VCI Legal – Juy 30, 2026

The Government of Vietnam has promulgated Decree No. 284/2026/ND-CP, establishing the administrative sanctions applicable to violations involving crypto assets and the crypto asset market. The Decree provides a comprehensive enforcement framework governing the issuance, trading, and provision of crypto asset-related services under the pilot regulatory regime introduced by Resolution No. 05/2025/NQ-CP.

Under the Decree, a crypto asset is defined as a digital asset that uses cryptographic technology or other equivalent digital technologies for authentication during its creation, issuance, storage, or transfer. The definition excludes securities, digital representations of fiat currency, and other financial assets regulated under applicable civil and financial laws.

The Decree covers a broad range of administrative violations, including non-compliance with rules governing the offering and issuance of crypto assets, the operation of crypto asset trading platforms, obligations of licensed crypto asset service providers, crypto asset transactions, cross-border fund transfers by foreign investors, obstruction of inspections and investigations, unlawful handling of crypto asset account information, and violations of anti-money laundering, counter-terrorism financing, and counter-proliferation financing requirements.

The maximum administrative fine is VND 200 million for organizations and VND 100 million for individuals. Where an individual commits a violation equivalent to that of an organization, the applicable fine is equal to one-half of the fine imposed on an organization.

For violations relating to the offering and issuance of crypto assets, issuers may be subject to fines ranging from VND 150 million to VND 200 million for conducting offerings that fail to satisfy statutory conditions, targeting ineligible investors, failing to publish the required prospectus and supporting documents, or failing to comply with the disclosures made in the prospectus.

Significantly, the Decree imposes fines ranging from VND 180 million to VND 200 million on organizations that provide crypto asset-related services or advertise and market such services without obtaining the required operating licence. These sanctions represent one of the strictest enforcement measures introduced under Vietnam’s pilot crypto asset regulatory framework.

With respect to investors, domestic investors may be fined between VND 30 million and VND 50 million for conducting crypto asset transactions outside licensed crypto asset service providers authorized by the Ministry of Finance. Domestic investors trading crypto assets that are permitted to be offered exclusively to foreign investors may face fines ranging from VND 70 million to VND 100 million.

The Decree also imposes fines of VND 50 million to VND 70 million on crypto asset service providers that fail to carry out investor identity verification during the account opening process. In addition, the unauthorized collection, storage, exchange, sale, transfer, disclosure, or publication of crypto asset account data or information is subject to fines ranging from VND 150 million to VND 200 million.

Decree No. 284/2026/ND-CP will take effect on 1 September 2026 and remain effective throughout the implementation period of Resolution No. 05/2025/NQ-CP on the pilot crypto asset market.

About VCI Legal:

VCI Legal is an award-winning business law firm in Vietnam with a wide range of legal and corporate services, among other things, corporate, banking & finance, tax, labor & HR, real estate and dispute resolution with special focus on international investment disputes, We also offer our specialized type of service called “In-House Counsel Service” with the aim of assisting our clients in dealing with all types of internal and external issues arising from their day-to-day operations and business activities. With our offices in both Hanoi and Ho Chi Minh City, we have a tremendous depth of experience in providing well-reasoned and comprehensive legal advice to not only multinationals and Fortune 500 companies, but also small and medium enterprises.

Our professional team comprises one of the leading law firms in Vietnam with service quality highly recommended and acknowledged by international legal service reviewers such as: The Legal 500, AsiaLaw Profiles, IFLR, KPMG’s Tax Directors’ Handbook, Acquisition International, ACQ Global, Global Law Experts, Finance Monthly, and Chambers & Partners.

For many years, VCI Legal has been ranked among the top law firms in Vietnam for corporate, finance, insurance, taxation, employment, intellectual property and investment. With a “Can Do Attitude” combined with a “Know How” capacity, our firm is big enough to provide comprehensive legal support for any in-house legal matters, yet small enough to care about each of our clients. We undertake each engagement with the mindset of a long-term relationship, with the will to give whatever it takes to understand and fulfill your needs.

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