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Vietnam

Brief summary:

Vietnam

Higher Risk

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Risk Indicators

  • FATF/EU Blacklist/Greylist (Higher Concern)
  • Terrorism Financing (Lower Concern)
  • US Dept of State INCSR
  • Proliferation Financing
  • Corruption
  • Criminality
  • Resilience & Governance
  • Financial Transparency
  • Offshore Finance Centres
  • Sanctions

Background

Vietnam’s history reflects successive periods of foreign occupation, dynastic consolidation, territorial expansion, and eventual reunification under Gia Long in 1802. From the Ly Dynasty’s establishment of Dai Viet and Thang Long to Tran Hung Dao’s resistance against Mongol invasions, the country’s political identity developed through recurring conflict and state-building. French colonial rule, the Geneva division of 1954, and the Second Indochina War later shaped Vietnam’s modern borders, institutions, and society.

Following reunification in 1975, diplomatic isolation and internal policies constrained growth until the “doi moi” reforms helped stimulate agriculture, industry, exports, foreign investment, construction, and tourism. The Communist Party continues to exercise tight political and social control while challenges including corruption and income inequality remain significant. Vietnam also balances tensions involving China’s South China Sea claims and cyber activity with security concerns linked to Laos and Cambodia, including scam networks, sanctions exposure, trafficking, and illicit financial flows.

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AML & Terrorist Financing

Vietnam remains subject to strategic AML/CFT deficiencies identified by FATF and was also placed on the European Commission’s high-risk jurisdiction list, with continuing concerns around risk understanding, supervision, beneficial ownership, virtual assets, and technical compliance. The Anti-Money Laundering Department of the State Bank of Vietnam and the Ministry of Public Security face challenges involving limited financial intelligence, weak interagency and international cooperation, few parallel money-laundering investigations, and uneven implementation across financial institutions and DNFBPs. Terrorist-financing risks are comparatively low, but gaps in targeted financial sanctions, proliferation-financing controls, private-sector monitoring, and enforcement—against a backdrop of cash usage, porous borders, corruption, cyber-enabled crime, and trade-related vulnerabilities—remain significant areas of attention.

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Sanctions

Vietnam supports United Nations sanctions regimes, including measures involving arms, travel, financial, and commodity restrictions, but no international sanctions are currently in force against the country itself. Its own enforcement has focused on tighter inspections, stricter “Made in Vietnam” certification, and inter-agency action against suspected transshipment linked to China, Russia, and historically North Korea. External pressure has nevertheless increased, notably when the EU’s 17th sanctions package in May 2025 targeted a Vietnamese firm alleged to have supported Russian military supply chains, while the United States and EU remain concerned about broader evasion routes through Vietnam.

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Criminality

Corruption remains widespread in Vietnam despite criminalization under the Anti-Corruption Law and Penal Code, with limited transparency, overlapping bureaucratic jurisdictions, weak conflict-of-interest safeguards, and concerns about selective accountability. The country also faces extensive illicit activity involving trafficking, counterfeit and excise goods, illegal timber and wildlife, synthetic drugs, cyberattacks, fraud, and tax evasion, while bodies such as the Communist Party Central Committee Internal Affairs and Towards Transparency provide channels for reporting concerns.

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Reports

Vietnam faces complex narcotics pressures as porous land and maritime borders facilitate synthetic drug and heroin trafficking, while the Ministry of Public Security, Customs, and defense authorities expand seizures, investigations, precursor-chemical controls, and cooperation with U.S. agencies. Human trafficking concerns span domestic exploitation, overseas labor and sex trafficking, and forced criminality in online scam operations, with a new anti-trafficking law and increased prosecutions accompanying continuing gaps in victim identification, specialized services, and protection for returnees.

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Industry/Product Sector Risk

Vietnam’s industry risk landscape is shaped by a cash-based economy, with banking identified as the most exposed channel alongside real estate, casinos, currency exchange, remittances, trade finance, and virtual assets. The State Bank of Vietnam and its branches face a complex supervisory environment involving cross-border flows, beneficial-ownership opacity, informal value transfer, and uneven risk-based controls across domestic institutions and smaller operators. Beyond finance, corruption, smuggling, illegal gambling, trade-based laundering, environmental crime, and infrastructure-related procurement risks create interconnected exposure across transportation, construction, agriculture, technology, and other key sectors.

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Economy & Investment Climate

Vietnam’s economy continues to draw substantial foreign investment, supported by political stability, trade agreements, export-oriented manufacturing, and growing ambitions in semiconductors, AI, energy, and other high-tech sectors, while FDI-linked firms account for a notable share of exports. At the same time, investors must navigate evolving regulations, foreign ownership limits, state-owned enterprise advantages, skilled-labor shortages, data and land requirements, and uneven administrative enforcement under institutions including the Ministry of Finance, State Bank of Vietnam, and Vietnam Competition and Consumer Authority.

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Cryptocurrency Regulations

Vietnam is moving from an uncertain digital-asset landscape toward structured recognition, with the Law on Digital Technology Industry, Resolution No. 05/2025/NQ-CP, and a Ministry of Finance–led pilot regime shaping how crypto services, token offerings, and asset tokenization may develop through 2030, while the State Bank of Vietnam maintains that crypto is not lawful payment currency. Licensed providers face substantial capital, ownership, KYC/AML, Travel Rule, transaction-reporting, and tax obligations, although the National Risk Assessment’s concerns around wallet providers and stablecoins—and the absence of publicly confirmed fully licensed VASPs—suggest that significant implementation details remain ahead.

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