2026
9 MIN READ
A Ministry of Finance document dated 12 March 2026 confirmed that five companies have cleared Stage One of Vietnam's inaugural crypto-asset exchange licensing process — while Hanoi drafts legislation to ban domestic investors from trading on unlicensed foreign platforms. This inflection point is defining the VASP license Vietnam framework and what compliance will mean in the country's next regulatory chapter.
The Starting Gun: Vietnam Opens Its First Exchange Licence Window
On 20 January 2026, Vietnam's Ministry of Finance began accepting applications for licences to operate crypto-asset exchanges — a milestone that would have been difficult to predict even two years ago. The legal basis is Government Resolution 05/2025/NQ-CP, dated September 2025, which authorised the pilot of a regulated crypto-asset market. The implementing framework, Decision No. 96/QĐ-BTC, set out a two-stage licensing process that filters applicants on capital, ownership structure, and governance before any operational requirements are assessed.
The significance of this opening should not be understated. Vietnam has ranked fourth in Chainalysis' Global Crypto Adoption Index, with Vietnamese users estimated to have moved approximately USD 200 billion in crypto in the year through June 2025. That market has operated, until now, almost entirely through unlicensed foreign platforms — Binance, OKX, and a range of other offshore exchanges. The licensing programme is Vietnam's first systematic attempt to bring that activity under domestic regulatory supervision.
For businesses evaluating Vietnam as a market — whether as exchange operators, institutional participants, or compliance advisors — the critical development is not simply that the window has opened. It is what the first round of applications and screenings reveals about the practical shape of the licensing regime and the compliance standards it will embed.
Five Companies Clear Stage One: Reading the Selection Signal
A Ministry of Finance document dated 12 March 2026 disclosed that five companies had cleared Stage One of the licensing process. These are affiliates of three private banks — Techcombank, VPBank, and LPBank — alongside VIX Securities and a subsidiary of the Sun Group conglomerate. This is not a random sample. It is a deliberate signal about the type of entity Vietnam intends to license.
The concentration of bank affiliates among the Stage One qualifiers reflects a regulatory design choice. The licensing framework requires that at least 35% of capital be contributed by a minimum of two financial institutions operating in banking, securities, fund management, insurance, or technology. That requirement effectively anchors the first generation of licensed exchanges to established financial institutions — entities that already operate under the SBV's supervisory framework and carry existing AML/CFT obligations. The regulator is not starting from scratch with unknown operators. It is extending regulated status to entities that already sit within the regulatory perimeter.
This selection pattern also has implications for how the compliance bar will be set. When bank affiliates constitute the reference cohort for the first licensed exchanges, the AML/CFT program standards, transaction monitoring expectations, and governance requirements that those entities apply internally will become the de facto baseline. International operators and new entrants will be assessed against that baseline — and it will be a demanding one.
The Capital Barrier: Market Architecture, Not Just Compliance
The minimum contributed charter capital requirement of VND 10 trillion — approximately USD 380 million — is the most widely reported feature of the licensing framework, and it warrants careful analysis. To put it in context: Hong Kong's VASP licensing regime under the SFC requires a minimum of HKD 5 million, roughly USD 640,000. Vietnam's threshold is approximately 600 times higher. This is not a compliance barrier in the conventional sense. It is a market architecture decision.
The capital threshold, combined with the requirement for at least 65% of capital to come from institutional shareholders and the 49% cap on foreign ownership, produces a framework that can only be satisfied by well-capitalised Vietnamese enterprises with significant institutional backing. The regulatory intent is clear: Vietnam does not want a fragmented market of dozens of lightly capitalised exchanges. It wants a small number of systemically significant, institutionally anchored domestic platforms that it can supervise effectively and that can anchor the capital flow redirection it is planning.
For international businesses, the 49% foreign ownership cap is the structural constraint that shapes every market entry strategy. A foreign operator cannot control a licensed Vietnamese exchange outright. It can be a minority shareholder. The practical implication is that market access requires a Vietnamese partner of substance — an entity with sufficient capital, institutional backing, and regulatory relationships to be eligible for the licensing process. Identifying, qualifying, and structuring a partnership with such an entity is not a simple transaction. It is a multi-stage advisory engagement.
The Offshore Trading Ban: A Strategic Dual Move
Concurrent with the licensing rollout, the Ministry of Finance is drafting legislation that would prohibit Vietnamese citizens from trading on unlicensed foreign platforms. Reporting from March 2026 indicates that violations would be subject to administrative and potentially criminal penalties. If enacted, this would redirect the estimated USD 200 billion in annual Vietnamese crypto transaction volume that currently flows through foreign platforms into the domestic licensed market.
This dual strategy — licensing domestic platforms while restricting foreign access — is consistent with Vietnam's broader approach to financial regulation. The same architecture governs payment intermediary services: offshore providers cannot offer intermediary payment services in Vietnam; only locally licensed entities can. The crypto framework is being built on that same foundational principle. Vietnam is not attempting to integrate its digital asset market into the global infrastructure on terms set by foreign platforms. It is creating a regulated domestic market on its own terms.
For compliance purposes, the offshore trading ban creates a new category of risk for businesses operating in or adjacent to the Vietnamese market. Institutional clients, distributors, or partners that currently route Vietnamese users through foreign platforms will need to assess their exposure. The enforcement timeline is not yet clear, but the direction is — and businesses that wait for formal enforcement before adjusting their structures will be managing a problem rather than a strategy.
AML/CFT and FATF Compliance as the Licensing Prerequisite
Vietnam has been on the FATF grey list since 2023, identified for deficiencies in AML/CFT controls including insufficient regulation of virtual assets and VASPs. The entire crypto regulatory programme — the Digital Technology Industry Law, Resolution 05/2025, and the exchange licensing framework — is designed in part to address those FATF deficiencies and build the case for grey list exit. The licensing framework's AML/CFT requirements are not incidental. They are central to the policy objective.
Stage Two of the licensing process requires applicants to submit operational procedures, technology assessments, and cybersecurity certifications within a 12-month window from Stage One clearance. In practice, this means that AML/CFT program design, transaction monitoring architecture, KYC/KYB workflows, STR reporting procedures, and Travel Rule compliance infrastructure all need to be built, documented, and evidenced before the application is complete. The standard that will be applied is informed by FATF Recommendation 15 — the recommendation that specifically addresses virtual asset regulation — and by the SBV's own AML framework as updated by Circular 27/2025/TT-NHNN.
Circular 27 — in effect from November 2025 — introduced standardised risk scoring across a 1-to-5 scale, expanded CDD requirements for beneficial ownership, and established new transaction reporting thresholds including a VND 500 million threshold for large domestic transfers. VASPs operating under the sandbox or seeking licensing under the new framework are subject to these requirements. The compliance infrastructure required for a licensing application is not a simplified version of general AML compliance. It is a full institutional-grade AML program applied to the specific characteristics of digital asset transaction flows.
What Stage Two Requires: The Compliance Build Ahead
The five companies that cleared Stage One have up to 12 months to submit the Stage Two documentation package. That package will include operational manuals covering all material functions of the exchange, technology assessments and cybersecurity certifications meeting Vietnamese technical standards, internal governance documentation including board-level compliance reporting structures, and an AML/CFT program with sufficient operational history to demonstrate that it functions as designed — not merely that it exists on paper.
The requirement for an AML program with operational history is the element most likely to create practical difficulty for applicants that have not been operating under the sandbox. A policy document, however well drafted, is not evidence that an AML program operates effectively. Evidence is transaction monitoring logs demonstrating alerts are generated and resolved. Evidence is STR filing records. Evidence is training records and compliance officer reporting. Assembling this evidence requires having operated the program for a sufficient period — and that period needs to begin now for any entity that intends to apply in the next licensing cycle.
The cybersecurity and technology requirements add a further dimension. Vietnam's Law on Cybersecurity and the technical standards applicable to financial infrastructure are specific and demanding. Exchanges will need to demonstrate that their technology platforms meet Vietnamese standards for data localisation, incident response, and operational resilience. International technology providers operating in this space need to assess their architecture against Vietnamese technical requirements — not assume that meeting standards in their home jurisdiction is equivalent.
Implications for International VASP Operators and Institutional Participants
For international VASP operators considering the Vietnamese market, the landscape is now substantially clearer than it was twelve months ago. The licensing framework is real, the capital and ownership requirements are established, the AML/CFT standards are defined, and the first round of qualified applicants has been identified. What was previously strategic optionality has become a concrete planning horizon.
The 49% foreign ownership cap makes local partnership the only viable route to a licensed presence. That partnership needs to be with an entity capable of meeting the capital and institutional backing requirements — a financial institution, a major securities firm, or a conglomerate with sufficient capital and regulatory standing. The due diligence required to identify and qualify a partner of that calibre is itself a significant engagement. And the compliance architecture required to support a licensing application needs to be designed and built before, not during, that process.
For institutional participants — funds, banks, and financial intermediaries with Vietnamese client bases or investment exposure to Vietnamese digital asset businesses — the licensing programme defines the compliance framework against which counterparty diligence will increasingly be assessed. Portfolios that include Vietnamese digital asset businesses, or that route Vietnamese clients through crypto infrastructure, will face questions about whether those businesses are licensing-eligible and what their FATF-aligned AML programs look like. The businesses that have built their compliance infrastructure ahead of these questions will present materially differently than those that have not.
Krysos Trust's founder brings direct experience in Vietnam's crypto regulatory environment — as founding compliance lead for the first crypto project admitted into Vietnam's regulatory sandbox, and as sell-side counsel on a USD 15 million crypto M&A transaction. The firm is positioned to advise on licensing strategy, AML/CFT program design for VASP applicants, local partnership structuring, and compliance readiness assessment. The window for proactive positioning is open now.
