【Vietnam】Vietnam Updates Anti-Money Laundering Framework: Reporting on Large Cash Transactions

Editor’s Note

This article discusses Vietnam’s new financial reporting rules for large domestic cash transfers, a significant move in the country’s ongoing efforts to modernize its financial infrastructure and combat illicit financial flows.

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Vietnam has introduced new reporting requirements for high-value domestic cash transactions, marking another step in its effort to modernize the financial system and align with global anti-money laundering (AML) standards.

The State Bank of Vietnam (SBV) has recently issued Circular No. 27/2025/TT-NHNN (“Circular 27”), which requires any domestic transfer of VND 500 million (approximately US$19,000) or more to be reported to the SBV’s Anti-Money Laundering Department.
This update strengthens Vietnam’s financial transparency framework and reflects the government’s continued push toward international compliance standards. For businesses, investors, and financial institutions, the rule reinforces the importance of maintaining clear transaction records and adopting robust compliance processes to navigate the evolving regulatory environment.

Background and regulatory landscape

Vietnam’s financial sector has undergone steady modernization in recent years, driven by rising investment flows, expanding digital banking, and the government’s goal of aligning with global anti-money laundering (AML) and counter-terrorist financing (CFT) standards.
The 2022 Law on Anti-Money Laundering laid the foundation for this framework, giving the SBV greater authority to regulate, monitor, and report suspicious financial activities.
Circular 27, issued on September 15, 2025, provides detailed guidance for implementing this law and operationalizing domestic transaction monitoring.
Vietnam’s move also responds to recommendations from the Financial Action Task Force (FATF) and the Asia/Pacific Group on Money Laundering (APG), which have encouraged the country to strengthen both its cross-border and domestic transaction surveillance. With financial transactions increasing in volume and complexity, the SBV is seeking to tighten traceability and mitigate risks associated with money laundering, tax evasion, and illicit financial flows.
This proactive regulatory tightening reflects Vietnam’s ambition to be viewed as a credible and transparent financial hub – a key factor in maintaining investor confidence and sustainable capital inflows.

Key provisions

Reporting threshold and scope
Circular 27 mandates that all domestic money transfers equal to or exceeding VND 500 million (US$19,000), or the equivalent in foreign currency, be reported to the SBV’s AML Department. The rule applies to both individuals and organizations, including corporations, financial institutions, and non-bank entities involved in the transfer or processing of funds. Cross-border transactions valued at US$1,000 or more are also subject to reporting.
The reporting requirement covers:

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Category Required information
Ordering and beneficiary financial institutions • Transaction name of institution/branch;
• Head office address (or bank code for domestic transfers SWIFT code for international transfers); and
• Country of receipt and remittance.
Individual customers • Full name;
• Date of birth;
• ID/ Citizen ID/ Personal ID/ Passport number;
• Entry visa number (if any);
• Registered permanent residence or current address (if any); and
• Nationality (per transaction documents).
Organizational customers • Full and abbreviated transaction name (if any);
• Head office address;
• Establishment license number or enterprise code or tax code; and
• Country of head office.
Transaction information • Account number (if any);
• Transaction amount;
• Currency;
• Amount converted to VND (if foreign currency);
• Reason and purpose of transaction;
• Transaction date;
• Transaction code or unique reference number (if no account number); and
• Identifier of the originator sent by ordering/intermediary financial institution for traceability.
Other information • Any additional information required by the Department of Anti-Money Laundering for AML state management in each period

This marks the first time that large-value domestic transfers, not just suspicious or cross-border transactions, have been brought under a formal reporting threshold.
Reporting method and content
Financial institutions are required to submit transaction reports immediately after execution using the SBV’s electronic AML reporting system. Reports must include:
• Sender and beneficiary identification details;
• Transaction value, date, and purpose;

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• Relationship between the parties (if applicable); and
• Source of funds and documentary verification of the transaction’s legitimacy.
Entities must also maintain a record of such transactions for a prescribed period to support future audits and compliance reviews by the SBV or related agencies.
Transactions exempt from reporting
Transactions that are not subject to reporting include:
• Wire transfers from debit, credit, or prepaid card transactions for payment of goods and services; and
• Wire transfers and payments between financial institutions, where both the sender and the recipient are financial institutions conducting transactions on their own behalf.
Customs declaration thresholds
Circular 27 sets out specific value thresholds requiring individuals to declare certain assets upon entering or exiting Vietnam, as well as the documents they must present to customs officers when carrying these items.

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Category Threshold Covered items
Precious metals and gemstones ≥ VND 400 million Gold, silver, platinum, diamonds, rubies, sapphires, emeralds, and other precious stones.
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⏰ Published on: November 14, 2025