.svg)
The State Bank of Vietnam (SBV) has launched a wide-ranging consultation process aimed at amending three key regulations governing the country’s payments ecosystem.
In a move signalling a major overhaul of rules for cards, payment intermediary services and payment agent activities, the SBV is looking to revise the compliance requirements for these entities.
The central bank has been prompted to act by the growth of digital payments in the country.
Draft one
One set of proposed amendments targets the that governs bank card activities.
The draft introduces new definitions, including for so-called supplementary cardholders and card acceptance devices, and prescribes detailed customer due diligence (CDD) requirements for both individuals and legal entities.
Notably, the draft proposes exemptions from certain CDD obligations for government agencies and Fortune 500 companies.
It also introduces revised transaction limits for both individual and corporate cardholders, while outlining permissible use cases for payment cards, such as paying for goods and services and topping up e-wallets.
Other proposed changes include mandatory authentication measures for different transaction types, including ATM withdrawals and online payments.
Draft two
A second consultation proposes amendments to the circular regulating payment intermediary services, with a particular focus on e-wallet providers.
The SBV is also seeking to strengthen CDD obligations, including for foreign-registered entities and beneficial owners, while introducing clearer record-keeping and safeguarding obligations.
One of the most notable provisions is a proposed ban on cash top-ups for e-wallets.
Instead, e-wallet holders would be required to link their wallets to a bank account or debit card denominated in Vietnamese dong (VND).
The amendments also outline new processes for settling transactions, handling outdated or incomplete CDD information and managing timelines for licensing applications.
Draft three
The third draft targets rules for payment agents. Proposed changes include provisions allowing customers to submit payment requests and transaction confirmations electronically.
The SBV is also seeking to introduce exemptions allowing banks to act as payment agents without obtaining additional licences.
In addition, it wants the power to conduct examinations of licensed payment agents, which would mean increased supervisory oversight.
International alignment
Vietnam’s goal in revising its compliance requirements appears to be alignment with international norms, as well as the expectations of global bodies such as the Financial Action Task Force (FATF).
For example, the move to introduce stricter CDD requirements, including detailed provisions for verifying beneficial ownership, reflects efforts by the regulator to align with FATF recommendations.
These changes could address gaps identified in peer reviews and mutual evaluations, as well as reduce the country’s exposure to illicit financial flows.
Such moves may attract attention from international investors and fintech firms previously deterred by the reputational risks of operating in a country without a clear regulatory framework.
Strengthened protections
Other potential new rules, such as the ban on cash top-ups to e-wallets, revised transaction limits and mandatory authentication measures, also signal the central bank’s intention to boost consumer protection and mitigate systemic risks.
Again, this reflects an attempt to replicate frameworks in key jurisdictions such as Singapore and the EU.
These measures should improve transparency in payment flows, enhance traceability and security and strengthen safeguards for users’ funds in an increasingly digital environment.
The requirement for e-wallet holders to link their wallets to a VND-denominated bank account or debit card should help curb money laundering and other illicit activity, as all wallet users would be traceable through the existing KYC checks of licensed banks.
Great expectations
Ultimately, digital payment firms that have a presence in Vietnam need to prepare for a significant increase in the compliance burden as regulatory expectations rise.
Operational costs are also likely to rise significantly, as firms invest in upgraded technical infrastructure for know-your-customer (KYC) processes, transaction monitoring and enhanced regulatory reporting.
Closer coordination with banks and regulators will be essential. As in jurisdictions such as the EU, this is likely to mean a shift away from focusing solely on growth, with firms expected to place greater emphasis on sound risk management.
