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November 7, 2025

Multilaw Global FinTech Guide 2025 – Vietnam

Tilleke & Gibbins has contributed the Vietnam chapter to the latest edition of the Global FinTech Guide published by Multilaw. The guide provides a comprehensive overview of the legal and regulatory framework governing financial technology across major jurisdictions around the world.

Compiled by experienced practitioners from Multilaw member firms, the Global FinTech Guide examines how technological innovation is transforming financial services and how regulators are adapting to developments such as digital payments, virtual assets, and online financial platforms. The publication offers comparative insights into regulatory regimes and presents detailed, jurisdiction-specific analysis for companies, investors, and entrepreneurs active in the FinTech sector.

The Vietnam chapter, prepared by lawyers in Tilleke & Gibbins’ technology, media, and telecommunications team, surveys the key legal and regulatory developments shaping the country’s FinTech ecosystem. It covers the following areas:

  • Payment services
  • Asset and portfolio management
  • Financial advisory and broking services (including robo-advisory and auto-trading)
  • Trading platforms, social trading platforms, and signal following
  • Crowdfunding, crowdinvesting, and crowdlending
  • Distributed ledger technology (DLT) and cryptocurrencies
  • Loan services, factoring, loan broking, and finetrading
  • Identification
  • Online banking services
  • Initial coin offerings (ICOs) and token sales
  • Insurtech
  • Regtech and compliance management
  • Know-your-customer (KYC) requirements

Tilleke & Gibbins also contributed the Thailand chapter to the Global FinTech Guide. The full guide is available on the Multilaw website.

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September 17, 2025
Thailand’s Ministry of Finance has introduced a five-year personal income tax exemption on capital gains from the disposal of cryptocurrency or digital tokens. The Ministerial Regulation No. 399, published in the Government Gazette on September 5, 2025, offers the personal income tax exemption for transfers occurring between January 1, 2025, and December 31, 2029. The ministerial regulation was enacted to promote Thailand as a global financial center and digital asset business hub while encouraging increased domestic investment in digital assets. Key Conditions The exemption, which covers capital gains from cryptocurrency and digital token disposals during the specified five-year period, applies only to individuals. Companies that trade in digital assets are not eligible for this tax exemption. With the tax holiday set to expire in 2029 (unless extended), individual traders should plan ahead for postexemption taxation to ensure full compliance with Thailand’s personal income tax requirements. Proper documentation of digital asset transactions during the exemption period will be essential for future tax compliance. For more details on this tax exemption, or on any aspect of Thailand’s tax law and regulations, please contact Saravut Krailadsiri at [email protected] or Papavarin Sarawongsuth at [email protected].
September 11, 2025
Thailand’s Securities and Exchange Commission (SEC) has amended its digital asset regulations to permit the offering, trading, and provision of services related to tokenized environmental commodities by licensed digital asset exchanges, brokers, and dealers. This regulatory development is aimed at facilitating Thailand’s green economy and net-zero goals while diversifying the products available in the regulated digital assets market. The environmental commodities currently being traded on certain market platforms and via over-the-counter channels include: Carbon credits: Tradable certificates representing a reduction of CO₂ emitted into the atmosphere. Renewable energy certificates (RECs): Tradable proof of electricity generated from renewable energy sources. Carbon allowances: Tradable permits to emit a capped amount of greenhouse gases. The tokenization of these instruments is essentially the process of converting them into digital tokens, making it possible to list them on blockchain exchanges for trading purposes. Background Tokenized carbon credits, RECs, and carbon allowances fall under the category of utility tokens for consumption purposes or tokens representing entitlement certificates—that is, group 1 utility tokens, which are not considered financial products. The offering, trading, and provision of secondary-market services of this type of token are exempted from licensing requirements for regulated digital asset businesses under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018). Under the previous regulatory framework, licensed digital asset business operators were not allowed to provide services involving such unregulated tokens, as it was deemed to be engaging in “other businesses,” which digital asset operators generally cannot engage in without prior SEC approval. Regulatory Amendment Under the amended digital asset regulations, licensed digital asset exchanges, brokers, and dealers may now apply for SEC approval to offer services related to these tokenized assets as “other businesses,” including listing them for trading on digital asset exchanges. Apart from requiring operators to comply with the general conditions
August 25, 2025
To implement the recently issued Resolution on International Financial Centers in Vietnam (“IFC Resolution”), which is set to take effect on September 1, 2025 (see our previous article), the government of Vietnam is making every effort to formulate and issue guiding decrees—up to eight in total—before the effective date of the resolution. These decrees will establish key principles, define the rights and obligations of stakeholders, and outline permissible business activities within the IFCs, and serve as a foundation for the legal framework of the IFCs. Below are highlights of two draft decrees that have been released for public consultation. Draft Decree on IFC Establishment Ho Chi Minh City: The IFC in Ho Chi Minh City will focus on capital markets integrated with asset management services, fund management, insurance, financial products and financial derivatives; banking systems and money market products; fintech and financial innovation through sandbox mechanisms; specialized exchanges and new trading platforms; commodity markets, commodity and commodity derivatives exchanges linked to domestic and international physical commodity markets; and regional supply chain services, logistics hubs, maritime transport, and seaport infrastructure. Da Nang: The IFC in Da Nang will mainly develop green finance and commercial finance for SMEs and innovative enterprises, non-resident organizations and individuals (i.e., offshore financial services); cross-border trade activities linked to free trade zones, high-tech zones, new economic zones, and industrial zones; pilot control mechanisms for emerging models, such as digital assets, cryptocurrencies, and digital payments and transfers; new exchanges and trading platforms; investment funds, remittance funds, and small and medium fund management companies; startups in financial solutions for consumer services, tourism, e-commerce, logistics, and services within free trade zones; and related support, advisory, development, and legal services. Incentives: The People’s Committees of Ho Chi Minh City and Da Nang will need to decide on their list of
August 21, 2025
On August 18, 2025, Thailand’s Securities and Exchange Commission (SEC), in collaboration with the Ministry of Finance, the Anti-Money Laundering Office, and the Ministry of Tourism and Sports, announced the launch of TouristDigiPay. The initiative, implemented under the SEC’s Regulatory Sandbox, allows foreign tourists to convert digital assets into Thai baht for use in everyday transactions in Thailand. Foreign tourists who opt to participate in TouristDigiPay must open two accounts once they are in Thailand: An account with a licensed digital asset operator to sell or exchange digital assets for Thai baht; and A tourist wallet account with a licensed e-money operator regulated by the Bank of Thailand. Funds from digital asset sales will be transferred into the tourist wallet, enabling tourists to make payments at participating merchants that accept e-money. Key Regulatory Requirements The TouristDigiPay project will operate for a period of up to 18 months, with the following conditions: Only licensed digital asset brokers, dealers, and exchanges integrated with licensed e-money operators are eligible to participate. Operators must implement anti-money laundering (AML) protocols that are proportionate to the assessed risk level. These include: Conducting know-your-customer and customer-due-diligence (KYC/CDD) checks on all users. For monthly transactions exceeding THB 50,000 per person, verifying the source of the digital assets and assessing AML risk using internationally recognized blockchain forensic tools or equivalent procedures. Suspending or rejecting services if digital assets are transferred from wallets flagged for AML concerns. Ensuring that conversion between digital assets and fiat includes safeguards such as matching account names and returning digital assets only to the original wallet. The following transaction limits apply to participants in the TouristDigiPay initiative: Payments to small vendors are capped at THB 50,000 per month. Payments to vendors who have completed the know-your-merchant (KYM) process are capped at THB 500,000 per