Five of Vietnam’s most powerful financial institutions have cleared the first hurdle in a high-stakes race to build the country’s inaugural licensed cryptocurrency exchanges. Simultaneously, the Ministry of Finance is drafting legislation that would prohibit Vietnamese citizens from trading on foreign platforms altogether — a dual regulatory strategy that could reshape one of the most active digital asset markets on the planet.
The developments, first reported by Reuters on March 17, 2026, mark the culmination of years of regulatory deliberation in Hanoi and signal an abrupt end to the legal grey zone that has defined Vietnamese crypto trading for the better part of a decade.
The Five Contenders
A finance ministry document dated March 12 confirms that five companies have passed the initial qualification round to operate licensed domestic crypto exchanges under Vietnam’s pilot programme:
- A Techcombank affiliate — backed by Technological and Commercial Joint Stock Bank, one of Vietnam’s largest private lenders by assets.
- A VPBank affiliate — connected to Vietnam Prosperity Joint-Stock Commercial Bank, a major consumer and digital banking player.
- An LPBank affiliate — linked to Lien Viet Post Joint Stock Commercial Bank, known for its extensive rural banking network.
- VIX Securities — one of Vietnam’s prominent stockbrokers, already deeply embedded in the country’s capital markets infrastructure.
- Sun Group — one of Vietnam’s largest private conglomerates, with a sprawling portfolio spanning real estate, tourism, hospitality, and entertainment.
The mix of applicants is telling. Three are affiliates of major commercial banks, one is an established securities broker, and one is a diversified conglomerate with deep pockets. There are no crypto-native startups, no foreign exchanges, and no Web3 protocol teams. This is by design.
Vietnam’s licensing framework, established under Resolution No. 05/2025/NQ-CP and operationalised through Decision No. 96/QĐ-BTC issued by the Ministry of Finance in January 2026, was explicitly calibrated to attract institutional heavyweights — and to exclude everyone else.
A $380 Million Barrier to Entry
The capital requirements alone make Vietnam’s crypto exchange licence one of the most expensive in the world.
Applicants must demonstrate minimum paid-up charter capital of 10 trillion Vietnamese dong (approximately $380–400 million). At least 35% of that capital must come from regulated financial institutions such as commercial banks, securities firms, fund management companies, or insurance companies. Foreign ownership is capped at 49%, ensuring that control remains squarely in Vietnamese hands.
To put this in perspective, Hong Kong’s forthcoming crypto licensing regime requires a minimum of HKD 5 million (roughly $640,000). Singapore’s Major Payment Institution licence demands S$250,000 in base capital. Even the European Union’s comprehensive MiCA framework tops out at €150,000 for the most capital-intensive licence category.
Vietnam’s $380 million threshold is in an entirely different league. It is less a licensing fee than a declaration of intent: only the country’s most financially resilient institutions need apply.
The ownership structure requirements reinforce this philosophy. At least 65% of capital must be held by institutional shareholders, and each investor — whether individual or institutional — may only invest in a single licensed crypto-asset service provider. This prevents cross-ownership, limits market concentration through opaque structures, and ensures that regulators can trace accountability to specific entities.
The Pilot Programme: Five Years, Five Exchanges
The pilot scheme is expected to run for five years, approving approximately five exchanges during that period. The State Securities Commission (SSC) — Vietnam’s capital markets regulator — began accepting applications on January 20, 2026, following the formal launch of the licensing procedures.
This is a two-stage process designed to filter out speculative applicants:
Stage One: Companies submit an initial dossier demonstrating that they meet capital, ownership, and governance requirements. The Ministry of Finance reviews submissions and, if satisfied, authorises applicants to proceed.
Stage Two: Successful first-round applicants then have up to 12 months to submit the remaining documentation — including detailed operational procedures, technology assessments, and cybersecurity certifications — before a final licence can be granted.
The March 12 finance ministry document indicates that all five firms have cleared Stage One. They now face the more demanding task of assembling the operational, technological, and compliance infrastructure required to satisfy Stage Two.
What Licensed Exchanges Must Build
The requirements for obtaining a final licence go far beyond capital adequacy. Vietnam is treating crypto exchanges as regulated financial market infrastructure — closer to stock exchanges than to fintech payment apps.
Governance and Personnel
Licensed platforms must employ:
- A CEO with at least two years of experience in regulated financial sectors
- A Chief Technology Officer with at least five years of experience in financial or enterprise technology
- At least 10 cybersecurity-qualified IT personnel
- At least 10 licensed securities professionals in operational roles
This effectively eliminates anonymous founders, pseudonymous teams, and crypto-native leadership without traditional finance credentials. Vietnam wants operators who understand regulators, compliance frameworks, and institutional risk management.
Compliance and Risk Management
Applicants must submit detailed written procedures covering:
- Risk management frameworks
- Information security and data protection protocols
- Custody and client asset protection
- Trading, clearing, and settlement procedures
- Anti-money laundering (AML), counter-terrorism financing (CTF), and counter-proliferation financing policies
- Market surveillance and manipulation detection
- Internal controls and audit mechanisms
- Conflict of interest management
- Customer complaint handling and compensation procedures
- Information disclosure requirements
This mirrors — and in several areas exceeds — the compliance requirements imposed on traditional stock exchanges and securities trading platforms.
Cybersecurity: Level 4 or Nothing
Perhaps the most technically demanding requirement concerns cybersecurity. Licensed platforms must achieve Level 4 cybersecurity classification under Vietnam’s national information security laws before going live. This involves:
- Formal government security assessments
- Approval by the Ministry of Public Security
- Ongoing monitoring and reporting obligations
Level 4 represents one of the highest cybersecurity thresholds applied to any crypto regime globally, reflecting Hanoi’s acute awareness of the fraud and hacking risks that have plagued unregulated exchanges worldwide.
The Offshore Ban: Closing the Exits
While the licensing framework creates a domestic on-ramp, the Ministry of Finance is simultaneously working to close the offshore exits.
Draft rules currently under development would prohibit Vietnamese nationals from trading on overseas cryptocurrency platforms — including the three dominant exchanges that currently serve the Vietnamese market: Binance, OKX, and Bybit.
Although there is no explicit ban on owning cryptocurrencies in Vietnam, digital assets are not recognised as money or a legal means of payment. As a result, the overwhelming majority of Vietnamese crypto traders currently use overseas centralised exchanges, which operate beyond the reach of domestic regulators and tax authorities.
The proposed ban would change this calculus entirely. Once licensed domestic exchanges are operational, they would become the only legal venues for Vietnamese nationals to trade digital assets. Violators could face administrative penalties and potentially criminal prosecution.
The enforcement mechanisms for such a ban remain unclear. Vietnam already maintains some of the most restrictive capital controls in Southeast Asia, and the country’s internet infrastructure gives authorities significant leverage over cross-border digital services. However, the crypto community has historically proven adept at circumventing geographic restrictions through VPNs and decentralised protocols — a challenge that China’s own offshore trading ban has never fully resolved.
Why Now? The Convergence of Three Pressures
Vietnam’s decision to simultaneously license domestic exchanges and ban offshore trading did not emerge in a vacuum. Three distinct pressures converged to force Hanoi’s hand.
1. Capital Flight and the Dollar Premium
Vietnam tightly restricts cross-border capital transfers, but cryptocurrency has created a de facto loophole. With over $200 billion in annual transaction volume flowing through offshore exchanges, regulators are concerned that crypto and stablecoins have become a shadow channel for capital flight — undermining monetary policy and weakening the central bank’s ability to manage foreign exchange reserves.
Vietnamese households have historically faced limited domestic investment options. Real estate and gold have long served as the primary stores of value, but both come with significant distortions. Gold trades at approximately a 10% premium to global benchmarks in Vietnam — a direct consequence of restricted supply and limited alternatives. Property markets are prone to speculative bubbles fuelled by excess liquidity with nowhere else to go.
Cryptocurrency emerged as a third option: accessible, liquid, and — critically — denominated in foreign currencies. For Hanoi, this represents not just a regulatory challenge but a macroeconomic vulnerability.
2. The FATF Grey List
Vietnam has been on the Financial Action Task Force’s “grey list” — formally known as Jurisdictions under Increased Monitoring — a designation that signals to the global financial community that the country has strategic deficiencies in its anti-money laundering and counter-terrorism financing frameworks.
The FATF’s February 2026 review specifically examined Vietnam’s progress, and the country’s unregulated crypto sector has been identified as a significant vulnerability. By bringing crypto trading onshore and under direct regulatory supervision, Hanoi is making a tangible effort to address one of the key deficiencies flagged by the FATF — potentially paving the way for eventual delisting.
Getting off the grey list matters enormously for Vietnam’s broader economic ambitions. The designation increases compliance costs for international banks doing business with Vietnamese counterparts, raises borrowing costs, and creates reputational friction for a country that is aggressively courting foreign direct investment in manufacturing, technology, and financial services.
3. The Digital Technology Law
The legal groundwork was laid by the Law on Digital Technology Industry, passed by Vietnam’s National Assembly in June 2025 and taking full effect on January 1, 2026. For the first time, this law officially recognised digital assets as “property” under the Civil Code — giving regulators the legal basis to tax transactions, enforce inheritance and property rights, and empower law enforcement to investigate fraud.
Prior to this law, crypto existed in a legal grey zone where it was neither prohibited nor properly classified. The reclassification as property was the prerequisite for everything that followed: the licensing framework, the pilot programme, and the proposed offshore ban all derive their legal authority from this foundational change.
Vietnam’s Crypto Market: The Numbers
Vietnam’s crypto market is massive relative to the country’s economic size:
- 4th globally in the 2025 Chainalysis Global Crypto Adoption Index — behind only India, Nigeria, and Indonesia
- $200 billion+ in transaction volume in the 12 months through June 2025
- Population of 100 million, with a median age of approximately 31 — one of the youngest and most digitally connected populations in Southeast Asia
- Smartphone penetration above 70%, with mobile-first financial services adoption accelerating rapidly
- GDP per capita of approximately $4,300 — making Vietnam a middle-income country where crypto’s appeal as an alternative investment vehicle and remittance channel is particularly strong
The combination of high adoption, large volumes, and a young, tech-savvy population explains both the urgency of regulation and the scale of the economic opportunity that licensed exchanges will compete to capture.
The Vietnam Blockchain Association’s Endorsement
The Vietnam Blockchain Association (VBA) has publicly endorsed the government’s approach, arguing that regulated local exchanges will:
- Keep transaction fees within the domestic economy rather than routing them to foreign platforms and their overseas shareholders
- Strengthen the broader digital sector by creating a regulated ecosystem that attracts institutional capital and fosters innovation
- Improve consumer protection by subjecting exchange operators to the same oversight standards as traditional financial institutions
- Support tax compliance by making crypto transactions visible to the General Department of Taxation
The VBA’s support is significant because the organisation represents a broad cross-section of Vietnam’s blockchain and crypto industry, including developers, entrepreneurs, and institutional investors. Its backing suggests that the domestic industry, while acknowledging the restrictive nature of the framework, views regulated legitimacy as preferable to the legal uncertainty of the current environment.
The Critics: Liquidity, Innovation, and the China Comparison
Not everyone is convinced that Hanoi’s approach will succeed.
The Liquidity Problem
International exchanges like Binance, OKX, and Bybit offer thousands of trading pairs, deep order books, advanced trading instruments (perpetual futures, options, margin trading), and 24/7 liquidity that domestic startups are unlikely to match in the near term.
Five newly licensed Vietnamese exchanges, no matter how well-capitalised, will initially struggle to offer comparable market depth. Vietnamese traders accustomed to instant execution on global platforms may find domestic alternatives slow, expensive, and limited in scope — particularly for altcoin trading and derivatives.
The Innovation Concern
By requiring $380 million in capital and mandating that leadership come from traditional finance backgrounds, Vietnam’s framework effectively locks out the crypto-native innovators who have driven much of the global industry’s growth. Critics argue that this will produce exchanges that look and feel like traditional securities platforms — regulated, compliant, and thoroughly boring — rather than the dynamic, fast-moving marketplaces that have attracted millions of Vietnamese users.
The China Parallel
Some market participants have drawn comparisons to China’s approach. Beijing banned cryptocurrency trading and mining in 2021, forcing activity offshore or underground. Despite the ban, Chinese traders remain among the most active in global crypto markets, accessing foreign exchanges through VPNs and over-the-counter (OTC) networks.
Vietnam’s proposed offshore ban could produce a similar dynamic: a compliant on-shore market for institutional players and cautious retail investors, alongside a thriving underground economy for traders who refuse to be confined to domestic platforms with limited liquidity and higher costs.
The critical difference is enforcement capacity. China has far more resources to devote to internet surveillance and financial monitoring than Vietnam. If Hanoi cannot effectively block access to foreign platforms, the offshore ban may push activity into less visible, harder-to-regulate channels rather than eliminating it.
Regional Context: Southeast Asia’s Regulatory Patchwork
Vietnam’s move comes amid a broader wave of crypto regulation across Southeast Asia, though approaches vary dramatically:
- Singapore has established itself as a regulated crypto hub under the Payment Services Act, with a licensing regime that balances innovation with oversight.
- Thailand has required crypto exchanges to be licensed since 2018 and recently expanded its framework to include decentralised finance (DeFi) activities.
- Indonesia transferred crypto regulatory authority from its commodities regulator to its financial services authority (OJK) in January 2025, signalling a shift toward treating digital assets as financial products.
- The Philippines regulates crypto through its central bank and securities commission, with a relatively permissive framework compared to Vietnam.
- Malaysia requires crypto exchanges to be registered with the Securities Commission and has taken enforcement action against unlicensed operators.
Vietnam’s approach is the most restrictive in the region in terms of capital requirements and the proposed offshore ban. However, it also represents the most comprehensive attempt to integrate crypto into the formal financial system — rather than treating it as a peripheral or niche asset class.
What Happens Next
The timeline is tight. According to the February government resolution, the pilot programme could begin operating as soon as March 2026. With the five qualifying firms now working through Stage Two of the licensing process, the first licensed exchanges could be operational by mid-to-late 2026 — assuming they can meet the demanding technical, governance, and cybersecurity requirements within the 12-month window.
Several key milestones to watch:
- Final licensing decisions — When the SSC issues the first full exchange licences, confirming which of the five firms (if not all) will actually launch.
- The offshore ban — When the Ministry of Finance formalises and implements the prohibition on overseas trading, and what enforcement mechanisms accompany it.
- Market launch — The first day of trading on a licensed Vietnamese crypto exchange, including which assets are available, what trading pairs are offered, and what fee structures look like.
- FATF review — Whether Vietnam’s crypto regulatory reforms contribute to a positive reassessment in the FATF’s next review cycle.
- User migration — Whether Vietnamese traders actually move from offshore platforms to domestic exchanges, or find ways to continue trading overseas.
The Bigger Picture: A $200 Billion Bet on Sovereignty
At its core, Vietnam’s strategy is a bet on sovereignty over market efficiency.
By channelling $200 billion in annual crypto volume through licensed, transparent, domestically supervised intermediaries, Hanoi is prioritising regulatory control, tax revenue, capital flow management, and international credibility over market depth, innovation speed, and user choice.
It is a calculated trade-off. The government is betting that the legitimacy of a supervised system will ultimately attract more capital — both domestic and foreign — than the opacity and legal uncertainty of the current unregulated environment. It is betting that Vietnamese traders, given a legal and transparent alternative, will choose compliance over the risks of operating in a prohibited offshore market.
Whether that bet pays off will depend on execution. Vietnam’s crypto licensing framework is among the most ambitious and demanding in the world. If the five qualifying firms can build exchanges that are liquid, secure, and user-friendly enough to compete with the global platforms they are meant to replace, Hanoi’s experiment could become a model for emerging markets grappling with the same challenges.
If they can’t, the $200 billion in annual volume may simply migrate to darker corners of the internet — regulated on paper, ungovernable in practice.
The race is on. And for the first time, Vietnam’s crypto market has rules.
This article is for informational purposes only and does not constitute financial or legal advice. Always conduct your own research before making investment decisions.
