Circular No. 27/2025/TT-NHNN guiding the implementation of the Law on Anti-Money Laundering

Circular No. 27/2025/TT-NHNN of the State Bank of Vietnam, providing guidance on the implementation of several provisions of the Law on Anti-Money Laundering, was issued on September 15, 2025.

Effective from November 1, 2025, the Circular stipulates:

  • Criteria and methods for assessing money laundering risks of reporting entities;

  • Procedures for money laundering risk management and customer risk classification;

  • Internal regulations on anti-money laundering;

  • Regime for reporting large-value transactions subject to reporting.

  • Regime for reporting suspicious transactions and wire transfer transactions;

  • Forms and deadlines for electronic data reporting;

  • Threshold values and supporting documents required by customs authorities when carrying foreign currency in cash, Vietnamese dong in cash, negotiable instruments, precious metals, or gemstones exceeding prescribed limits.

Circular No. 27/2025/TT-NHNN

The Circular also applies to:
  • Financial institutions;

  • Designated non-financial businesses and professions (DNFBPs);

  • Vietnamese organizations and individuals, foreign organizations and individuals, and international organizations engaged in transactions with financial institutions or DNFBPs;

  • Other organizations and individuals related to anti-money laundering activities.

Article 3 of Circular No. 27/2025/TT-NHNN also provides criteria and methods for assessing money laundering risks of reporting entities, including:

  1. Criteria for assessing money laundering risks, which cover both money laundering risk factors and the adequacy of internal policies and regulations on anti-money laundering at the reporting entity.

  2. Money laundering risk factors include risks arising from the business environment of the reporting entity and risks arising from the business activities of the reporting entity.

  3. Criteria on the adequacy of internal policies and regulations on anti-money laundering include the comprehensiveness of such internal policies/regulations and the effectiveness of their implementation.

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