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October 7, 2026

Vietnam Recognizes Cross-Border Payment Activities for Offshore Credit Institutions

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On August 5, 2026, the State Bank of Vietnam (SBV) issued Circular No. 39/2026/TT-NHNN (Circular 39) amending and supplementing a number of articles of Circular No. 16/2014/TT-NHNN (Circular 16). Circular 39 took effect on September 19, 2026, establishing a framework for offshore credit institutions to conduct cross-border payments through accounts held in Vietnam.

Key Provisions

Prior to the issuance of Circular 39, Circular 16 allowed non-residents, including offshore credit institutions, to use bank accounts they had opened at Vietnam-based licensed banks only for their own permitted transactions (e.g., payment for current transactions or capital transactions), not for providing cross-border payment services to third parties in Vietnam.

Circular 39 provides a more flexible framework by expressly permitting offshore credit institutions to utilize both foreign currency and VND accounts they have opened at Vietnam-based licensed banks for cross-border payment activities, including:

  • Processing international payment and fund transfer transactions for their customers under written agreements between the offshore credit institutions and licensed banks in Vietnam; and
  • Conducting receipt and payment transactions through such accounts.

The offshore credit institution’s use of accounts in Vietnam and other related matters must be governed by a written agreement between the credit institution and the licensed bank. This agreement serves as the operational basis for cross-border payment services, while remaining subject to Vietnamese law.

Practical Implications

Circular 39 opens a significant new channel for correspondent banking activity in Vietnam. International banks, foreign payment service providers, and fintech companies operating in or seeking to enter the Vietnamese market should take note, as this new legal framework facilitates expanded cross-border payment capabilities.

From a market perspective, Circular 39 marks a shift to greater regulatory certainty. When the law was unclear, foreign fintech companies or credit institutions tended to rely on close engagement with Vietnam-based licensed banks and a higher risk appetite to develop their business models in Vietnam. With a more solid legal framework in place under Circular 39, these companies can structure similar cooperation arrangements with greater confidence, supported by more explicit regulatory guidance.

As Circular 39 is newly introduced, its practical implementation will likely depend on further guidance from the SBV and licensed banks’ internal policies. Continuous monitoring of regulatory developments and market practice relating to this framework is therefore recommended.

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