Vietnam Emerging Crypto Regulatory Landscape: A Comprehensive Overview for Investors
Introduction
Vietnam is undergoing a transformative shift in its cryptocurrency regulatory landscape, moving from a legal grey zone to a structured framework. In June 2025, Vietnam’s National Assembly passed the landmark Law on Digital Technology Industry, the country’s first comprehensive law governing the digital asset sector. This new law – which takes effect January 1, 2026 – formally recognizes digital assets as legal property under Vietnamese law, granting them status similar to other assets like stocks or real estate. The reform comes amid Vietnam’s unusually high crypto adoption: over 21 million Vietnamese (about 21% of the population) have owned or traded crypto as of 2023, one of the highest rates globally. For a U.S.-based investment audience – from retail and institutional investors to venture capital and fintech firms – Vietnam’s new legal clarity opens a dynamic frontier. This report provides a comprehensive overview of Vietnam’s current crypto regulatory landscape, detailing the legal framework, exchange licensing, investor protections, and emerging opportunities in Vietnam’s digital asset ecosystem.
Vietnam’s New Legal Framework for Digital Assets
The Law on Digital Technology Industry (DTI) marks a turning point for Vietnam’s policy on digital assets. Passed with overwhelming support (441/445 deputies), the law makes Vietnam the first country to enact a dedicated law on the digital technology industry. Crucially, the DTI law defines and categorizes digital assets for the first time. It distinguishes between “crypto assets,” which rely on blockchain technology, and “virtual assets,” which may not use distributed ledgers but still carry digital value. Both categories are now recognized as legal property under Vietnam’s Civil Code, meaning individuals and institutions can legally own, transfer, inherit, or gift these assets with full civil law protection. In effect, cryptocurrencies and other tokenized assets have been elevated from an unrecognized grey area to a legitimate asset class in Vietnam.
Under the new law, digital assets enjoy the same legal status as other forms of property, which has far-reaching implications. Market participants will, for the first time, operate under a state-sanctioned framework with defined rules for ownership rights, contractual enforcement, and dispute resolution. The government is tasked with issuing detailed regulations to govern digital asset activities – covering technical standards, cybersecurity, consumer protection, and transparency – to ensure that innovation is balanced with risk management. Notably, while Vietnam now recognizes crypto assets as property, these assets are not recognized as legal tender or a means of payment in the country. The State Bank of Vietnam continues to prohibit the use of cryptocurrencies for payment purposes in line with financial stability concerns. This means Bitcoin or stablecoins cannot be used to settle everyday transactions in Vietnam, but they can be held and traded as investments or digital property within the legal framework.
The DTI law also introduces a regulatory sandbox approach for fintech and digital assets. It authorizes the government to allow approved companies to pilot new digital asset products and services in a controlled environment. Participants in such sandboxes may receive temporary exemptions from certain requirements, enabling experimentation with blockchain, decentralized finance (DeFi) and other innovations under regulators’ supervision. This sandbox mechanism, alongside plans for “digital technology zones” with favorable policies, underlines Vietnam’s intent to become a regional digital innovation hub. In fact, the law mandates establishing Vietnamese digital tech offices in major global markets to promote international cooperation and investment in Vietnam’s tech sector. Overall, the new legal framework provides much-needed certainty and legitimacy for Vietnam’s booming digital asset market, setting the stage for regulated growth after years of legal ambiguity.
Exchange, Custodian, and Service Provider Regulations
A cornerstone of Vietnam’s crypto regulations is the development of licensing regimes for exchanges, custodians, and other service providers in the digital asset space. Until now, Vietnam had no legal route for crypto businesses to obtain licenses, leaving exchanges and brokers to operate unofficially or offshore. This gap contributed to Vietnam’s inclusion on the Financial Action Task Force (FATF) grey list for deficiencies in anti-money laundering controls. Recognizing this, Vietnamese authorities are moving swiftly to institute a comprehensive licensing framework to supervise crypto-related activities. The new DTI law explicitly requires that entities providing digital-asset services meet government-defined business conditions.
Vietnam’s Pilot Program for Licensed Crypto Exchanges
At the forefront of Vietnam’s pragmatic approach is a pilot program for licensed cryptocurrency exchanges, which serves as a testing ground for the new regulatory framework. The Ministry of Finance has prepared a draft resolution to pilot the operation of digital asset exchanges in Vietnam, with final approval expected in 2025. During this pilot phase, a limited number of exchanges will be authorized to operate under close regulatory supervision. Officials have indicated there will be “more than one exchange” to encourage healthy competition, but the number of licensed exchanges will be kept small initially to allow effective oversight and evaluation of the pilot’s success. This controlled rollout is designed to both foster innovation and safeguard investors, reflecting Vietnam’s cautious stance. As Deputy Finance Minister Nguyễn Đức Chi noted, the pilot’s criteria cover market participants, technical capacity, procedures, financial strength, and expertise of service providers, ensuring only well-prepared firms participate.
The pilot exchanges will operate within the ambit of Vietnam’s planned International Financial Centre (IFC), a new initiative to position the country as a regional financial hub. In late June 2025, the National Assembly passed a resolution to establish an IFC in two locations: Ho Chi Minh City and Da Nang. Notably, specialized digital asset exchanges are a core component of the IFC, and the pilot exchanges are slated to launch within these zones by the end of 2025. The IFC framework provides attractive incentives for participants, such as liberalized foreign exchange, tax breaks on corporate and personal income, streamlined immigration, and possibly a bespoke dispute resolution system (including a special court and arbitration center) for financial and digital asset cases. These “sandbox” conditions in the IFC will allow the pilot crypto exchanges to operate with certain regulatory flexibilities for a defined period. For instance, eligible fintech and digital asset businesses in the IFC sandbox may receive temporary exemptions from some technical standards or licensing procedures, and even enjoy government support or liability waivers during the testing phase. In return, they must rigorously self-assess and comply with risk controls. Regulators have made clear that pilot exchanges must implement stringent AML/CFT measures and cybersecurity protections in line with international norms. Exchanges will also be expected to carefully vet the tokens they list, focusing on “valuable, highly liquid assets” to protect investors from speculative excesses. By mid-2026, after sufficient data from the pilot, Vietnam intends to refine its approach and potentially license exchanges on a broader scale. This sandbox-first strategy – licensing a small number of exchanges with high entry barriers and institutional oversight – exemplifies Vietnam’s controlled experimentation. It provides a “cautious but credible path” to scale up the crypto market, allowing regulators to build capacity and trust gradually. For U.S. and global investors, the pilot program signals that Vietnam is serious about developing regulated trading venues which could eventually welcome foreign participation once fully established.
Legal Clarity, Investor Protection, and Civil Recourse
One of the most significant benefits of Vietnam’s new legal regime is the enhanced protection it affords to investors and consumers in the digital asset market. Previously, because crypto assets were unrecognized by law, investors had essentially no legal recourse if they were defrauded or lost access to their assets on an exchange. Cases of scams or exchange collapses left Vietnamese users with no statutory protections – a point tragically illustrated by investors who lost funds and could not seek help from authorities in the pre-regulation era. That era is now coming to an end. By recognizing digital assets as property, the law enables aggrieved investors to pursue claims through Vietnam’s legal system just as they would for other property disputes. “If a person lost their [crypto] assets, there was no legal basis for protection. Now… citizens can legally trade, transfer, donate, or inherit them, and be protected just like with other assets,” explained one Vietnamese lawyer about the new law. In practical terms, this means a Vietnamese investor who is a victim of hacking, fraud, or exchange misconduct can file civil suits or seek enforcement of contractual rights, with courts recognizing the digital asset in question as an item of value. Licensed exchanges and service providers are also subject to regulatory oversight for consumer protection, so they face legal consequences (including fines or loss of license) if they engage in unfair practices or fail to safeguard client assets. This dramatically improves the accountability of crypto businesses and the safety of investors’ funds.
Fraud prevention is a major driving force behind the regulations. Authorities revealed that in recent years, an overwhelming proportion of crypto-related complaints and investigations involved fraudulent schemes – one official noted that nearly 90% of cases reviewed by the Securities Commission had elements of fraud. Scammers exploited the legal vacuum, knowing victims had nowhere to turn. With the new framework, Vietnamese law enforcement and regulators have clearer authority to crack down on illegal activities. Unlicensed operators can be prosecuted, and fraudulent token offerings or Ponzi schemes can be pursued under statutes now that digital assets are explicitly covered. Additionally, by bringing crypto transactions into legal scope, Vietnam can enforce taxation (capturing revenue previously lost to the informal market) and impose reporting duties that deter illicit behavior. The law and the pilot regulations mandate robust AML and counter-terrorism financing compliance by crypto exchanges and custodians, aligned with FATF standards. This includes requirements for KYC (Know-Your-Customer) identity checks, transaction monitoring, and reporting of suspicious activities. The central bank and law enforcement are actively involved in ensuring that crypto does not become a haven for crime – even though large-scale abuse (e.g. terrorism financing) has not yet been observed domestically, officials are acting preemptively. Such measures will help weed out fly-by-night operators and build investor trust in the remaining, law-abiding platforms.
Importantly, legal clarity now provides civil recourse in scenarios that were previously unthinkable. If a licensed exchange were to suffer a hack or insolvency, Vietnamese users would have legal standing to claim compensation or remaining assets through the courts or the special dispute resolution mechanisms in the IFC. Investors “previously had minimal recourse in cases of fraud or exchange failure” but now enjoy “contractual and civil law protections,” as noted in a Vietnam Investment Review analysis. Furthermore, regulators are pushing exchanges to implement protective measures like asset segregation (keeping customer assets separate from exchange’s own funds), regular audits, and insurance or reserve requirements. Such measures, common in mature financial markets, significantly reduce the risk of consumers losing money to mismanagement. The emerging Vietnamese rules echo global best practices – for instance, authorities are studying U.S. proposals that stablecoin issuers maintain full reserves and that exchanges be able to freeze assets under court order when needed. By integrating these lessons, Vietnam is signaling that it will not tolerate the chaotic “wild west” conditions of the past. Instead, it seeks a well-regulated market where investors are protected by law, fraud is policed, and disputes can be resolved through official channels. This new environment should greatly bolster investor confidence, both for Vietnamese citizens and for foreign investors who can be more assured of legal protections when entering Vietnam’s crypto market.
Investment Opportunities in Vietnam’s Digital Asset Ecosystem
For U.S. investors – whether retail enthusiasts, venture capitalists, or fintech companies – Vietnam’s clarified legal status for crypto assets unlocks a host of investment opportunities that were previously high-risk or off-limits. With the government now legitimizing and supervising the sector, Vietnam’s digital asset ecosystem is poised for rapid development across several segments:
- Tokenized Assets (Real-World Assets): Vietnam’s recognition of digital tokens as property paves the way for tokenization of real-world assets such as real estate, commodities, or corporate bonds. Under the new law, tokenized assets can be legally issued and traded, provided they comply with relevant regulations (and are not simply disguised securities). This means U.S. institutional investors or venture-funded startups could collaborate with Vietnamese partners to launch platforms for tokenized real estate or infrastructure projects, allowing fractional ownership by investors globally. Vietnamese banks and asset managers, now operating with clear rules, can explore compliant offerings of tokenized real-world assets to clients. Such products can tap Vietnam’s growing capital markets while giving foreign investors new channels to Vietnamese assets through digital tokens. As always, projects will need to align with the SSC’s guidelines to ensure they don’t violate securities laws, but the overall legal acceptance of digital assets makes security token offerings (STOs) and other tokenization ventures viable in Vietnam for the first time.
- Stablecoins and Digital Currencies: Although Vietnam bans using cryptocurrency as a payment medium, it is very aware of the importance of stablecoins and digital currencies for innovation. The law explicitly excludes central bank digital currency (CBDC) or digital fiat from the “digital asset” definition, leaving those to separate regulation. However, USD-backed stablecoins are widely used by Vietnamese crypto users, and regulators are monitoring this trend. The MoF has indicated support for establishing licensing standards for stablecoin issuers. This opens opportunities for companies to issue VND-pegged stablecoins or other asset-backed stablecoins under a regulated model, potentially in partnership with Vietnamese banks or fintech firms. U.S. fintech companies specializing in stablecoin infrastructure might find a market for technology transfer or joint ventures to create compliant stablecoin platforms for Vietnam. Moreover, stablecoins could significantly improve remittances and cross-border payments for Vietnam’s diaspora if regulatory approval is granted in the future. With Vietnam watching the U.S. GENIUS Act (which mandates full reserve backing for stablecoins) closely, we can expect any Vietnamese stablecoin framework to emphasize reserve transparency and investor protection, thereby offering a new, secure asset class for investors to consider.
- Decentralized Finance (DeFi): Vietnam has been a hotbed of retail DeFi usage, ranking among the top countries in crypto adoption and on-chain DeFi activity. Thus far, Vietnamese DeFi projects (lending platforms, DEXs, etc.) have mostly been launched abroad or anonymously, due to domestic legal uncertainty. With the new law, DeFi startups have the chance to operate openly and legally through sandbox programs. Vietnam’s regulators have even acknowledged the legitimacy and potential of DeFi – noting that bringing DeFi into a legal framework can foster innovation and integrate crypto into the economy. We may see Vietnam’s sandbox or IFC allow controlled trials of DeFi protocols, perhaps with conditions like participant caps or disclosure requirements. This creates investment openings for U.S. venture capital to fund Vietnamese DeFi projects that are now onshore and compliant. Vietnamese developers are highly skilled (the country is known for strong math and engineering talent) and can contribute significantly to the global DeFi ecosystem if supported domestically. For U.S. investors, keeping an eye on Vietnamese DeFi ventures – whether decentralized exchanges, yield platforms, or innovative fintech dApps – could be rewarding, given the combination of local developer talent and a massive user base ready to adopt DeFi services once officially sanctioned.
- GameFi and Metaverse: Vietnam is already on the map in the GameFi sector – notably, it is the home of the team behind Axie Infinity, one of the earliest play-to-earn game successes. Many other blockchain game (GameFi) projects with Vietnamese founders have launched in recent years, often incorporating in Singapore or elsewhere for legal reasons. The new regulatory clarity offers a chance for Vietnam to nurture these projects domestically. GameFi combines Vietnam’s strengths in gaming and crypto adoption, and legal acceptance means gaming studios can issue tokens or NFTs to Vietnamese users without operating underground. U.S. investors and gaming companies may find Vietnam’s young, tech-savvy population a fertile ground for blockchain gaming ventures. With 70% of Vietnam’s population under age 35 and high mobile gaming penetration, regulated GameFi projects (from NFT-based games to metaverse platforms) could see huge engagement. Vietnam’s law could also extend legal protections to digital collectibles/NFTs as “virtual assets,” giving companies confidence to develop marketplaces and games locally. The ability to base operations in Vietnam (instead of relocating to Dubai or Singapore) can reduce costs and retain talent, making Vietnam’s GameFi scene an attractive investment ecosystem supported by government innovation policies.
- Digital Asset Custody and Infrastructure: A critical area now emerging is digital asset custody services – secure storage and management of crypto assets on behalf of investors. Traditionally, Vietnamese crypto users have either self-custodied or left assets on offshore exchanges, with significant risk. With institutional players entering the market, the demand for professional custody (meeting standards akin to traditional custodianship of securities) is rising. Vietnam’s framework encourages banks and licensed companies to offer digital custody services with proper legal protections and audit frameworks. This opens opportunities for collaboration: for example, U.S. custodians or wallet security firms could partner with Vietnamese banks to establish custody solutions for large investors, complete with insurance and compliance. We may also see Vietnamese fintech startups focusing on custody technology (multi-signature wallets, cold storage solutions) attract venture funding. Additionally, broader blockchain infrastructure development – such as blockchain-as-a-service platforms, developer tools, and security auditing services – will be needed to support the domestic ecosystem. U.S. investors might consider funding infrastructure startups or entering joint ventures to provide these backbone services in Vietnam’s growing market. Given the government’s push to become a blockchain security hub (leveraging local cybersecurity talent), there is likely support for companies that help audit smart contracts, secure exchanges, and build core tech for the industry. In summary, nearly every segment of the digital asset value chain – from issuance and trading to custody and utilitarian applications – is now on the table in Vietnam. With legal risks abating, U.S. entities have a green light to explore partnerships, investments, and market entry strategies into Vietnam’s crypto sector across tokenized assets, stablecoins, DeFi, GameFi, and infrastructure services.
Prospects for Institutional Adoption in Vietnam
A key question for investors is how quickly traditional financial institutions in Vietnam will embrace digital assets under the new regime. All indications suggest that Vietnam’s banks, securities firms, and fintech companies are gearing up to participate now that clearer regulations are in place. In fact, institutional involvement is effectively built into the framework: the pilot exchange program requires at least two regulated institutions (such as banks, brokers, or insurers) to be among the principal shareholders of each licensed exchange. This policy ensures that major Vietnamese financial institutions have skin in the game from the outset, accelerating institutional know-how in crypto trading. Already, some leading firms have signaled interest – SSI Securities (one of Vietnam’s largest brokerages) formed “SSI Digital” and its CEO publicly expressed eagerness for the regulatory framework to launch so that they can roll out new digital asset products. We can expect Vietnam’s top securities companies and fintech-savvy banks (such as Techcombank, Vietcombank, or VPBank) to either back new exchanges or develop in-house crypto service offerings for clients once permitted.
Banks in particular may explore roles in custody and settlement of digital assets. With the legal status clarified, Vietnamese banks could legally custody crypto for customers, much as U.S. banks have begun doing under regulatory guidance. Some banks might partner with tech companies to create joint ventures for crypto trading platforms or wallet services. Given that the law mandates strong AML controls, banks – already experienced in compliance – will be valuable contributors to ensuring exchanges meet reporting standards. Banks may also leverage blockchain technology for their own operations (e.g. interbank settlements or trade finance), now that blockchain is officially embraced as a strategic technology by the government.
Asset managers and funds are likewise poised to enter. Vietnam’s major funds (like Dragon Capital or VinaCapital) have so far largely stayed on the sidelines of crypto, but this could change swiftly. According to market experts, nearly all crypto trading in Vietnam to date has been driven by retail investors, with major institutional investors yet to participate in asset management capacity. That scenario is set to evolve. With a legal framework in place, large financial institutions can get involved “in a meaningful asset management capacity,” offering crypto-themed funds or investing directly in blockchain projects. It’s anticipated that once big institutions enter, the market will become more regulated and less volatile, as one SSI executive observed, because professional risk management and longer-term capital will counterbalance retail speculation. We might see the launch of Vietnam-based crypto investment funds, trusts, or exchange-traded products (ETFs) for local and foreign investors, subject to SSC approval. Global institutions may also find partnership opportunities – for example, a U.S. crypto hedge fund could team up with a Vietnamese firm to create a Vietnam-focused digital asset fund, now that such investments can be legally protected and custodied in Vietnam.
Fintech and payment companies are another important player group. Vietnam has a vibrant fintech scene (e-wallets, payment apps, remittance platforms) that could incorporate digital asset features. While direct crypto payments remain illegal, fintech firms could offer users services like buying/selling approved cryptocurrencies, loyalty tokens, or cross-border transfers via crypto in a regulated way. The law’s recognition of digital assets could allow fintechs to treat certain tokens as promotional or utility assets with clarity on their status. Additionally, the new regulations encourage technological integration in traditional sectors – for instance, insurance companies or e-commerce firms might use tokens or blockchain for customer rewards, now with legal sanction. Banks and fintechs are also exploring CBDC pilots (the State Bank has run a blockchain-based digital currency pilot project 2021–2025), which indicates an overall institutional willingness to adopt crypto-related innovations when guided by government policy.
In summary, Vietnam’s institutional adoption is on the cusp of acceleration. Banks, asset managers, and fintechs now have official backing to engage with digital assets in a compliant manner, from launching new investment products to integrating blockchain into services. The presence of institutions will not only provide new offerings to Vietnamese consumers (such as secure custody, crypto investment funds, and tokenized securities on regulated exchanges) but also raise the bar for market integrity. Major institutions bring credibility and rigorous standards, helping Vietnam’s crypto market mature. For U.S. institutional investors, this trend is encouraging: it means any partnerships or investments in Vietnam will likely involve reputable Vietnamese counterparts with government licenses. It also suggests that exit opportunities (such as IPOs or M&A) for crypto ventures in Vietnam may improve as the sector formalizes. Vietnam is moving from a retail-driven, informal market to an institutionally-anchored, professionally managed ecosystem, which bodes well for sustainable growth and investor confidence.
In conclusion, Vietnam’s current crypto regulatory landscape represents a new era of legal clarity and strategic vision. For years, Vietnam had one of the world’s most active crypto communities operating in a legal grey zone; now, law and policy have caught up. The Law on Digital Technology Industry and its forthcoming implementing regulations provide a robust framework that recognizes digital assets as legal property, licenses exchanges and service providers, and protects investors. The pilot program for exchanges – with its high standards for capitalization and governance – illustrates Vietnam’s measured, safety-first approach to market development. These regulatory advances will bring much-needed investor protections, reduce fraud, and enable civil recourse in the event of disputes. At the same time, they unlock myriad opportunities: from tokenized assets and stablecoins to DeFi and GameFi ventures that can now flourish under the Vietnamese flag. Institutional adoption is poised to accelerate, with banks and funds entering the space and imposing greater stability and trust. To fully capitalize on this potential, Vietnam will need to invest in its infrastructure and talent, and it appears ready to do so with supportive policies and the establishment of the IFC hub.
For U.S. investors, Vietnam’s crypto renaissance offers a unique proposition: a large, youthful market with high crypto literacy, now buttressed by law and open for business. It presents a chance to participate in the growth of a new digital finance hub at an early stage. Vietnam’s journey – from a regulatory grey area to a model of controlled innovation – exemplifies a global trend that crypto is here to stay and must be integrated into the financial system with prudent oversight. By bridging innovation with trust and ambition with accountability, Vietnam is charting a path that could see it emerge as one of the leaders in the next chapter of the digital asset economy. Investors who understand this landscape and engage with Vietnam’s ecosystem may find significant rewards, while also contributing to the shaping of a safer and more inclusive global crypto market.
As a U.S.-listed fintech company with majority ownership of ONUS Pro, one of Vietnam’s leading digital asset exchanges, VMNT is strategically positioned to benefit from this regulatory evolution. The new framework, particularly the licensing of exchanges and the establishment of the International Financial Centre, creates a pathway for ONUS Pro to operate under official approval. This not only enhances credibility and investor protection but also opens the door for institutional partnerships with Vietnamese banks and securities firms. For VMNT’s investors, the reforms represent a timely opportunity to participate in Vietnam’s transition from a grey-market environment to a regulated digital finance hub.
Citations
Vietnam Passes First-Ever Law on Digital Technology Industry
Vietnam: Landmark Law on Digital Technology Industry - New Frameworks for AI & Digital Assets - DFDL
Legalizing digital assets opens new investment opportunities in Vietnam
From a “gray area” to the first legal framework for digital assets in Vietnam
Vietnam: Landmark Law on Digital Technology Industry - New Frameworks for AI & Digital Assets - DFDL
Crypto market poised to explode as the Government inches closer to legalise digital asset exchange
Vietnam's Crypto Regulation: From Regulatory Gray Zone to Controlled Experimentation
Việt Nam advances crypto exchange pilot programme
Crypto market poised to explode as the Government inches closer to legalise digital asset exchange
Vietnam: Establishing the IFC to power future technology, innovation, and digital transformation - Baker McKenzie InsightPlus
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