Hanoi, September 15, 2025. The Governor of the State Bank of Vietnam (SBV) has signed Circular No. 27/2025/TT-NHNN (Circular 27) guiding the implementation of a number of Articles of the Law on Anti-Money Laundering.
Circular 27 is built on the basis of inheriting the relevant provisions of Circular No. 09/2023/TT-NHNN; amending and supplementing certain contents to remove major difficulties and obstacles faced by reporting entities and supervisory authorities in the course of implementation, while at the same time ensuring strict fulfillment of the commitment under Action No. 5 of the Annex to the National Action Plan for implementing the Government of Vietnam’s commitments on combating money laundering, terrorist financing, and financing of proliferation of weapons of mass destruction with the Financial Action Task Force (FATF), promulgated together with Decision No. 194/QD-TTg dated February 23, 2024 by the Prime Minister.
Circular 27 is composed of 13 Articles, providing regulations on: criteria and methods for assessing money laundering risks of reporting entities; procedures for managing money laundering risks and classifying customers by levels of money laundering risk; internal regulations on anti-money laundering; reporting regime for large-value transactions subject to reporting; reporting regime for suspicious transactions; electronic funds transfers; reporting regime for electronic funds transfers; forms and deadlines for reporting electronic data; thresholds and supporting documents required for customs clearance when carrying foreign currencies in cash, Vietnamese dong in cash, negotiable instruments, precious metals, and gemstones exceeding the prescribed limits.
Entry into force: Circular 27 enters into force on November 1, 2025. However, in order to provide reporting entities with sufficient time to prepare for proper implementation of the adjusted provisions related to internal regulations, risk management procedures, reporting templates, and reporting requirements, Circular 27 stipulates transitional provisions for certain contents, specifically:
- Reporting entities shall continue to apply the current provisions on internal regulations and risk management procedures until December 31, 2025.
- From January 1, 2026, reporting entities shall be responsible for completing the adjustment and update of internal regulations and risk management procedures to ensure full compliance with Circular 27, and for developing appropriate information technology systems to support electronic data reporting. They must also have software systems in place to screen and filter against blacklists, warning lists, and lists of politically exposed persons as provided in Clauses 9 and 10 of Article 3 and Clause 1 of Article 17 of the Law on Anti-Money Laundering, and to monitor transactions to detect and alert suspicious signs in order to combat money laundering, terrorist financing, and financing of proliferation of weapons of mass destruction.
HM