Tilleke & Gibbins has contributed the Vietnam chapter to Fintech 2027, a global guide published by Lexology Panoramic that provides comparative insights into the legal and regulatory frameworks governing fintech businesses across multiple jurisdictions. The Vietnam chapter offers a comprehensive overview of the country’s rapidly evolving fintech landscape, examining both the regulatory environment and practical considerations for businesses operating in or entering the Vietnamese market. Topics covered include: Fintech landscape and initiatives: General innovation climate; government and regulatory support Financial regulation: Regulatory bodies; regulated activities; consumer lending; secondary market loan trading; collective investment schemes; alternative investment funds; peer-to-peer and marketplace lending; crowdfunding; invoice trading; payment services; open banking; robo-advice; insurance products; credit references Cross-border regulation: Passporting; requirement for a local presence Sales and marketing: Restrictions on the promotion and marketing of financial products and services Cryptoassets and tokens: Distributed ledger technology; cryptoassets; token issuance Artificial intelligence: Regulatory framework governing AI systems and AI-enabled financial services Change of control: Notification and consent requirements for regulated businesses Financial crime: Anti-bribery and anti-money laundering procedures; regulatory guidance Data protection and cybersecurity: Data protection obligations; cybersecurity requirements applicable to fintech businesses Outsourcing and cloud computing: Outsourcing of material functions; use of cloud computing in the financial services industry Intellectual property rights: IP protection for software; employee- and contractor-created IP; joint ownership; trade secrets; branding; remedies for infringement Competition: Competition law issues affecting fintech businesses Tax: Incentives for innovation and investment; developments affecting tax and compliance obligations Immigration: Immigration options for recruiting skilled foreign personnel; special measures available through Vietnam’s international financial centers The chapter also examines a number of significant recent developments shaping Vietnam’s fintech sector, including the introduction of the country’s first comprehensive regulatory framework for cryptoassets, the adoption of a dedicated law on artificial intelligence, implementation of the banking regulatory sandbox,

Vietnam’s new E-Commerce Law, which took effect on 1 July 2026 along with its implementing Decree No. 248/2026/ND-CP (Decree 248), marks a significant development in the country’s approach to online intellectual property (IP) enforcement, reflecting a clear shift from a reactive model of intermediary liability to one that expects platforms to play a more active role in preventing infringement. From notice-and-takedown to platform responsibility The most significant change introduced by the E-Commerce Law is the transformation of the legal role of e-commerce platforms. The existing safe harbor provisions under the IP Law and the copyright notice-and-takedown regime established by Decree 17/2023/ND-CP (Decree 17) largely required intermediaries to act only after receiving notice of infringement. Once infringing content had been removed, the platform’s legal obligation was generally considered fulfilled. The new legislation adopts a fundamentally different approach. Article 17 of the E-Commerce Law requires intermediary platforms to screen information relating to goods and services before publication in order to prevent listings involving counterfeit or IP-infringing goods, and goods of unknown origin. Rather than relying exclusively on complaints from rights holders, platforms are now expected to implement preventive measures before infringing listings become publicly available. Decree 248 further requires platforms to update keyword filters based on recommendations issued by competent authorities. These filtering mechanisms are intended to prevent prohibited listings from appearing on the platform and represent a further move away from a purely complaint-driven enforcement model. The legislation also introduces Vietnam’s first statutory stay-down obligation. Under the E-Commerce Law and Decree 248, major digital platforms must maintain automated systems capable of reviewing, warning against, and removing unlawful listings while also implementing measures to prevent repeat violations, defined under Decree 248 as conduct that has previously been identified and handled by the platform, but continues to recur. This obligation addresses one

A new decree on penalties for violations related to the crypto asset market creates compliance risks for offshore crypto asset exchanges in Vietnam that do not hold, and practically cannot obtain, a Vietnamese license, and for Vietnamese users who continue to transact on those platforms. Decree No. 284/2026/ND-CP (Decree 284), issued by the government of Vietnam on July 16, 2026, formally establishes an administrative penalty framework for violations related to crypto assets and the crypto asset market. The decree takes effect on September 1, 2026, and will remain in force for the duration of the five-year pilot program under Resolution No. 05/2025/NQ-CP, which is scheduled to end in September 2030. Direct Penalties on Vietnamese Users The most immediate commercial risk to offshore platforms is that their Vietnamese users now face direct personal liability for using their exchanges. Vietnamese users who trade crypto assets outside of a Ministry of Finance-licensed service provider face fines of up to VND 50 million (approximately USD 1,900). Vietnamese users trading in crypto assets that are offered or issued to foreign users face higher penalties of up to VND 100 million (approximately USD 3,800). It is expected that Vietnamese users will be more willing to migrate away from offshore platforms now that there is a risk of real enforcement against them. Penalties on Unlicensed Service Providers Violations of providing crypto asset services or advertising crypto-related services without a license face fines of up to VND 200 million (approximately USD 7,700). Operating a crypto asset trading market without proper authorization falls within the same highest penalty bands. Organizations that violate issuance, provision, or disclosure rules may face fines of up to VND 200 million. Although the maximum administrative fine per violation is capped at VND 200 million for organizations and VND 100 million for individuals, these

Aviation law experts from Tilleke & Gibbins’ Vietnam offices have prepared the Vietnam chapter of Aviation Finance & Leasing 2026 from Chambers and Partners. Covering nearly 40 jurisdictions worldwide, the guide addresses key legal considerations for aircraft lessors, lessees, and financiers. Alongside the Vietnam chapter, Tilleke & Gibbins also provided the Thailand chapter for this year’s edition. The Vietnam chapter delivers detailed insights into the legal environment affecting aircraft sale and purchase, aircraft and engine leasing, and aircraft debt finance. Some of the topics it examines include: sale and lease agreement terms taxation lease registration and enforcement lease assignment/novation insurance and reinsurance debt structuring securities liens The guide also covers other issues influencing the day-to-day activities of aviation industry participants in Vietnam. Chambers and Partners’ Global Practice Guides provide in-house counsel with authoritative analysis of practical legal matters impacting business, enabling readers to compare legislation and relevant procedures across leading jurisdictions. The Vietnam chapter of Aviation Finance & Leasing 2026 is available as a PDF through the button below. The full guide can be accessed for free on the Chambers and Partners website.