This Circular builds upon the applicable provisions of Circular No. 09/2023/TT-NHNN, while revising and supplementing several key aspects to address implementation challenges faced by reporting entities and supervisory authorities. It also ensures Vietnam’s compliance with Action 5 of the National Action Plan under Decision No. 194/QĐ-TTg (23 February 2024), reflecting the Government’s commitments to the Financial Action Task Force (FATF) in combating money laundering, terrorist financing, and proliferation financing.
Key provisions of Circular 27
The Circular, comprising 13 Articles, sets out:
- Criteria and methodology for assessing money laundering risks (risk-scoring approach).
- Risk management framework and customer risk classification.
- Internal regulations on AML: policies, procedures, and templates.
- Reporting regimes: large-value transactions, suspicious transactions, and electronic funds transfers.
- Electronic reporting requirements: format, timelines, and system specifications.
- Cross-border declarations: thresholds and documentation for foreign currency cash, VND cash, negotiable instruments, precious metals, and gemstones.
Effective date and transitional provisions
- The Circular takes effect on 01 November 2025.
- Reporting entities may continue to apply existing internal rules and risk management procedures until 31 December 2025.
- From 01 January 2026, reporting entities are required to:
- Update and align their internal AML policies and risk management procedures with Circular 27;
- Implement adequate IT systems to enable electronic reporting;
- Deploy automated tools to screen against blacklists, watchlists, and politically exposed persons (PEPs);
- Monitor and flag suspicious transactions in compliance with AML/CFT standards.
Impact and significance
Circular 27 marks an important step in aligning Vietnam’s AML regulatory framework with international standards, enhancing transparency in the financial system, and strengthening resilience against money laundering, terrorist financing, and proliferation financing risks.
SBV/VNBA News
