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January 22, 2025

Vietnam’s Draft Resolution on Financial Centers: Implications for Fintech and Banking

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Tasked with implementing the Politburo’s policy outlined in Notice No. 47-TB/TW dated November 15, 2024, the prime minister of Vietnam issued Decision No. 1718/QD-TTg on December 31, 2024, appointing himself as the head of a steering committee dedicated to the establishment of an international financial center in Ho Chi Minh City and a regional financial center in Da Nang by 2025. The Ministry of Planning and Investment has subsequently drafted an outline for the National Assembly’s Resolution on the Establishment of Regional and International Financial Centers in Vietnam (“Draft Resolution”).

This Draft Resolution introduces two key policy groups: (i) policies governing the quantity, location, structure, organization, functions, and responsibilities of the financial centers; and (ii) policies applicable to various areas and matters within the financial centers.

Notably, under the Draft Resolution, fintech has been identified as a key sector, with a specific focus on the implementation of a “controlled sandbox” policy for business models involving virtual assets and cryptocurrencies. Under this framework, transactions related to virtual assets and cryptocurrencies will be permitted from July 1, 2026, subject to licensing, management, impact assessment, and risk oversight by the financial centers’ Management and Operations Committee.

Scope of Application and Key Principles

The Draft Resolution applies to a wide range of stakeholders, including investors, regulatory agencies, organizations, and individuals involved in the establishment, organization, and operation of regional and international financial centers in Vietnam. These financial centers will have clearly defined geographical boundaries and specific locations, which will be further specified and detailed by the People’s Committees of Ho Chi Minh City and Da Nang.

Companies successfully registered as members of these financial centers will benefit from special investor-friendly policy principles, which may differ from the general legal and regulatory framework applicable in other parts of Vietnam.

Most notably, the state will implement mechanisms and policies to encourage capital inflows, facilitate the adoption of advanced technology and modern management practices, and promote infrastructure development within the financial centers. The management agencies of the financial centers will apply specialized administrative procedures to meet investors’ needs in accordance with international standards and best practices. Additionally, where provisions of the Draft Resolution differ from existing laws, resolutions, or ordinances, the provisions of the Draft Resolution will prevail.

Policy Framework for Establishment and Governance of Financial Centers

The Draft Resolution outlines the framework for the establishment and governance of financial centers in Vietnam, which will include a comprehensive international financial center in Ho Chi Minh City and a regional-scale financial center in Da Nang. To ensure effective management and operations, the financial centers will be overseen by dedicated agencies, including a (i) management and operations committee, (ii) financial supervision committee, and (iii) international arbitration center.

The management and operations committee will be responsible for the overall administration and strategic oversight of the financial center. Its organizational structure will consist of a board of directors and several key departments, including strategic management, financial management, operations supervision, and management coordination.

The financial supervision committee will focus on ensuring compliance with international financial standards and regulations, fostering a transparent and integrity-driven environment. This committee will also comprise a board of directors supported by specialized departments, such as audit, legal, welfare, risk management, and governance and human resources.

Additionally, each financial center will host an international arbitration center, which will facilitate the resolution of disputes arising from investment and business activities within the financial ecosystem.

Specific Policies for Financial Centers

The Draft Resolution also sets forth specific policies that will govern key areas within the financial centers. These policies cover the membership registration system; currency, banking, and foreign exchange management; fintech; capital markets; personal and corporate income tax; immigration and residency; human resource training and development; labor, employment, and social security; strategic investments; land use and infrastructure development; and trade and business regulations. Furthermore, policies related to dispute resolution mechanisms for investment and business activities are also included.

A significant feature of the Draft Resolution is the introduction of a controlled sandbox policy for fintech enterprises, particularly those engaged in virtual assets and cryptocurrency-related business models. Under this framework, transactions involving virtual assets and cryptocurrencies will be clearly permitted within the financial centers starting from July 1, 2026. These transactions will be subject to licensing, regulatory oversight, impact assessment, and risk management measures administered by the Management and Operations Committee. Additionally, issues concerning anti-money laundering measures related to crypto assets and cryptocurrencies; the issuance, ownership, and trading of non-fungible tokens (NFTs) and utility tokens; and regulatory measures for crypto-asset mining activities (to limit risks to energy security and the environment) will be further regulated by the government.

In the domain of currency, banking, and foreign exchange management, the Draft Resolution proposes policies that reflect international best practices and address the practical needs of the financial centers. These policies include (i) anti-money laundering regulations, including those related to crypto assets; (ii) allowing financial transactions within the centers in both VND and freely convertible foreign currencies; and (iii) procedures and processes for priority areas in the financial centers for some traditional products in commercial banking activities.

The Draft Resolution also provides a streamlined regulatory framework for establishing and managing the operations of foreign credit institutions within the financial centers. Notably, banks and credit institutions headquartered in the centers will not be subject to foreign ownership restrictions or investment conditions when providing financial services within the centers or across borders. In addition, to align with international financial standards, the implementation of Basel III regulations is scheduled to commence on January 1, 2026. Furthermore, a digital banking model will be introduced, enabling commercial banks to offer advanced digital services within the financial centers from the same date.

Outlook

By establishing a structured regulatory framework, the forthcoming resolution aims to attract investment, drive financial innovation, and position Vietnam as a competitive player in the global financial landscape. A key highlight of the resolution is its focus on the fintech sector, particularly through initiatives such as the controlled sandbox for virtual assets and cryptocurrencies. This demonstrates Vietnam’s commitment to advancing digital transformation in financial services, fostering opportunities for fintech enterprises, and driving innovation across the industry.

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