Dr. Hung opened the meeting emphasizing the need to hear directly from participants about difficulties with domestic transaction screening — an issue affecting both foreign and domestic banks. He stated that VNBA would compile these concerns and work with the State Bank of Vietnam (SBV) on potential improvements.

Dr. Nguyen Quoc Hung, VNBA Vice Chairman cum Secretary General

Practical challenges highlighted focused on inadequate customer identification data in domestic transfer orders — common name duplication in Vietnamese, and missing attributes like ID numbers, birthdates, and addresses — leading to high false positive rates. In addition, the quality and consistency of screening lists supplied by authorities were noted as problematic: only the police blacklist is publicly accessible, while the Ministry of National Defence list lacks clear publication, and the SBV’s alert list is disseminated via fragmented communications rather than a centralized database.

Representatives from BWG and international banks such as MUFG, Standard Chartered, HSBC, and CitiBank noted that real-time screening today places heavy burdens on IT infrastructure and operational costs, negatively impacting user experience — especially in fast payment channels like QR Code and NAPAS. They suggested that under international practice and FATF recommendations, domestic screening need not be real-time as cross-border screening is; focusing instead on strong customer identification at onboarding.

Domestic banks including Vietcombank, VietinBank, BIDV, and Agribank agreed that the issue lies less with technology and more with data limitations. They underscored that isolated technological solutions cannot fully solve the problem without industry-wide data-sharing mechanisms. They also noted that, legally, the originating bank remains accountable under anti-money laundering laws even where joint agreements exist.

Notably, BWG proposed considering a sector-wide cooperation framework allowing banks to leverage third parties in customer due diligence under Article 14 of the AML Law — a path that could reduce compliance burdens while still meeting financial security goals.

At the meeting’s close, Dr. Hung proposed a two-pronged approach: In short term, strengthening coordination and harmonizing implementation across banks to improve information sharing and reduce operational risk. In long term, advocating for regulatory refinements, enhanced data standards, and clearer distinctions between domestic and cross-border screening requirements.

Dr. Hung reiterated the need to balance legal compliance with seamless payment operations — protecting both the integrity and efficiency of Vietnam’s banking system.

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