Vietnam's government issued Decree No. 284/2026/ND-CP on 16 July 2026, establishing an administrative penalty regime for violations of laws governing crypto asset markets. The decree takes effect on 1 September 2026 and will remain in force for the duration of the five-year crypto asset pilot programme under Resolution No. 05/2025/NQ-QH, scheduled to run until September 2030. The Ministry of Finance is the designated licensing authority for domestic crypto asset service providers under the pilot programme.
Decree No. 284/2026/ND-CP sets fines across a graduated scale. Individuals trading crypto assets through providers not licensed by the Ministry of Finance face fines up to VND 50 million (approximately USD 1,900). Trading assets designated for foreign investors only carries fines up to VND 100 million (approximately USD 3,800). Providers failing to conduct customer identity verification face fines up to VND 70 million. Unauthorised crypto asset offerings and material anti-money laundering failures carry fines up to VND 200 million (approximately USD 7,700). The decree imposes liability on both individual end users and operating entities.
Offshore crypto asset exchanges serving Vietnamese retail customers face direct compliance exposure under the decree. The decree shifts enforcement from platform-level obligations alone to end users of unlicensed platforms, imposing per-transaction fine risk on Vietnamese retail investors who continue using exchanges not licensed by the Ministry of Finance. International exchanges without Ministry of Finance licences face a choice between seeking domestic licensing or implementing effective geoblocking for Vietnamese-resident users. The previous enforcement regime targeted platforms; the new decree makes users financially liable for trading on unlicensed exchanges.
The decree operates alongside the crypto asset pilot programme under Resolution No. 05/2025/NQ-QH, which designates the Ministry of Finance as the sole domestic licensing authority. No safe harbour applies to offshore exchanges that restrict Vietnamese-resident access in their terms of service but permit account registration with Vietnamese identity documents. The decree does not expressly address decentralised protocols or non-custodial wallet interactions, leaving enforcement focused primarily on centralised exchange operations and their users.
We advise crypto asset firms on regulatory exposure in Vietnamese and regional Southeast Asian markets and may assist through our partner network. Contact us for Decree No. 284/2026/ND-CP compliance analysis, Vietnamese market access strategy, or geoblocking and licensing assessments for offshore exchange operators. Work we undertake includes Southeast Asian crypto regulatory analysis, market access advisory, anti-money laundering compliance reviews, and regulatory mapping for exchange operators across the region.
Source: Tilleke & Gibbins / Mondaq, Vietnam's New Crypto Sanctions to Impact Offshore Exchanges, July 2026