On December 31, 2025, the State Bank of Vietnam (SBV) issued Circular No. 72/2025/TT-NHNN (Circular 72), establishing a streamlined foreign exchange framework for Vietnam’s International Financial Center (IFC). Circular 72, which took effect on the same day, implements core provisions of Decree No. 329/2025/ND-CP and marks a fundamental shift from ex ante licensing to ex post supervision for IFC member enterprises and foreign investors. These changes are designed to accelerate capital flows, reduce compliance costs, and position Vietnam as a competitive regional financial hub by granting IFC members substantially greater autonomy in currency transactions, borrowing, lending, and investment activities. Key provisions for IFC members to note are discussed below. Use of Foreign Currency and Payments within the IFC Vietnam generally requires the use of Vietnamese dong for transactions within the country, with limited exceptions. This can be burdensome for foreign investors, who may be unfamiliar with all the foreign exchange rules they must comply with. Under the new regulation, IFC member enterprises and foreign investors gain the ability to transact, list prices, and settle obligations in foreign currency when dealing with other IFC members or offshore counterparties, avoiding currency risk and conversion friction. With respect to individuals and organizations located within Vietnam who are not IFC members, the use of foreign currency must continue to comply with general restrictions on foreign exchange usage within Vietnam. Dual-Track Account System for IFC Members The new regulation introduces a two-tier account structure that differentiates transactions by purpose and counterparty. IFC member enterprises must use a designated foreign currency capital account at an IFC member bank for four specified activities: Borrowing from offshore individuals and organizations Lending to offshore entities and domestic borrowers Outbound investing from the IFC Investing elsewhere in Vietnam from the IFC All other foreign exchange transactions—including operational receipts, vendor

On January 20, 2026, Vietnam’s Ministry of Finance (MOF) issued Decision No. 96/QD-BTC to formally launch pilot administrative procedures for licensing crypto asset trading market services in Vietnam. The decision took immediate effect and implements the government’s pilot crypto asset market program under Resolution No. 05/2025/NQ-CP. Notably, competent authorities have now begun accepting license applications, marking the first time Vietnam has operationalized a licensing pathway for crypto trading market operators. Administrative Procedures and Applications The decision stipulates procedures for (i) granting, (ii) adjusting, and (iii) revoking licenses to provide services for organizing crypto asset trading markets. It provides detailed, step-by-step guidance for each procedure, including dossier composition, internal review stages, coordination mechanisms, and statutory timelines. These procedures apply specifically to entities seeking to organize and operate crypto asset trading markets within Vietnam’s pilot regulatory framework. The MOF is the authority responsible for reviewing and deciding on the above procedures, with the State Securities Commission acting as the receiving, coordinating, and procedural focal point. For licensing applications, the MOF will coordinate with multiple authorities, including the State Bank of Vietnam and the Ministry of Public Security, particularly in relation to anti-money laundering, cybersecurity, system safety, and risk control requirements. Applications may be submitted in person, by post, or electronically via the National Public Service Portal or the administrative procedure information system, in line with applicable regulations. Statutory processing timelines vary depending on the specific procedure and stage involved. For applications to obtain a license to organize a crypto asset trading market, the process is conducted in multiple phases: The MOF will issue an initial written response within 20 working days from receipt of a complete and valid initial dossier, following which, upon submission of the full set of required documents, the MOF will complete substantive review and issue the license

Thailand’s Board of Investment (BOI) has imposed new restrictions on foreign-majority shareholding and land ownership for companies in certain promoted activities. The changes took effect on September 1, 2025, but were not published in the Government Gazette until December 30, 2025, under Notification of the Board of Investment No. Sor. 7/2568 on the Amendment to List of Activities Eligible for Investment Promotion under Notification of the Board of Investment No. 9/2565, dated July 22, 2025. Foreign Land Ownership Restrictions Generally, foreign land ownership is one of the privileges granted to BOI-promoted companies, allowing them to own land to engage in the promoted activities. However, with these new restrictions, the BOI will no longer grant land-ownership privileges to foreign-majority-owned companies that conduct business activities in the following categories: Rolling, drawing, casting, or forging of nonferrous metals (category 5.4.9) Manufacturing of ferrous metal products or ferrous metal parts (category 5.4.11.2) Manufacturing of nonferrous metal products and/or nonferrous metal parts for industrial use (category 5.4.11.4) Manufacturing of other metal products, including other metal parts for industrial use (category 5.4.11.5) Manufacture of chemical products for industry (category 6.2) Manufacture of plastic products for industrial goods and parts (category 6.4.1) These restrictions do not apply to existing BOI-promoted companies that have at least three projects granted promotion under the same juristic person during the past 15 years (2011–2025) with total investment of at least THB 5 billion, excluding the cost of land and working capital. Foreign Shareholding Restrictions For companies to be eligible for BOI promotion in three other categories of business activities, at least 51% of the company’s registered capital must be held by Thai individual shareholders, unless the BOI-promoted activity is located within a special border economic zone as designated by the BOI. These three categories are: Manufacture of bags made of

On January 7, 2026, the Central Bank of Myanmar (CBM) announced a further relaxation of foreign exchange regulations through Notification No. 2/2026, with an effective date of January 1, 2026. This notification reduces the mandatory conversion requirement for exporters’ earnings in foreign currency into Myanmar kyat (MMK). Under the new notification, exporters are required to convert only 15 percent of their foreign currency export earnings into MMK at official CBM reference exchange rates, down from the previous required minimum conversion level of 25 percent. The adjustment provides exporters with more flexibility to manage foreign currency, improving liquidity for international transactions and reducing cash flow pressure. However, companies must still comply with the foreign currency conversion procedures and timelines set out in the CBM’s Notification No. 12/2022.