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.

Thailand’s consumer protection authorities have strengthened oversight of residential leasing businesses following numerous complaints about unfair lease terms, including unjustified deposit forfeitures and excessive utility charges. The Contract Committee of Thailand’s Office of the Consumer Protection Board issued the Notification of the Contract Committee Re: The Stipulation of Residential Property Leasing as a Contract-Controlled Business B.E. 2568 (2025), published in the Government Gazette on June 6, 2025. The notification becomes effective on September 4, 2025, and repeals the prior notification issued in 2019. The notification prescribes two types of standard residential lease contracts: short-term residential lease contracts (for leases of not more than three years) and long-term residential lease contracts (for leases of more than three years up to 30 years or for the lessee’s lifetime). However, use of these standard contract forms is not compulsory, and parties may use any form as long as the terms do not contradict the notification’s requirements. Expanded Scope The notification expands the scope of enforcement to include any lessor with at least three residential units, while the 2019 notification applies only to businesses leasing five or more residential units. Hotels and dormitory operators are excluded, as they are regulated under other specific laws. Residential lease contracts entered into under the 2019 notification will remain valid and enforceable until the expiration of the contract. Any residential lease contract executed from September 4, 2025, onward must comply with the new notification. The notification also expressly extends its applicability to lease contracts made through online platforms. Electronically executed lease contracts must comply with the required and prohibited terms specified in the notification as well as applicable laws governing electronic transactions in Thailand. Mandatory Terms and Conditions Residential lease contracts must contain clearly legible Thai text no smaller than two millimeters in size and no more

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 12, 2025, Vietnam’s Ministry of Agriculture and Environment submitted a draft law amending several provisions of the Land Law 2024 (“Draft Amended Land Law” or “Draft”) for government consultation and public comment. The Draft primarily aims to address three controversial issues in Vietnam’s land regime concerning (i) land pricing, (ii) land clearance, and (iii) the allocation of land outside auctions, following policy set out by Resolution 18-NQ/TW and the newly adopted Resolution 69-NQ/TW on land governance modernization. Land pricing is potentially one of the most important areas among the proposed reforms. The Draft, however, has notably not addressed a major concern recently raised by the public: When a project has been allocated or leased land, but the relevant authority has not yet issued the land-price decision, a “supplemental charge” continues to accrue for the entire waiting period. Under current rules, this charge is calculated at 5.4% per year on the ultimately determined land-use fee or land rent, materially shifting project economics and pricing risks to developers or end-buyers. Core Reforms on Land Pricing The Draft Amended Land Law sets out a number of reforms on land pricing, including the following: Land price tables: The Draft maintains provincial land price tables but clarifies the scope of application: They are used to determine land-related financial obligations of land users and compensation when the state recovers land; the government will detail the adjustment coefficient regime, ratios for land-use fee calculation by land type/user/form, and deductible infrastructure costs. Provincial people’s committees will continue to issue land price tables every five years, effective from January 1 of the first year in the cycle, with authority to supplement within the cycle as necessary. In provinces with cadastral maps and digital land price databases, the tables may be established down to the land-parcel level,