personnel to genuinely detect risks rather than treating compliance as a mere administrative formality.

The broader context is tied to commitments made to the FATF. According to the Government Inspectorate, as of May 2026, Vietnam still had 14 out of 17 action items left to complete under its roadmap to exit the enhanced monitoring list, ahead of the third round of mutual evaluations in 2028. On the very day the law was passed, the Deputy Inspector General of the Government Inspectorate directed Department VI to propose at least one thematic inspection on AML before the end of the year, while the Ministry of Finance was tasked with inspecting the crypto asset sector as assigned by the Government.

Viewed within the sequence of regulatory steps taken since 2025 (the Resolution on the market pilot program, Circulars on accounting and taxation, and the Decree on administrative sanctions effective September 1, 2026), this AML piece makes the legal framework for digital assets in Vietnam fairly comprehensive in structure: issuance, trading, taxation, penalties, and now anti-money laundering. For domestic exchange and service operators, December this year marks the first practical compliance milestone; the true challenge lies not in understanding the regulations, but in building transaction monitoring systems robust enough to comply with them.