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 payments, currency conversion, and other investment—may be conducted through standard foreign currency payment accounts at any IFC member bank. The last category includes directly receiving investment from local and foreign investors, marking a substantial liberalization of foreign exchange rules.

When IFC member enterprises open foreign currency payment accounts at non-IFC commercial banks or foreign bank branches, they remain subject to the general restrictions set out under the current foreign exchange regulations, highlighting that this special treatment is only offered to IFC members.

Liberalized Borrowing and Lending with Limited Registration

For borrowing, IFC members may now borrow foreign currency from offshore lenders without the registration and amendment procedures with the SBV that are currently required outside the IFC. Instead, borrowers who are IFC members only need to fulfill declaration and reporting obligations with the SBV.

For lending abroad, the new regulations distinguish between IFC members wholly owned by foreign investors—who may lend offshore subject only to declaration and reporting requirements—and other IFC members, who must satisfy additional conditions on borrower eligibility, lending limits relative to equity, compliance with safety ratios, tax settlement, and approved due-diligence reports.

Streamlined Investment and Remittance Procedures

For inbound investment into the IFC, foreign investors must channel all IFC investment inflows, profit distributions, and lawful proceeds through a foreign currency capital account at an IFC member bank, eliminating the foreign currency-Vietnamese dong conversion requirement that previously applied to foreign investment into Vietnam.

When IFC members invest elsewhere in Vietnam outside of the IFC, they must transfer funds through the foreign currency capital account and follow procedures analogous to those for foreign investors, maintaining consistency with Vietnam’s foreign exchange policy.

For outbound investment from the IFC to foreign countries, it is similarly bifurcated as with lending abroad. Wholly foreign-owned IFC members conduct such investments without registration, whereas other IFC members must register and report amendments with the local IFC operating authority before transferring capital.

Practical Implications for Businesses

The new regime substantially shortens transaction timelines and lowers administrative overhead for IFC members. However, liberalization carries heightened self-compliance responsibilities. Enterprises must establish robust internal controls to ensure accurate declaration, timely reporting, and proper account segregation, particularly where capital and payment accounts coexist. During the initial implementation period, businesses should monitor guidance from the IFC operating authority and coordinate closely with IFC member banks to confirm procedural consistency and reporting formats, ensuring that the benefits of liberalization are realized without inadvertent regulatory exposure.