You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

July 7, 2021

A New Dawn for Cryptocurrency in Vietnam?

Over the past decade, cryptocurrency has been a consistently hot topic in Vietnam. A recent surge in the price of Bitcoin (BTC) from approximately USD 4,000 to nearly USD 65,000 in just over a year has turned up the heat more than ever. According to a recent report by Statista, Vietnam is ranked second among 74 countries surveyed in terms of the percentage of respondents who said that they used or owned cryptocurrency in 2020.

The considerable interest of Vietnamese users has in turn grabbed great attention from the government, specifically regarding how it can effectively regulate and potentially utilize this type of currency. Recently, the government issued Decision No. 942/QD-TTg dated June 15, 2021, approving the strategy for development of e-government toward digital government for 2021-2025 with orientation toward 2030 (“Decision 942”). Decision 942 raised a stir among Vietnamese investors as it seemed to hint at the government’s growing openness toward cryptocurrency, which to date has been largely opposed.

Legality of Cryptocurrency in Vietnam

For a general picture of cryptocurrency’s legal status in Vietnam, it can be briefly summarized that (i) there is no legal definition of cryptocurrency; and (ii) cryptocurrency is not yet explicitly recognized as either an asset/property or a means of transaction.

Thus far, the government’s opposition to cryptocurrency has been relatively clear. Under Official Letter No. 5747/NHNN-PC dated July 21, 2017, the State Bank of Vietnam (SBV) explicitly stated that cryptocurrency in general and BTC and Litecoin in particular are not legal currencies or means of payment in Vietnam; thus, any issuance, supply, or use of them as currency or a means of payment is prohibited, and subject to administrative or even criminal sanctions.

Later, on April 11, 2018, the Prime Minister issued Directive No. 10/CT-TTg to agencies including the SBV, the Ministry of Finance, and the Ministry of Public Security on increasing the management of activities related to BTC and other cryptocurrencies, with the aim to control, prevent, and deal with transactions related to cryptocurrency. In response, two days later, the SBV issued Decision No. 02/CT-NHNN, which requires credit institutions, payment intermediary organizations, and SBV units to strengthen measures to control and deal with transactions related to cryptocurrency.

Although cryptocurrency is not legal in Vietnam, an interesting case arose in 2020, when the Criminal Police Department proposed prosecution of 16 defendants in the case of a robbery of cryptocurrency (including BTC and other cryptocurrencies) equivalent to VND 35 billion, under the charge of “theft of assets/property”. This charge raised a contentious debate over whether cryptocurrency should be recognized as an asset/property under Vietnamese law, because otherwise, it would be impossible to accuse someone of “theft of assets/property” in this situation.

Does Decision 942 Open a Door for Recognition of Cryptocurrency?

While Decision 942 does not specifically mention cryptocurrency, it interestingly assigns the SBV to research, develop, and pilot the use of “virtual currency” (“tiền ảo” in Vietnamese) based on blockchain technology, without elaborating any further. It remains unclear whether such blockchain-based “virtual currency” under Decision 942 refers to cryptocurrency or any other virtual currency.

According to Associate Professor Dinh Trong Thinh, Senior Lecturer at the Academy of Finance, with this new pilot program, the government plans to issue a virtual VND (that is, a currency that is still Vietnamese currency, but has been issued and circulated in the digital space), and this is not related to cryptocurrency like BTC. The value of this new virtual currency, if codified and put into practice, would depend on the government’s decision, rather than fluctuating in price based on the market, like other cryptocurrencies. (See related article in Vietnam Finance.)

It should be noted that in March 2021, Vietnam’s Ministry of Finance announced that they had established a research group on virtual assets and virtual currency, with the aim to achieve an appropriate policy and management mechanism for them.

Are these signs that the government is ready to formally allow cryptocurrency, and even embrace it? It will be interesting to see what further steps the government takes to respond to this emerging trend.

RELATED INSIGHTS​ 

August 10, 2026
Thailand’s Office of the Personal Data Protection Committee (PDPC) recently released draft guidance on records of processing activities (ROPA) for personal data controllers and processors under the Personal Data Protection Act B.E. 2562 (2019) (PDPA). The draft guidance, which was presented to the public on July 7, 2026, addresses both controller records of collection, use, and disclosure of personal data and processor records of processing activities carried out on behalf of controllers. If implemented, the guidance will significantly expand organizational expectations for ROPA preparation, maintenance, and use across all sectors. Key Takeaways The draft guidance contains several important implications for organizations subject to the PDPA: ROPA reframed as a core accountability tool. The guidance elevates ROPA from an administrative record to a central accountability mechanism, connecting controller duties with recordkeeping obligations. ROPA as a source for privacy notices and governance documents. ROPA should serve as the primary source for privacy notices and align with consent management, retention schedules, DPIAs, incident response plans, and vendor contracts. Expanded scope across all activities. ROPA must cover all processing activities across the organization—including security, finance, HR, and external contractors—with correct controller or processor classification for each. Ongoing maintenance and auditability. ROPA must be updated for any change to systems, purposes, or processors, reviewed at least annually, and maintained with version control and a designated owner. Enhanced vendor, processor, and cross-border transfer requirements. Organizations must document all processors, external recipients, and cross-border transfers, specifying purposes, access scope, and destination countries. Linkage with risk assessment, DPIAs, and LIAs. ROPA should assign risk levels to each activity and identify when data protection impact assessments (DPIAs) or legitimate interests assessments (LIAs) are required, functioning as a risk-management tool. ROPA and data breach readiness. Incomplete ROPA can delay breach response and notification. Organizations should map data flows, vendors,
August 4, 2026
Thailand’s Personal Data Protection Act B.E. 2562 (2019) (PDPA) could soon see some important changes, as a draft bill to amend the PDPA has been introduced in the House of Representatives. The draft amendment is currently in the public consultation phase, with comments accepted from July 16 to August 15, 2026. If enacted in its current form, the amendment would make three key changes: expanding the government exemption to cover anticorruption operations, introducing a statutory definition of “government agency,” and restructuring the lawful bases for personal data processing to align with international standards. Background The PDPA has encountered several enforcement challenges since its implementation, including three core problems identified by the bill’s sponsors: (1) the current exemptions for government agencies do not cover anticorruption and misconduct-prevention operations; (2) the PDPA lacks a clear statutory definition of “government agency,” causing legal uncertainty as to which entities are covered; and (3) the existing framework for lawful bases of data processing does not align with international standards—particularly the multiple-lawful-bases system in the EU’s General Data Protection Regulation (GDPR)—making compliance inflexible for both government and private sector entities. Expanded Government Exemption The current PDPA exempts government agencies performing duties related to national security (including fiscal security), public safety, anti-money laundering, forensic science, and cybersecurity. The proposed amendment adds “prevention and suppression of corruption and misconduct” to this list of exempted functions. This would allow anticorruption bodies—most notably the National Anti-Corruption Commission (NACC), which is identified as a directly affected party—to collect, use, and disclose personal data without being subject to PDPA requirements when carrying out their duties. New Statutory Definition of “Government Agency” Notably, while the current PDPA use the term “government agency” in several provisions, the term is not comprehensively defined, creating potential uncertainty as to its scope. The draft bill therefore
August 3, 2026
On July 23, 2026, the Bank of Thailand (BOT) released for public comment its draft Notification on Digital Channel Security, which would significantly expand the scope and stringency of Thailand’s existing mobile banking security framework. If finalized in its current form, the draft notification would extend mandatory security requirements to credit card providers and credit providers, cover internet banking in addition to mobile applications, phase out SMS one-time passwords (OTPs) for transaction authentication, and introduce biometric verification requirements for high-value transactions. The public comment period is open through August 24, 2026. Background The BOT’s existing Mobile Banking Security Notification, issued in 2024, sets minimum security standards for financial institutions, specialized financial institutions (SFIs), and e-money providers, significantly reducing “money-draining app” fraud. However, fraudsters have since shifted to nonbank providers and internet banking channels, prompting the BOT to propose broader security requirements. Expanded Scope of Regulated Entities and Channels The existing Mobile Banking Security Notification covers only financial institutions, SFIs, and e-money providers offering mobile banking services. The draft expands coverage in two key areas: entities and channels. On the entity side, it adds credit card providers and credit providers that offer fund transfers to third parties at other financial service providers or that provide cash withdrawal services to individual retail customers. On the channel side, it broadens coverage to include internet banking in addition to mobile banking. Strengthened Customer Authentication The draft introduces enhanced authentication requirements in three areas: Service enrollment and device changes. Providers must implement rigorous identity verification, notify customers of enrollment results through out-of-band communication channels, and adopt risk-mitigation measures such as cooling-off periods and temporary transaction limits. Transaction-level authentication. Providers must use two-factor authentication for fund transfers, cardless ATM withdrawals, and transaction limit increases. Secure authentication factors. Key requirements include the following: “What-you-know” factors must
July 28, 2026
Data protection officers (DPOs) have become a fixture of Thailand’s privacy compliance landscape since the Personal Data Protection Act B.E. 2562 (2019) (PDPA) took full effect and the Office of the Personal Data Protection Committee (PDPC) began requiring certain organizations to appoint them. On July 7, 2026, the Office of the PDPC presented draft guidance on DPOs as part of a public consultation on a series of draft personal data protection manuals and recommendations. The draft offers the clearest indication yet of how the regulator expects the DPO role to work in practice, addressing recurring implementation issues under the PDPA—including when an organization must appoint a DPO, how the DPO should operate independently, how to manage conflicts of interest, and how data subjects and regulators should be able to contact the DPO. Because it remains in draft, organizations have an opportunity to weigh the practical implications now before the guidance is finalized. When a DPO Must Be Appointed The draft guidance clarifies the triggers for mandatory DPO appointment, including: Regular and systematic monitoring of personal data or systems on a large scale, such as tracking, analyzing, or predicting behavior, attitudes, or individual characteristics. Core activities involving large-scale processing of sensitive personal data, such as health data, biometric data, or criminal records. Certain foreign-organization representative arrangements. Public-sector coverage under relevant notifications identifying government entities that must appoint a DPO. Processing involving 100,000 or more data subjects may be considered large-scale. The guidance also contemplates voluntary DPO appointment for organizations that wish to raise their privacy governance standards, and such organizations should still comply with the standards applicable to DPOs under the law. Independence and Reporting Lines The draft guidance identifies lack of DPO independence as a core risk because an ineffective or constrained DPO may be unable to raise deficiencies