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Vietnam

Retail_Trading_Status

Gray-Zone Unknown

Status Changed

Previous status: Allowed-UnRegulated

The shift in the assessed status of Retail_Trading_Status in Vietnam from "Allowed-UnRegulated" in the Previous Analysis (dated April 12, 2025) to "Gray-Zone" in the New Analysis (dated June 26, 2025) is primarily justified by significant legislative developments and a more nuanced understanding of the evolving regulatory landscape that occurred in the interim period. The core reason for the change is the passage of the Law on Digital Technology Industry by the National Assembly on June 14, 2025, which is set to take effect in 2026. This law is a pivotal development not available or fully incorporated into the Previous Analysis. Here's a detailed justification for the differences: 1. Introduction of Foundational Legal Recognition: The Previous Analysis correctly stated that owning, trading, or holding cryptocurrencies was not explicitly illegal, existing in a "legal gray area" and being "largely unregulated." It anticipated a legal framework around Q2 2025. The New Analysis incorporates the passage of the Law on Digital Technology Industry. This law, for the first time, legally recognizes digital assets, including virtual assets and cryptoassets. This is a fundamental shift from a purely unregulated space to one where these assets have a nascent legal definition. However, the status is termed "Gray-Zone" because this law is foundational and not yet fully implemented with detailed, specific regulations for retail trading. 2. Timing and Implementation Gap: The Previous Analysis focused on the *absence* of a specific framework. The New Analysis acknowledges the *creation* of a foundational framework (the new Law) but emphasizes that its effective date is in 2026 and that detailed implementing decrees and circulars regarding retail trading, exchange licensing, and specific operational guidelines are still required. This interim period, where a law exists but its practical application and comprehensive supporting regulations are still developing, perfectly defines a "Gray-Zone." It's no longer entirely "unregulated" because a law now touches upon it, but it's not yet "regulated" in a comprehensive, operational sense for retail traders. 3. Nuance of "Gray-Zone" vs. "Allowed-UnRegulated": "Allowed-UnRegulated" (Previous Analysis) implied a passive stance from the government regarding individual trading, with the main restriction being on payment. "Gray-Zone" (New Analysis) captures a more active but incomplete regulatory evolution. It reflects the tension between high public adoption, the new legal recognition of digital assets, the ongoing prohibition of crypto as payment, and the fact that specific rules for investor protection, exchange operation, and taxation are still being formulated or are yet to come into full effect. The new law moves the needle from "unregulated" but doesn't yet provide full clarity, hence the "grayness." 4. Evolution of Regulatory Development Narrative: The Previous Analysis mentioned the government was "actively working on developing a comprehensive legal framework" expected by May 2025. The New Analysis provides an update on this, noting the actual passage of the Law on Digital Technology Industry in June 2025. It also details that while this law is a major step, the Ministry of Finance (MoF) is still tasked with developing further frameworks and that discussions around pilot programs and the MoF's reservations about rushing implementation continue. This shows a more complex and phased approach to regulation than perhaps anticipated in the earlier report. 5. AML/CFT Context: Both analyses mention AML/KYC expectations. The New Analysis, however, more explicitly links the AML safeguards mandated by the new Law on Digital Technology Industry to international standards and the need to address concerns raised by the Financial Action Task Force (FATF), given Vietnam's inclusion on the grey list. This adds another layer to why the regulatory environment is in flux and under development. 6. Clarity on Taxation: The New Analysis reiterates the current ambiguity in cryptocurrency taxation but frames it within the context of the upcoming legal framework, anticipating that tax regulations for digital assets will be developed as a consequence of the new law. This reinforces the transitional nature of the "Gray-Zone." In summary, the New Analysis presents a more current and refined assessment. The passage of the Law on Digital Technology Industry in June 2025 is the primary catalyst for shifting the status from "Allowed-UnRegulated" to "Gray-Zone." While this law provides initial legal recognition, the fact that it is not effective until 2026 and requires substantial detailed implementing regulations means that the retail trading environment remains in a state of ambiguity and transition, which is better encapsulated by the term "Gray-Zone." The activity is no longer purely in a vacuum of specific legislation but is not yet under a clear, comprehensive, and operational regulatory regime.

Analysis ID
#568
Version
Latest
Created
2025-06-26 13:30
Workflow Stage
Live

Executive Summary

As of June 2025, Vietnam's regulatory landscape for retail crypto trading remains in a "Gray-Zone." While the use of cryptocurrencies as a payment method is explicitly prohibited and carries severe penalties, a comprehensive legal framework for the broader crypto market, including licensing for exchanges and clear taxation rules, is still under development. Although a significant "Law on Digital Technology Industry" was passed in June 2025, establishing a legal foundation for digital assets, its detailed regulations and full effect are slated for January 2026. This period is characterized by ongoing governmental efforts to formulate a robust regulatory approach to manage and potentially leverage digital assets while mitigating associated risks.

Key Pillars

  • Prohibition of Crypto as Payment: The use of cryptocurrencies as a means of payment for goods and services is strictly illegal across Vietnam.

  • Absence of Comprehensive Regulation: No overarching legal framework is yet fully in force that comprehensively governs the issuance, trading, or ownership of crypto assets, leading to a regulatory vacuum for many activities.

  • Pending Licensing and Taxation: Specific licensing requirements for cryptocurrency exchanges and clear, comprehensive taxation rules for crypto-related activities are still being formulated and are not yet implemented.

  • Regulatory Framework Under Development: Various governmental bodies are actively engaged in drafting and implementing new laws and decrees to establish a clearer legal environment for digital assets.

Landmark Laws

Decree No. 88/2019/ND-CP on administrative sanctions for monetary-banking infringements, as amended by Decree 143/2021/ND-CP. Decree 52/2024/ND-CP, newly issued on May 15, 2024, also stipulates that cryptocurrency is not a recognized form of cashless payment.
- Authority: State Bank of Vietnam (SBV) in conjunction with the Government of Vietnam. Initial pronouncements from the SBV affirming cryptocurrencies are not legal tender date back to October 2017.
- Date: Decree 88/2019/ND-CP (October 2019), Decree 143/2021/ND-CP (December 2021), Decree 52/2024/ND-CP (May 2024).
- Summary: Strictly prohibits the issuance, supply, and use of cryptocurrencies as currency or payment instruments. Violations can incur administrative fines ranging from VND 50,000,000 to VND 100,000,000, with potential criminal prosecution for severe cases under Article 206 of the Criminal Code 2015.

Law on Digital Technology Industry.
- Authority: National Assembly of Vietnam.
- Date: Passed on June 14, 2025.
- Summary: This landmark law officially legalizes crypto assets and creates a regulatory framework classifying digital assets as "virtual assets" or "crypto assets." However, its detailed regulations and full effect are scheduled to commence on January 1, 2026. As of June 2025, it primarily lays the groundwork for future specific business rules and oversight mechanisms, including cybersecurity and anti-money laundering standards.

Considerations

  • Asset Classification: As of June 2025, Vietnam's existing civil laws do not clearly define or classify cryptocurrencies as a specific type of property, commodity, or security. This ambiguity has historically made it challenging to apply existing legal provisions. However, the DTI Law, passed in June 2025 but effective January 2026, begins to categorize them as virtual or crypto assets, explicitly excluding securities, digital fiat currencies, and other financial instruments under existing frameworks.

  • Taxation: Clear taxation rules for cryptocurrency transactions are still pending. The Ministry of Finance is actively working on a draft resolution to propose a pilot program for taxing digital assets, acknowledging the complexity due to the lack of clear classification. This initiative aims to define tax obligations and explore effective collection methods.

  • Enforcement: Despite the lack of comprehensive regulation for trading and ownership, the prohibition on using crypto as payment is enforced, carrying significant fines and potential criminal charges. Law enforcement agencies, such as the Hanoi City Police Department, continue to issue warnings against such activities.

Notes

  • The Vietnamese government is actively engaged in developing a more robust regulatory framework for digital assets. This ongoing process is driven by several factors, including the high rate of crypto adoption within Vietnam and the need to address risks like fraud, money laundering, and tax evasion, as well as to facilitate innovation.

  • Pilot Programs and Regulatory Sandbox: The Ministry of Finance (MoF), in coordination with the State Bank of Vietnam (SBV) and the Ministry of Public Security, is proposing a pilot program for the issuance and trading of crypto assets. This includes discussions on stringent licensing conditions for cryptocurrency exchanges, such as a minimum paid-in charter capital of VND 10 trillion (approximately USD 385 million). A regulatory sandbox is also being considered to evaluate compliance frameworks for anti-money laundering (AML) and know-your-customer (KYC) protocols, and the use of stablecoins.

  • Government Directives: Prime Minister Pham Minh Chinh has issued directives (e.g., Directive No. 05/CT-TTg in March 2025) instructing the MoF and SBV to propose a legal framework for managing and promoting digital assets and currencies. Earlier, Decision No. 194/QD-TT-g (February 2024) also assigned the MoF to draft a legal framework by May 2025.

  • International Alignment: Efforts are underway to align Vietnam's legal framework with international standards, particularly concerning anti-money laundering and counter-terrorism financing, as Vietnam has been on the Financial Action Task Force's (FATF) "gray list." The enactment of the DTI Law is expected to help address these concerns.

  • Inter-Ministerial Coordination: Key agencies involved in developing the new framework include the Ministry of Finance, the State Bank of Vietnam, the Ministry of Public Security, and the Ministry of Science and Technology, reflecting a multi-faceted approach to regulation.

Detailed Explanation

As of June 2025, Vietnam's regulatory environment for retail crypto trading is best characterized as a "Gray-Zone," reflecting a period of transition and active development rather than definitive clarity. The core reason for this status lies in the significant disparity between the widespread adoption and use of cryptocurrencies by the Vietnamese public and the government's still-evolving official stance. The most definitive aspect of current regulation is the strict prohibition on using cryptocurrencies as a means of payment. This prohibition is robustly enforced, with individuals and organizations found using crypto for transactions facing substantial administrative fines under decrees like No. 88/2019/ND-CP and its amendments, and potentially even criminal prosecution. This firm stance from the State Bank of Vietnam, reiterated consistently since 2017, underscores the government's intent to maintain control over the national currency and financial stability.However, beyond the payment ban, the regulatory landscape for other aspects of retail crypto trading, such as ownership, investment, and exchange operations, remains largely undefined. There is no comprehensive law currently in force that provides clear guidelines for these activities, creating a "murky" legal area where trading and holding cryptocurrencies are not explicitly illegal, but also lack official recognition, protection, or supervision. This regulatory vacuum has presented challenges for both investors, who lack legal recourse in disputes, and authorities, who struggle with oversight, tax collection, and preventing illicit activities like money laundering.Significant strides were made in June 2025 with the passage of the "Law on Digital Technology Industry" by the National Assembly. This legislation is pivotal as it officially "legalizes" crypto assets by introducing classifications for "virtual assets" and "crypto assets." However, it is crucial to note that this law is set to take effect on January 1, 2026, and primarily serves as a foundational framework. It assigns the government the responsibility to issue more detailed regulations concerning classification, business conditions, and management. Therefore, as of June 2025, its direct impact on day-to-day retail trading regulations is anticipatory rather than immediate.The ongoing development of the regulatory framework is a multi-ministerial effort, coordinated by key agencies such as the Ministry of Finance (MoF), the State Bank of Vietnam (SBV), and the Ministry of Science and Technology. Directives from the Prime Minister, like Directive No. 05/CT-TTg in March 2025, have tasked these bodies with proposing comprehensive legal frameworks. The MoF, for instance, is actively drafting resolutions for a pilot program concerning the issuance and trading of digital assets, which includes discussions on substantial minimum capital requirements for crypto exchanges, signaling an intent towards future licensing and formalization of the market. Additionally, efforts are being made to establish clear taxation policies, an area currently lacking definitive rules due to the absence of clear asset classification. The government is exploring mechanisms to collect taxes from crypto activities, including potential temporary guidelines. The implementation of a regulatory sandbox is also under consideration to test new regulations and technologies in a controlled environment. These proactive steps demonstrate Vietnam's commitment to eventually establishing a regulated digital asset ecosystem, influenced by the country's high crypto adoption rate and the need to align with international anti-money laundering standards. Despite these developments, for June 2025, the overarching status remains one of a "Gray-Zone," characterized by a clear payment ban alongside a pending, but rapidly progressing, regulatory architecture for other crypto activities.

Summary Points

Here's a clear, well-structured bullet point summary of Vietnam's retail crypto trading regulations as of June 2025:

### Vietnam's Retail Crypto Trading Regulations: A Gray-Zone Landscape (June 2025)

1. Regulatory Status

  • Overall Status: "Gray-Zone" as of June 2025.
  • Key Characteristics:
  • Explicit prohibition of cryptocurrencies as a payment method.
  • Absence of a comprehensive legal framework for broader crypto market activities (e.g., trading, ownership, exchange licensing).
  • Period of active governmental development towards a robust regulatory approach.

2. Key Regulatory Bodies & Their Roles

  • State Bank of Vietnam (SBV):
  • Primary authority for monetary policy; issued decrees prohibiting crypto as legal tender/payment.
  • Involved in proposing legal frameworks and pilot programs.
  • Government of Vietnam:
  • Approves decrees and oversees policy implementation.
  • National Assembly of Vietnam:
  • Legislative body responsible for passing laws (e.g., Law on Digital Technology Industry).
  • Ministry of Finance (MoF):
  • Actively drafting resolutions for pilot programs on crypto issuance/trading and taxation.
  • Tasked with proposing legal frameworks for digital assets.
  • Ministry of Public Security (MoPS):
  • Involved in enforcement, addressing risks like fraud and money laundering.
  • Participates in discussions for pilot programs.
  • Ministry of Science and Technology (MoST):
  • Involved in the broader digital technology industry framework development.
  • Prime Minister (PM):
  • Issues directives to ministries for developing comprehensive legal frameworks.

3. Important Legislation & Regulations

  • Prohibition on Crypto as Payment Instruments:
  • Legislation: Decree No. 88/2019/ND-CP (Oct 2019), amended by Decree 143/2021/ND-CP (Dec 2021), and Decree 52/2024/ND-CP (May 2024).
  • Authority: State Bank of Vietnam (SBV) in conjunction with the Government of Vietnam.
  • Impact:
  • Strictly prohibits the issuance, supply, and use of cryptocurrencies as currency or payment instruments.
  • Penalties: Administrative fines ranging from VND 50,000,000 to VND 100,000,000.
  • Severe Cases: Potential criminal prosecution under Article 206 of the Criminal Code 2015.
  • Law on Digital Technology Industry (DTI Law):
  • Authority: National Assembly of Vietnam.
  • Date Passed: June 14, 2025.
  • Impact (as of June 2025):
  • A landmark law that officially legalizes crypto assets by classifying them as "virtual assets" or "crypto assets."
  • Lays the foundational groundwork for future specific business rules and oversight mechanisms (e.g., cybersecurity, anti-money laundering).
  • Note: Detailed regulations and full effect are scheduled to commence on January 1, 2026.

4. Requirements for Compliance

  • Current (June 2025):
  • Strict Prohibition: Absolutely no use of cryptocurrencies as a means of payment for goods and services.
  • Other Activities (Trading, Ownership): No comprehensive legal framework or specific licensing requirements are yet in force. Compliance requirements for these activities are still being formulated.
  • Future (Post-January 2026, anticipated):
  • Expected to include stringent licensing conditions for cryptocurrency exchanges (e.g., high minimum charter capital).
  • Adherence to Anti-Money Laundering (AML) and Know-Your-Customer (KYC) protocols.
  • Compliance with forthcoming taxation rules.

5. Notable Restrictions & Limitations

  • Payment Prohibition: The most significant and strictly enforced restriction, carrying substantial penalties.
  • Regulatory Vacuum: Lack of clear legal definitions and comprehensive frameworks for crypto assets (beyond payment) creates uncertainty for investors and businesses.
  • Asset Classification Ambiguity: Historically, cryptocurrencies were not clearly defined under civil laws. While the DTI Law (effective Jan 2026) begins to categorize them, this ambiguity persists in the interim.
  • Taxation Uncertainty: No clear, comprehensive taxation rules for cryptocurrency transactions are currently in place.
  • Limited Legal Recourse: Due to the regulatory vacuum, investors may lack formal legal protection or recourse in disputes related to crypto trading or ownership.

6. Recent Developments & Future Outlook

  • Passage of DTI Law (June 2025): A pivotal step towards formalizing digital assets, with its full effect commencing January 2026.
  • Active Regulatory Development:
  • The Vietnamese government is actively engaged in drafting new laws and decrees.
  • Driven by high crypto adoption rates, the need to mitigate risks (fraud, money laundering, tax evasion), and to facilitate innovation.
  • Proposed Pilot Programs & Regulatory Sandbox:
  • The Ministry of Finance (MoF), in coordination with SBV and MoPS, is proposing a pilot program for crypto asset issuance and trading.
  • Discussions include stringent licensing conditions for exchanges (e.g., a minimum paid-in charter capital of VND 10 trillion, approx. USD 385 million).
  • A regulatory sandbox is being considered to evaluate AML/KYC compliance frameworks and the use of stablecoins.
  • Government Directives:
  • Prime Minister Pham Minh Chinh has issued directives (e.g., Directive No. 05/CT-TTg in March 2025) instructing ministries to propose comprehensive legal frameworks for managing and promoting digital assets.
  • Taxation Initiatives:
  • The MoF is actively working on a draft resolution to propose a pilot program for taxing digital assets.
  • International Alignment:
  • Efforts are underway to align Vietnam's legal framework with international standards, particularly concerning anti-money laundering and counter-terrorism financing (e.g., addressing FATF "gray list" concerns).
  • Inter-Ministerial Coordination:
  • Key agencies (MoF, SBV, MoPS, MoST) are collaborating to develop a multi-faceted regulatory approach.

Full Analysis Report

Report on Retail Trading Status of Cryptocurrencies in Vietnam

Date of Report: 2025-06-26

Topic: Retail_Trading_Status

Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

Retail_Trading_Status: Gray-Zone

Detailed Narrative Explanation:

Vietnam's stance on retail cryptocurrency trading is complex and evolving, currently best described as a Gray-Zone. While not explicitly banned for individuals to own, buy, or sell, cryptocurrencies lack a clear legal framework, are not recognized as legal tender or a means of payment, and operate in an environment of regulatory uncertainty. This ambiguity creates a situation where the activity is popular and widespread among the population, yet without specific legal protections or comprehensive, crypto-focused regulations.

Historical Context and Current Developments:

Historically, Vietnamese authorities have issued warnings about the risks associated with cryptocurrencies and have explicitly prohibited their use as a means of payment. The State Bank of Vietnam (SBV) has consistently stated that cryptocurrencies are not legal tender and has cautioned financial institutions against engaging in crypto-related transactions.

Despite this, Vietnam has one of the highest cryptocurrency adoption rates globally. Recognizing this trend and the potential of blockchain technology, the Vietnamese government has initiated steps towards developing a legal framework.

A significant recent development is the passage of the Law on Digital Technology Industry by the National Assembly on June 14, 2025, which is set to take effect in 2026. This law, for the first time, legally recognizes digital assets, including virtual assets and cryptoassets, while excluding securities, central bank digital currencies, and other financial instruments. The law defines "virtual assets in electronic environments" as a type of digital asset that may be used for exchange or investment purposes, and "cryptoassets" as digital assets utilizing encryption technology. This law also mandates cybersecurity and anti-money laundering (AML) safeguards in line with international standards.

However, even with this new law, the specifics of regulating retail trading, licensing exchanges, and taxation remain to be fully clarified and implemented. The law provides a foundational recognition but detailed regulations are still anticipated.

Prior to this law, and continuing until its full implementation and the issuance of subsequent detailed decrees and circulars, the legal status remained murky. The Ministry of Finance (MoF) has been tasked with developing a legal framework for virtual assets and virtual asset service providers, with a deadline of May 2025 mentioned in some directives. There have been discussions and proposals for piloting cryptocurrency exchanges under a controlled sandbox mechanism. However, the MoF has also expressed reservations about rushing into such pilots without a comprehensive legal framework, citing financial security concerns.

Regulatory Environment (Current and Emerging):

  • Legality of Owning, Buying, Selling: Currently, owning, buying, and selling cryptocurrencies by individuals is not explicitly illegal, though it is not officially protected or regulated. The new Law on Digital Technology Industry, effective 2026, will provide a legal basis for these activities.
  • Use as Payment: The use of cryptocurrencies as a means of payment for goods and services remains prohibited. Violations can lead to administrative fines and, in some cases, criminal liability.
  • KYC/AML Requirements: While a specific crypto-focused regulatory regime is still developing, general Anti-Money Laundering (AML) laws are in place. The Law on Anti-Money Laundering (2022), effective from March 2023, aims to establish a more stringent AML framework. The new Law on Digital Technology Industry also mandates AML safeguards for digital assets. There is an expectation that crypto exchanges operating in Vietnam, even if not formally licensed under a specific crypto regime yet, should implement Know Your Customer (KYC) and AML procedures. The government is under pressure to strengthen its AML/CFT framework, partly due to Vietnam's inclusion on the Financial Action Task Force (FATF) grey list. The national action plan includes developing a legal framework to either prohibit or regulate virtual assets and virtual asset service providers by May 2025.
  • General Warnings: Authorities, particularly the State Bank of Vietnam, have consistently issued warnings to the public about the risks associated with cryptocurrency trading, including volatility, fraud, and the lack of legal recourse in case of disputes or losses.
  • Taxation: The taxation of cryptocurrency earnings remains unclear due to the lack of legal recognition of cryptocurrencies as specific types of assets or income. Court rulings have previously sided against tax authorities attempting to tax crypto trading profits due to this ambiguity. However, with the upcoming legal framework, it is anticipated that tax regulations for digital assets will be developed.
  • Regulatory Bodies: Key government bodies involved in the ongoing development of cryptocurrency regulation include the Ministry of Finance (MoF), the State Bank of Vietnam (SBV), the Ministry of Justice, and the Ministry of Information and Communications.

Complexity and Ambiguity:

The "Gray-Zone" status arises from several factors:
* High Public Adoption vs. Lack of Specific Regulation: A significant portion of the Vietnamese population engages with cryptocurrencies, yet there are no specific, comprehensive laws governing these activities for individuals.
* Prohibition as Payment vs. Permissibility of Trading/Holding: While using crypto for payments is illegal, the act of trading or holding them as assets is not explicitly banned.
* Ongoing Legislative Development: The legal framework is actively being developed. The new Law on Digital Technology Industry is a major step, but detailed implementing regulations are still needed. Directives and pilot programs are being discussed and formulated, indicating a transition period.
* Differing Views Among Authorities: Historically, there have been slightly different perspectives among government bodies, with the SBV focusing on the risks and payment prohibitions, while the MoF has been more involved in considering them as potential assets for taxation and regulation. However, there is now a more concerted effort to establish a unified framework.

In conclusion, while Vietnam is moving towards a more defined regulatory environment for cryptocurrencies with the recent passage of the Law on Digital Technology Industry, the current situation for retail trading remains a gray area. Individuals participate widely, but specific regulations, investor protections, and clear guidelines for service providers are still in the process of being fully established and implemented.

Specific, Relevant Text Excerpts:

  1. Legal 500 (June 5, 2025): "Informal digital asset trading is fueling a vast underground economy, but Vietnam still lacks an official legal framework for cryptocurrency and digital assets. According to Directive No. 05/CT-TTg dated March 1, 2025, the Ministry of Finance and the State Bank are tasked with proposing a legal framework for managing and promoting digital assets and cryptocurrency by March 2025."
  2. Cointelegraph (September 3, 2024): "It is still legal to own and trade cryptocurrency on an exchange, but due to a lack of regulation, this is still a gray area. Vietnam will have developed a major legal framework for crypto regulation by 2025." And, "Currently, the State Bank of Vietnam prohibits issuing, distributing and using cryptocurrency as a payment method. That said, it's not illegal to own or trade cryptocurrency."
  3. Vietnam Investment Review (June 25, 2025) on the Law on Digital Technology Industry: "The National Assembly passed the Law on Digital Technology Industry on June 14, to take effect in 2026. The legislation marks a pivotal development in the country's digital economy framework, recognising digital assets, including virtual and crypto, while explicitly excluding securities, central bank digital currencies, and other financial instruments." And, "‘Virtual assets in electronic environments are a type of digital asset that may be used for exchange or investment purposes,’ the law states. ‘Cryptoassets are defined as digital assets that utilise encryption technology or equivalent digital technologies to authenticate the asset throughout its creation, issuance, storage, and transfer processes.’"
  4. ANT Lawyers (May 23, 2024): "Although it's illegal to use cryptocurrency as a payment method, owning, trading, or holding cryptocurrency is not considered a criminal offense. However, because cryptocurrency exchanges are unregulated, investors have limited legal protection."
  5. Vietnam Investment Review (May 6, 2025): "Thus, cryptoassets are presently in a legal grey zone in Vietnam – not banned, but also not legally recognised or protected as an asset, a type of money, commodities or securities in Vietnam."
  6. Vietnam Investment Review (June 25, 2025) on AML/CFT: "Under the new Law on Digital Technology Industry, to come into effect in 2026, digital assets are officially recognised... The law also mandates the adoption of cybersecurity safeguards and anti-money laundering frameworks in line with international best practices, in a move likely aimed at addressing concerns raised by the Financial Action Task Force (FATF)." (Note: This links to an article discussing the FATF grey list and AML measures in the context of the new law).
  7. State Bank of Vietnam (via VTN and Partners, September 30, 2023): "SBV has declared that “cryptocurrencies in general, and Bitcoin and/or Litecoin in particular, are not legal means of payment in accordance with the laws of Vietnam. The issuance, provision and use of cryptocurrencies in general, and Bitcoin and/or Litecoin in particular (illegal means of payment) as currencies or means of payment are prohibited”."
  8. Luther Law Firm (April 8, 2025): "Vietnam has one of the highest cryptocurrency ownership rates in the world as of 2025. Despite this, cryptocurrencies remain unregulated and legally ambiguous in Vietnam... The Prime Minister's Decision 194/QD-TTg directs the Ministry of Finance to develop a legal framework for virtual assets by May 2025. Until then, crypto taxation remains uncertain, with the only certainty being that crypto is still a legal gray area and investors should exercise caution while engaging in digital asset transactions."

Direct URL Links to Sources:

  1. Legal 500 (June 5, 2025): https://www.legal500.com/developments/thought-leadership/refining-the-legal-framework-for-cryptocurrency-and-digital-assets-to-achieve-legal-recognition-in-vietnam/ (Link from search result)
  2. Cointelegraph (September 3, 2024): https://cointelegraph.com/news/vietnam-cryptocurrency-laws-investor-risks-and-rewards (Link from search result)
  3. Vietnam Investment Review (June 25, 2025) - "Digital assets finally go legal for Vietnam": https://vir.com.vn/digital-assets-finally-go-legal-for-vietnam-112386.html (Link from search result)
  4. ANT Lawyers (May 23, 2024): https://antlawyers.vn/10-facts-about-regulations-on-cryptocurrency-exchange-in-vietnam/ (Link from search result)
  5. Vietnam Investment Review (May 6, 2025) - "Evaluating the feasibility of taxing cryptocurrency assets in Vietnam": https://vir.com.vn/evaluating-the-feasibility-of-taxing-cryptocurrency-assets-in-vietnam-111174.html (Link from search result)
  6. Vietnam Investment Review (June 25, 2025) - "Crypto transaction regulations more sophisticated than ever": https://vir.com.vn/crypto-transaction-regulations-more-sophisticated-than-ever-112387.html (Link from search result)
  7. VTN and Partners (September 30, 2023): https://vtn-law.com/cryptocurrency-and-its-legal-status-in-vietnam/ (Link from search result)
  8. Luther Law Firm (via Lexology, April 8, 2025): https://www.lexology.com/library/detail.aspx?g=07f6e071-9f6b-4df2-8e01-9c80880158a5 (Link from search result)
  9. ASL LAW Firm (April 2, 2025): https://aslgate.com/vietnam-is-it-illegal-to-purchase-or-trade-bitcoin/ (Link from search result)
  10. Vietnam Investment Review (March 19, 2025) - "Digital asset legal clarity now imminent": https://vir.com.vn/digital-asset-legal-clarity-now-imminent-110058.html (Link from search result)
  11. Vietnam Government Portal (via Baochinhphu.vn, March 5, 2025) - "Viet Nam to pilot digital assets and cryptos at financial centers": https://en.baochinhphu.vn/viet-nam-to-pilot-digital-assets-and-cryptos-at-financial-centers-11150030.htm (Link from search result)
  12. Tilleke & Gibbins (via Lexology, April 28, 2025) - "Vietnam's Emerging Regulatory Landscape for Blockchain and Cryptocurrency": https://www.lexology.com/library/detail.aspx?g=a0b2738a-e993-4a6a-8d38-2787707a750a (Link from search result)
  13. Terminal 3 (June 25, 2025) - "Vietnam Legalises Digital Assets Under New Digital Technology Law": https://www.terminal3.io/insights/vietnam-legalises-digital-assets-under-new-digital-technology-law (Link from search result)
  14. Binance Square (June 19, 2025) - "The Governor of the State Bank of Vietnam has made statement": https://www.binance.com/en/feed/post/20250619000000-the-governor-of-the-state-bank-of-vietnam-has-made-statement-kt-nguyn-98-1000000000000 (This is a tertiary source summarizing SBV's stance, link from search result)
  15. Sanction Scanner (October 3, 2023) - "Anti-Money Laundering (AML) in Vietnam": https://sanctionscanner.com/knowledge-base/anti-money-laundering-aml-in-vietnam-1017 (Link from search result)
  16. Viet An Law Firm (Date not specified, accessed June 2025) - "Legal framework for cryptocurrency in Vietnam": https://vietanlaw.com/legal-framework-for-cryptocurrency-in-vietnam/ (Link from search result)
  17. Vietnam Investment Review (February 21, 2025) - "MoF rejects digital asset trading proposal": https://vir.com.vn/mof-rejects-digital-asset-trading-proposal-109403.html (Link from search result)
  18. Fintech Singapore (February 24, 2025) - "Vietnam MOF Rejects Proposal to Pilot Crypto Transactions in July 2026": https://fintechnews.sg/90350/vietnam/vietnam-mof-rejects-proposal-to-pilot-crypto-transactions-in-july-2026/ (Link from search result)
  19. Vietnam News (March 27, 2025) - "Việt Nam advances crypto exchange pilot programme": https://vietnamnews.vn/economy/1652957/viet-nam-advances-crypto-exchange-pilot-programme.html (Link from search result)
  20. Vietnam Briefing (Date not specified, accessed June 2025, refers to 2022/2023 AML Law) - "Five reasons why Vietnam's crypto usage is so high": https://www.vietnam-briefing.com/news/five-reasons-why-vietnams-crypto-usage-is-so-high.html/ (Link from search result)
  21. Vietnam Investment Review (April 17, 2025) - "The building blocks of crypto policy": https://vir.com.vn/the-building-blocks-of-crypto-policy-110753.html (Link from search result)
  22. VietnamNet (via VNA, March 5, 2025) - "Vietnam plans pilot cryptocurrency exchange": https://vietnamnet.vn/en/vietnam-plans-pilot-cryptocurrency-exchange-225623.html (Link from search result)

Web Sources (23)

Sources discovered via web search grounding

Search queries used (8)
  • Vietnam cryptocurrency regulation retail trading
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  • Vietnam Ministry of Finance cryptocurrency retail
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