Author: Xiao Sa lawyer

Since March, the crypto asset industry has the least shortage of big news, but only a few people have noticed that our neighbor Vietnam is carrying out a cryptocurrency reform that is not very loud but may have far-reaching impact - from a "one-size-fits-all" ban to a gradual relaxation and compliance supervision.

In early March this year, according to the requirements of Vietnamese Prime Minister Fan Mingzheng, all ministries and commissions must propose a legal regulatory framework for cryptocurrency within March. Vietnam's Deputy Finance Minister Nguyen Dezhi said the Ministry of Finance will report to the legal framework on digital currencies within March, including allowing the pilot operation of digital currency trading platforms. At the same time, the Ministry of Finance and Vietnamese Bank are also stepping up their research on the legal framework on the management of digital assets and digital currencies.

This reform may become a "test server" for future legislation in our country.

Today, the Sajie team will start from the historical evolution of Vietnam's crypto assets and combine it with Vietnam's financial regulatory system to talk to you. Is it possible that it will develop into a "Poxian" for people in the currency circle in the future, or even a choice for overseas travel?

01 From ban to liberalization, how do Vietnamese crypto assets manage? As a typical development in Middle and Southeast Asia, Vietnam has a population structure dominated by young people and a abundant labor force. About 35% of the population is less than 20 years old and has a large number of newborns. It has long been regarded as a cost "value depression" by various overseas companies. At the same time, Vietnam has also benefited from the dividends of industrial transfer. In recent years, it has generally maintained rapid economic growth and has relatively stable political situations, making it one of the preferred investments of Chinese enterprises in overseas enterprises.

As we all know, the younger the population structure, the larger the holding rate and transaction volume of cryptocurrencies will be. Coupled with Vietnam's strict foreign exchange control system and the continuous depreciation of Vietnam's dong, the penetration rate of crypto assets in recent years has actually been far higher than we imagined. However, due to the lack of scientific and technological innovation capabilities in the country and the backward development of Internet technology, it is often a "little transparent" role in the currency circle and has little say. But it is unquestionable that Vietnam is becoming an increasingly large and vibrant market in a crypto world.

(I) Vietnam's strict supervision of crypto assets

For a long time, Vietnam has adopted a strict regulatory system that is more similar to my country for crypto assets. It does not recognize that crypto assets can be circulated in the market as a general equivalent, nor its property attributes, but in judicial practice it can be recognized as a criminal object in the sense of criminal law.

Vietnam's legislation belongs to the civil and commercial division type. That is to say, Vietnam is different from my country. It has both the Civil Code and the Commercial Code, but neither has clear provisions on special assets such as crypto assets.

First of all, according to the existing Vietnamese legal provisions, crypto assets do not belong to the "valued rights of things, money, documents and property" stipulated in Article 105 of the Civil Code, and are not property in the legal sense. Secondly, crypto assets do not belong to the "service" stipulated in Article 9 of Vietnam's Commercial Law.

In terms of actual regulatory measures for crypto assets, Vietnam has always maintained a high-pressure state, and some of the time nodes and practices are quite similar to those of our country. Specifically, it is as follows:

It can be seen that after my country issued the "9.4 Announcement" in 2017, it clearly included ICO behavior as a criminal act, Vietnam also banned crypto assets at the same time node and stipulated a high fine. However, from practice, we can see that the implementation of relevant administrative orders in Vietnam may be poor. According to data published by Triple-A, Vietnam has more than 17 million crypto asset holders, ranking 7th in the world. Based on Vietnam's population, its crypto asset holding rate is about 17%, which is twice the global average.

(II) Vietnam has made it clear: embracing crypto assets

Maybe it is due to the recent bull market in crypto assets, or Vietnamese regulators have found that crypto assets business can also help its economic development, or it is due to compromise on the reality - it is better to be relieved than to block... Vietnamese Prime Minister Fan Mingzheng made a clear requirement that all ministries and commissions must propose a legal regulatory framework for cryptocurrency within March. The Vietnamese Ministry of Finance then released a rumor: it is necessary to build a sandbox space to allow pilot operation of digital currency trading platforms. This move is actually quite similar to the move by Hong Kong to issue the Web3 Declaration two years ago.

Although Vietnam's official has not given specific provisions on legal supervision of cryptocurrencies, we can judge based on its recent regulatory cooperation trends that Vietnam is likely to adopt a regulatory framework that is more similar to Singapore. On March 12, the Vietnam Securities Commission and the Monetary Authority of Singapore (MAS) reached an agreement on cooperation intention and signed a letter of intent for cooperation (LOI). The two sides agreed to carry out capacity-building cooperation in building and improving the Vietnamese digital asset regulatory framework.

Therefore, the Sajie team predicts that if Vietnam can successfully pass relevant legislation today, it will soon open the application for "boxing" of crypto asset trading platform. Partners can pay attention to relevant information.

02 For people in my country's currency circle, is Vietnam's "Po County" a replacement?

Give a conclusion first: The Sajie team believes that investing in crypto asset platforms in Vietnam at this stage is a coexistence of risks and opportunities.

In terms of opportunities. First, people in my country's currency circle investing in cryptocurrencies in Vietnam can effectively combine their technological advantages with the advantages of Vietnam's market. If relevant businesses can be carried out smoothly, the platform's transaction volume will be guaranteed. Secondly, my country's investment channels in Vietnam are relatively mature and smooth, in addition to professional agency, Most law firms can provide full-process companionship and implementation services. Again, Vietnam has given a large number of tax incentives, customs incentives, etc. to overseas investors to encourage overseas investment.

In addition, holding a compliant crypto asset exchange license can also participate in my country and other asset disposal businesses involved in the case that will be carried out in the future, which is also attractive to crypto asset exchanges.

Risk. Vietnam has always been a strict foreign exchange control , but at the same time, it is a financial regulatory "lowland" with flooding money laundering and mixed funds. Since the Global Anti-Money Laundering and Counter-Terrorism Financing Financial Action Task Force (FATF) added Vietnam to the "grey list" on June 23, 2023, the country has maintained stable performance and has not been "closed" to this day. It continues to be on the list in 2025.

This means that the financial activities of enterprises registered in Vietnam and Vietnamese users will be subject to very strict scrutiny, and most banks and financial institutions in the world need to perform enhanced customer due diligence on funds entering and leaving the Vietnamese crypto asset trading platform. In this way, Vietnamese crypto asset exchanges may cause various difficulties in providing users with cross-border crypto asset services, especially virtual currency and fiat currency exchange services, and the platform compliance costs may increase significantly.

03Written in the end

In general, if Vietnam wants to become a "Poxian" substitute, it still has a long way to go. In the short term, Vietnam's lack of infrastructure construction and the backward development of Internet technology are all unfavorable factors for the crypto industry. It is not easy to join the Vietnam regulatory sandbox to open a crypto asset exchange. As we all know, developing emerging businesses in Southeast Asia actually has a certain invisible threshold. If there is no better barrierIt's hard to get the first wave of bonuses.

The above is today's sharing, thank you readers!