On August 18, 2025, Thailand’s Securities and Exchange Commission (SEC), in collaboration with the Ministry of Finance, the Anti-Money Laundering Office, and the Ministry of Tourism and Sports, announced the launch of TouristDigiPay. The initiative, implemented under the SEC’s Regulatory Sandbox, allows foreign tourists to convert digital assets into Thai baht for use in everyday transactions in Thailand. Foreign tourists who opt to participate in TouristDigiPay must open two accounts once they are in Thailand: An account with a licensed digital asset operator to sell or exchange digital assets for Thai baht; and A tourist wallet account with a licensed e-money operator regulated by the Bank of Thailand. Funds from digital asset sales will be transferred into the tourist wallet, enabling tourists to make payments at participating merchants that accept e-money. Key Regulatory Requirements The TouristDigiPay project will operate for a period of up to 18 months, with the following conditions: Only licensed digital asset brokers, dealers, and exchanges integrated with licensed e-money operators are eligible to participate. Operators must implement anti-money laundering (AML) protocols that are proportionate to the assessed risk level. These include: Conducting know-your-customer and customer-due-diligence (KYC/CDD) checks on all users. For monthly transactions exceeding THB 50,000 per person, verifying the source of the digital assets and assessing AML risk using internationally recognized blockchain forensic tools or equivalent procedures. Suspending or rejecting services if digital assets are transferred from wallets flagged for AML concerns. Ensuring that conversion between digital assets and fiat includes safeguards such as matching account names and returning digital assets only to the original wallet. The following transaction limits apply to participants in the TouristDigiPay initiative: Payments to small vendors are capped at THB 50,000 per month. Payments to vendors who have completed the know-your-merchant (KYM) process are capped at THB 500,000 per

Thai authorities have escalated efforts to block unlawful cross-border digital asset business operators. On June 19, 2025, the Ministry of Digital Economy and Society (MDES) issued a notification empowering it to ban internet access to operations or services offered by digital asset business operators who lack licenses from the Thailand Securities and Exchange Commission (SEC) under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018). This ban, issued under the 2023 Royal Decree on Measures for the Prevention and Suppression of Technology Crime, particularly aims to block Thai users’ access to services offered by unlicensed offshore digital asset providers via their own apps or websites or through public social media platforms. Compliance Requirements The notification requires internet service providers and social media platforms selected by MDES to immediately impose internet access restrictions on identified apps, websites, and IP addresses of illegal operators upon receiving MDES orders. Takedown Orders There are two tracks for competent officials at MDES to issue orders to operators: If the competent official is notified by the SEC of licensing noncompliance by a particular digital asset business operator, the competent official can issue a takedown order to the operator upon approval from the permanent secretary of MDES. If the competent official independently discovers, or receives a complaint from any third party other than the SEC, that a digital asset business operator may have violated licensing requirements, the competent official can ask the SEC to verify and confirm the relevant facts and noncompliance before seeking approval from the permanent secretary of MDES to issue the takedown order. Streamlined Enforcement Prior to this notification, the SEC could obtain takedown orders only from Thai courts under the 2007 Computer Crime Act to take down or block access to unlicensed digital asset platforms and apps. This was a relatively

Vietnam’s recent embrace of “regulatory sandboxes” reflects a deliberate policy choice to balance the need for robust oversight with an equally pressing imperative to catalyze innovation. A sandbox is a controlled, time-bound framework in which businesses may pilot emerging technologies, products, or business models under relaxed or tailor-made regulatory requirements, thereby allowing regulators to observe risks in real time while innovators validate commercial viability without bearing the full weight of the traditional compliance regime. By issuing sandbox regulations, the government of Vietnam is signaling its commitment to accelerating digital transformation, attracting investment, and developing a knowledge-based economy, all while safeguarding financial stability, consumer protection, and national security. This strategy is embodied in a suite of instruments that together establish sector-specific sandboxes: Decree No. 94/2025/ND-CP on the Regulatory Sandbox in the Banking Sector (Fintech Sandbox Decree), effective July 1, 2025. Law on Digital Technology Industry (DTI Law), effective January 1, 2026, and Law on Science, Technology and Innovation (STI Law), effective October 1, 2025. Resolution No. 222/2025/QH15 on International Financial Centers (IFC Resolution), effective September 1, 2025. In addition, a draft resolution on the pilot implementation of the crypto-asset market (Draft Crypto Pilot Resolution) is expected to introduce a dedicated sandbox for crypto-asset service providers later this year, further underscoring Vietnam’s holistic, forward-looking approach to regulating emerging technologies. Below is a brief summary of all the regulatory sandboxes, who they are open for, and what businesses are attracted. Fintech Sandbox Decree Under the Fintech Sandbox Decree, besides credit institutions and foreign bank branches, fintech companies operating in Vietnam can apply for a Certificate of Sandbox Participation issued by the State Bank of Vietnam to operate any of the following services in Vietnam: Credit scoring: A solution applicable to information technology systems of credit institutions, branches of foreign banks, and fintech

On June 27, 2025, Vietnam’s National Assembly adopted a Resolution on International Financial Centers in Vietnam (“IFC Resolution”), which is set to take effect September 1, 2025, putting forward major policy breakthroughs on multiple fronts. The IFC Resolution has the goal of turning Ho Chi Minh City and Da Nang into leading international financial centers with autonomy and tools to compete, thereby raising Vietnam’s position in the global financial network, in association with economic growth drivers. Below are some of the key points of the IFC Resolution, which has notable changes from previous drafts (see our articles on Vietnam’s Draft Resolution on Financial Centers: Implications for Fintech and Banking and Vietnam’s Emerging Regulatory Landscape for Blockchain and Cryptocurrency), including: The removal of the Central Supervisory Agency. The addition of a definition of international financial centers, which are specific geographic areas in Ho Chi Minh City and Da Nang with members entitled to special policies. The addition of a list of entities eligible for membership, and entitlement to the special policies. Major Policy Breakthroughs The IFC Resolution introduces specific policies in the following areas: Liberalization of foreign exchange control for members, including policies such as open foreign exchange use between members and exemption from foreign exchange control procedures for 100% foreign-owned members. Specialized licensing for members to establish and operate single-member limited liability banks and foreign bank branches with the ability to apply accounting standards, debt classification, risk provisions, and prudential ratios according to the owner’s policies. Creation of a capital market for innovative startups, including a crowdfunding mechanism or private placement mechanism through a licensed platform, and development of a green finance market with green certification. Creation of a regulatory sandbox for fintech technologies, products, services, and business models not yet prescribed by law, offering exemption from compliance with