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In brief

On 15 November 2022, the National Assembly of Vietnam passed the new law on anti-money laundering (“New Law“), which will replace the Current Law[1] from 1 March 2023. Reporting entities as covered in the New Law should take into account certain key changes in anti-money laundering (AML) regulations.

Key takeaways

As a high-level comment, the amendments and supplementations made under the New Law are to implement the recommendations of the Financial Action Task Force (FATF). The New Law also finally excludes the regulations on peer-to-peer lending platform providers and virtual asset service providers, as introduced in the draft version. Nonetheless, the New Law mentions that the government, after being approved by the Standing Committee of the National Assembly, will provide regulations for any emerging/new activities that the reporting entities consider as posing a threat of money laundering and which are not yet covered under the New Law.

In particular, the New Law covers significant changes to the following:

  • The scope of reporting entities
  • New requirement on national money-laundering risk assessment and money-laundering risk assessment by the reporting entities
  • AML measures
  • Reporting high-value transactions, suspicious transactions and suspicious signs
  • Time limit for reporting
  • Obligation to retain customer’ data
  • State authorities’ responsibilities in preventing and combating money laundering

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[1] Law No. 07/2012/QH13 on Anti-Money Laundering passed by the National Assembly on 18 June 2012 (“Current Law“).


Oanh Nguyen is a partner in Baker McKenzie Vietnam and has been practising capital markets, banking and finance, M&A, and commercial law for more than 25 years. Knowledgeable about all aspects of investments, she advises on all types of transactions, ranging from investment structures to project structures and their related financing. She has focused on public M&A matters, including major IPOs and projects finance.

Oanh is a respected presenter in the areas of finance and capital markets. In addition, she has lectured at the Ho Chi Minh City Bar Association. She also serves as a legal advisor to the Capital Market Committee of Ho Chi Minh City American Chamber of Commerce.


Thuy Van Pham is a special counsel at the Firm's Ho Chi Minh City office with more than 10 years of experience advising on investment, banking and finance in Vietnam. She has been involved in many transactions, including cross-border financing deals and M&A transactions in Vietnam across a wide range of industries, including banking and finance, insurance and securities, manufacturing, oil and gas, real estate, telecommunications. Van has also been advising major banks in Vietnam on regulatory issues for their daily operations.

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