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Clause 9, Article 1 of Law No. 23/2026/QH16 adds Article 33a after Article 33 of the Law on the State Bank of Vietnam, providing 15 suspicious signs in the crypto-asset sector:
(1) Splitting crypto-asset transactions into multiple amounts of lower value than the prescribed threshold for customer identification or reporting, or conducting multiple large-value crypto-asset transactions within a short period of time without a clear business purpose.
(2) The occurrence of any of the following cases that is inconsistent with the customer’s profile and characteristics: making deposits, conducting transactions and withdrawing crypto-assets consecutively within a very short period of time immediately after establishing the customer relationship; making a large-value initial deposit immediately after opening a crypto-asset account; or conducting transactions of a large value or at an unusual frequency through a crypto-asset account that has been inactive for a long period of time.
(3) Immediately transferring crypto-assets to multiple crypto-asset service providers in countries or territories included in lists published by the Financial Action Task Force for anti-money laundering, counter-terrorist financing and countering the financing of the proliferation of weapons of mass destruction, or in countries or territories that have not promulgated or have not fully promulgated legal frameworks on anti-money laundering, counter-terrorist financing and countering the financing of the proliferation of weapons of mass destruction applicable to crypto-assets and crypto-asset service providers and are included in lists concerning crypto-assets published by the Financial Action Task Force, while having no reasonable connection with the customer’s place of residence or place of operation.
(4) Converting crypto-assets into multiple different types of crypto-assets without a reasonable business or investment purpose, or converting crypto-assets into fiat currency under unfavorable price conditions, accepting losses or incurring transaction fees that are unusually high compared to the state of the blockchain network at the time of the transaction.
(5) Multiple accounts or wallet addresses having no clear relationship jointly transferring crypto-assets to the same wallet address, or one account transferring crypto-assets to multiple different wallet addresses in equivalent amounts consecutively within a short period of time.
(6) Conducting transactions involving crypto-assets with enhanced anonymity features or transaction mixing services, or repeatedly converting crypto-assets recorded on a public and transparent distributed ledger into crypto-assets with enhanced anonymity features, thereby disrupting transaction traceability.
(7) Conducting crypto-asset transactions from wallet addresses or crypto-asset service providers identified or warned by competent authorities as being related to anonymous websites trading in illegal goods or services, extortion, fraud, illegal online gambling, stolen assets or other criminal activities.
(8) A customer accesses the platform of a crypto-asset service provider through tools that allow identity anonymization or Internet Protocol address anonymization, or multiple crypto-asset accounts registered under different identities show signs of being operated from the same device or Internet Protocol address.
(9) A customer refuses or delays providing customer identification documents or information on the origin of assets; provides documents showing signs of forgery or inconsistent information; or is unable to provide a reasonable explanation of the purpose of the transaction, the origin of the assets and the relationship with the counterparty.
(10) The customer’s crypto-asset wallet address appears in public information sources as being related to illegal activities, or the deposited or withdrawn crypto-assets have a history of passing through cross-chain bridges assessed as high-risk.
(11) A customer shows signs of acting as a nominee, being used as an intermediary, or being a victim of fraud, including cases in which the customer has limited knowledge of crypto-assets but conducts transactions with a frequency and value inconsistent with the customer’s profile and characteristics, or conducts transactions under instructions from a third party.
(12) The customer’s assets are mainly derived from initial crypto-asset offerings that lack transparency or show signs of fraud, or the customer’s crypto-assets originate directly from transaction mixing services or crypto-asset service providers lacking anti-money laundering controls.
(13) Conducting transactions with a crypto-asset service provider whose valid legal status cannot be identified, including cases in which it operates in a country or territory having no legal framework on crypto-assets and included in lists concerning crypto-assets published by the Financial Action Task Force; is not included in the list of entities licensed by the competent authority of the host country; or has been warned, suspended or had its operation license revoked by a competent authority.
(14) Notes accompanying crypto-asset transactions show signs of being related to illegal activities, or a customer frequently changes important identification and authentication information in a manner inconsistent with ordinary usage; conducts transactions from an Internet Protocol address inconsistent with the information provided by the customer; or repeatedly opens crypto-asset accounts from the same Internet Protocol address.
(15) A customer conducts transactions through a crypto-asset service provider headquartered or operating in a country or territory included in lists published by the Financial Action Task Force for anti-money laundering, counter-terrorist financing and countering the financing of the proliferation of weapons of mass destruction, or in a country or territory that has not promulgated or has not fully promulgated legal frameworks on anti-money laundering, counter-terrorist financing and countering the financing of the proliferation of weapons of mass destruction applicable to crypto-assets and crypto-asset service providers and is included in lists concerning crypto-assets published by the Financial Action Task Force.
