In recent years, Vietnam has positioned itself among the leading countries in the world in terms of digital asset ownership and trading volume. This rapid adoption reflects the country’s growing digital economy and the increasing engagement of individuals and businesses in blockchain-based financial activities. Central to this growth are Resolution No. 57-NQ/TW of the Politburo dated December 22, 2024, on breakthroughs in science, technology, innovation, and national digital transformation with a vision to 2045 (“Resolution 57”) and Resolution No. 03/NQ-CP of the Government dated January 9, 2025, promulgating the Action Plan to Implement Resolution 57 (“Resolution 03”), which outline a flexible and innovative policy framework that embraces pilot programs for emerging technologies to lay the groundwork for Vietnam’s legislative framework concerning cryptocurrency and blockchain technologies. Regulatory clarity in terms of digital assets and blockchain technologies is now more critical than ever for businesses and investors. In light of this, Vietnam is currently in the process of introducing three key legal instruments, with drafts of the Law on Digital Technology Industry (“Draft DTI Law”), Resolution of the National Assembly on the Establishment of Regional and International Financial Centers in Vietnam (“Draft Financial Center Resolution”), and Resolution of the Government on the Pilot Implementation of Crypto Asset Markets in Vietnam (“Draft Crypto Pilot Resolution”) nearing promulgation. Current Regulatory Direction and Schedule Vietnam’s regulatory framework for crypto assets and blockchain has been in a developmental stage since 2017, focusing on directions, plans, and schedules rather than established regulations. In February 2024, under Decision No. 194/QD-TTg of the Prime Minister, the Ministry of Finance (MOF) was assigned to draft a legal framework to either prohibit or regulate virtual assets and service providers by May 2025, signaling a clearer regulatory direction. In March 2025, Directive No. 05/CT-TTg of the Prime Minister directed the MOF

On April 13, 2025, the government of Vietnam issued Decree No. 89/2025/ND-CP to amend and supplement Decree No. 92/2016/ND-CP dated July 1, 2016, concerning conditional business lines within the civil aviation sector (“Decree 89”). This update was implemented through an expedited procedure with immediate effect and has drawn public attention as it broadens the types of aircraft eligible for import into Vietnam, thereby promising to inject greater diversity into the country’s aviation market. What has changed? Decree 89 expands the recognition of aircraft type certificates—documents ensuring that the design of the aircraft, aircraft engine, or propeller meet airworthiness standards—from two to seven foreign aviation authorities. While Vietnam previously only accepted type certificates from the U.S. Federal Aviation Administration (FAA) and the European Union Aviation Safety Agency (EASA), the country now further accepts type certificates issued by five additional foreign aviation authorities: National Civil Aviation Agency of Brazil (ANAC) Transport Canada Civil Aviation (TCCA) Federal Agency for Air Transport of the Russian Federation (Rosaviatsiya) U.K. Civil Aviation Authority (UK CAA) Civil Aviation Administration of China (CAAC) Additionally, on April 14, 2025, Vietnam’s Ministry of Construction issued Circular No. 03/2025/TT-BXD (“Circular 03”) with immediate effect, amending and supplementing several articles under Circular No. 01/2011/TT-BGTVT previously issued by the Ministry of Transport (which was merged into the Ministry of Construction on March 1, 2025) in 2011 on the promulgation of the Civil Aviation Safety Regulations for aircraft and aircraft operations. Echoing Decree 89, Circular 03 allows the Civil Aviation Authority of Vietnam (CAAV) to issue or recognize Certificates of Airworthiness to aircraft that hold type certificates issued by the aviation authorities of Brazil, Canada, Russia, the United Kingdom, or China, in addition to those issued by the FAA or EASA. Following the entry into force of Decree 89 and Circular 03, the

On April 12, 2025, Thailand published an amendment to the Emergency Decree on Measures for the Prevention and Suppression of Technological Crimes in the Government Gazette, with the regulation taking effect the following day. Drafts of the amendment had been shared in recent months, and the final amendment of the decree contains some additional key revisions, such as narrowing the business operators subject to the decree’s requirements, reducing operators’ obligations, and establishing collaboration between relevant stakeholders to tackle technology crime. These key revisions to the amendment are detailed below. Business operators subject to the decree: The business operators covered under the decree now include only payment service providers under the Payment System Act and digital asset operators under the Royal Decree on Digital Asset Businesses. Digital platform services under the Royal Decree on Digital Platform Service Businesses That Are Subject to Prior Notification are no longer within the scope of the decree. Definition of technology crime: The final version of the amendment removed the expanded definition of technology crime that had been included in a previous draft, leaving the decree’s existing definition unchanged. Telecommunications provider obligations: Mobile and telecommunications service providers now have an obligation to monitor and screen for content that may be related to technology crime and suspend SIM cards when instructed to do so by the National Broadcasting and Telecommunications Commission (NBTC). Transaction and account suspension: The amendment removes the decree’s complex transaction suspension procedures and leaves room for business-specific regulators (e.g., Bank of Thailand, Securities and Exchange Commission, NBTC) to impose various technology crime suspension requirements on business operators under their supervision. The newly established Center for Prevention and Suppression of Technology Crimes can also notify financial institutions and business operators of names or digital asset wallet addresses that may be related to technology crime,

On April 12, 2025, Thailand issued an amended digital asset regulation that covers offshore digital asset businesses providing services on a cross-border basis to Thai users. These businesses will now be subject to the licensing requirements of the Royal Decree on Digital Asset Business Operations B.E. 2561 (2018), which is supervised by Thailand’s Securities and Exchange Commission (SEC). A digital asset business will be deemed as providing services in Thailand—and therefore subject to requirements under the Royal Decree on Digital Asset Business Operations—if the business does any of the following: Displays content in Thai, either fully or partially; Is registered under a “.th,” or “.ไทย” domain, contains any name relating to Thailand, or uses a domain written in Thai characters; Allows or requires payments in Thai baht (THB) or receives payments through Thai bank accounts or e-wallets; Chooses Thai law to govern transactions or Thai courts to litigate any dispute; Pays online search engines to attract users in Thailand to its services; Has an office, establishment, or personnel in Thailand to support or assist users within the country; or Meets any other criteria specified by the SEC. To operate legally in Thailand, offshore operators meeting any of the above criteria will be required to incorporate a local company in Thailand in order to apply for a digital asset business license with the SEC.