On September 10, 2025, Vietnam’s National Credit Information Center (CIC) reported to the Vietnam Cybersecurity Emergency Response Team (VNCERT) a suspected significant cybersecurity incident involving unauthorized access to the CIC’s credit information database. A hacker group has claimed responsibility and allegedly posted over 160 million records for sale, including sensitive personal and financial data. Implications for Banks and Financial Institutions Companies that share customers’ or potential customers’ personal data with the CIC for credit scoring or other purposes—and continue to act as a data controller for such data—may be obligated under Vietnam’s Personal Data Protection Decree (PDPD) and related regulations to: Notify A05 (Department of Cybersecurity and High-Tech Crime Prevention) and the State Bank of Vietnam without delay. Inform affected individuals if their personal data is at risk. Recommended Actions Companies that could be impacted by this data breach should take the following actions: Conduct an internal review of CIC-related data in their systems, and identify whether and how the systems have been affected by this incident. Assess whether to notify regulators and customers/potential customers. Enhance cybersecurity controls, monitor for suspicious activity, and implement additional safeguards to prevent secondary breaches.

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

On August 19, 2025, the Trade Competition Commission of Thailand (TCCT) released its draft Guidelines on the Consideration of Unfair Trade Practices and Conduct Constituting Monopoly, Reducing Competition, or Restricting Competition in Multi-Sided Platform Businesses in the Category of Digital Platforms for the Sale of Goods or Services (E-commerce). A public comment period on the guidelines is open until September 18. The draft provides the first detailed framework for how the TCCT will interpret and enforce the substantive provisions under the Trade Competition Act against digital platforms, which have a unique network effect and require complex competition analysis. This development will profoundly impact the operations of e-commerce platforms, sellers, and associated service providers in Thailand. The guidelines primarily target e-commerce digital platform business operators, which are defined as follows: E-commerce digital platform: A medium facilitating the sale, purchase, or exchange of goods or services, including any operations to create transactions or interactions between business operators via an electronic transaction system, regardless of whether service fees are charged. E-commerce digital platform business operator: A service provider of a digital platform for the sale of goods or services who acts as an intermediary facilitating the sale of goods or services, including any operations to create transactions or interactions through an electronic transaction system by receiving orders for goods or services transacted via an electronic system, whether in the form of an e-marketplace, a social marketplace, or any other form that connects purchase orders for goods or services with business operators through an electronic system. Prohibited Conduct The guidelines classify potentially anticompetitive conduct and unfair trade practices into two categories: price-related and non-price-related conduct. 1. Price-related conduct The TCCT is targeting pricing strategies that can harm competition. Key prohibited behaviors include: Price below cost: Setting prices below the average total cost without

On August 6, 2025, Myanmar’s National Defence and Security Council (NDSC) issued Order No. 20/2025, announcing a change in the composition of the country’s Foreign Exchange Supervisory Committee (FESC). The prime minister has been appointed committee chair of the FESC, and five other individuals were appointed to the committee. The order took immediate effect. Originally established in April 2022, the FESC is responsible for approving foreign currency conversion, granting exemptions to foreign exchange restrictions, and permitting overseas transfers of foreign currency. The FESC supervises the flow of foreign currencies for domestic and foreign investment, manufacturing, exports and imports, and service businesses (including education- and health-related initiatives). The FESC is specifically responsible for considering and approving the use of foreign currency for the following: Importing machinery, vehicles, equipment, and raw materials essential for foreign investment and manufacturing projects; Importing fuel, medicine, cooking oil, fertilizer, insecticide, and construction materials not readily available on the domestic market; Covering Myanmar citizens’ needs abroad, such as medical treatment, education, or religious activities; Facilitating imports of general goods, loan repayments, interest payments to foreign lenders, service payments, and profit repatriation from investments; and Importing luxury products, including brand-name goods, jewelry, sports cars, and watches. The FESC is empowered to carry out further duties related to foreign exchange management as assigned by the NDSC Importers, exporters, investors, and business owners are encouraged to consult the most current FESC guidelines and approval lists before conducting transactions in Myanmar. For more details on these FESC composition developments, or on any aspect of financial regulations in Myanmar, please contact Tilleke & Gibbins at [email protected].