Context: eKYC has moved from a convenience feature to compliance infrastructure: the new rules widen remote account opening while tightening biometric anti-spoofing, because criminals have also upgraded from stolen photos to deepfake videos.
Reading the Framework from the Source Texts
The base electronic-identification framework comprises Decree 69/2024/ND-CP on electronic identification and authentication (effective 1 July 2024) operating on the national VNeID identification system, the Anti-Money Laundering Law 14/2022/QH15 on customer-identification duties, and State Bank rules on opening accounts by electronic means. Since 1 July 2024, Decision 2345/QD-NHNN requires biometric authentication matched against the chip-ID database for covered online transactions (high-value transactions, first activation on a new device) — biometrics is thereby a mandatory layer of banking eKYC architecture, no longer each bank’s choice.
The current expansion problem lies with two edge customer groups. The first is foreigners: with no data in Vietnam’s population database, their eKYC must rest on chip passports, verification via electronic-passport data reading and visa and entry-exit information matching — some banks still require a supplementary counter confirmation step for full limits. The second is FDI companies opening accounts remotely: the entity is verified via enterprise registration, while the foreign representative is verified under the first group’s mechanism, and the combination of the two layers decides whether the bank allows fully remote opening or stops at initiation. Biometric anti-spoofing (liveness detection, deepfake and presentation-attack detection) has become a criterion in appraising eKYC vendors, because a weak face-recognition system turns eKYC from an AML tool into its gateway.
Practical Points Commonly Overlooked
An FDI company choosing a bank for account opening should ask two direct questions before signing any balance commitment: does the bank have a dedicated process for a foreign representative with no population data, and what is the initial transaction limit during supplementary verification. These two answers decide a newly established company’s first-month cash-flow plan more realistically than any fee table.
Concrete Steps for Those Involved
The steps below turn the analysis above into concrete work:
- First, test your own situation against this ground: The base electronic-identification framework comprises Decree 69/2024/ND-CP on electronic identification and authentication (effective 1 July 2024) operating on the national VNeID identification system, the Anti-Money Laundering Law 14/2022/QH15 on customer-identification duties, and State Bank rules on opening accounts by electronic means.
- Record the application point specific to this case instead of copying conclusions from another case: The current expansion problem lies with two edge customer groups.
- Prepare the evidence and file relating to the following point before dealing with authorities or partners: An FDI company choosing a bank for account opening should ask two direct questions before signing any balance commitment: does the bank have a dedicated process for a foreign representative with no population data, and what is the initial transaction limit during supplementary verification. These two answers decide a newly established company’s first-month cash-flow plan more realistically than any fee table.
- Answer the question clients ask most directly with this conclusion, and keep it on file: Core conditions: the customer’s biometric data can be matched against the chip-ID database or valid identification documents, the system meets anti-spoofing requirements, and the bank completes customer-identification duties under AML Law 14/2022/QH15. Transactions covered by Decision 2345/QD-NHNN must pass the corresponding biometric layer.
Frequently Asked Questions
What are the conditions for applying eKYC?
Core conditions: the customer’s biometric data can be matched against the chip-ID database or valid identification documents, the system meets anti-spoofing requirements, and the bank completes customer-identification duties under AML Law 14/2022/QH15. Transactions covered by Decision 2345/QD-NHNN must pass the corresponding biometric layer.
Can an FDI company open an account remotely?
It can be initiated and, at many banks, completed remotely, provided the entity verifies via enterprise registration and the representative verifies identity. The usual bottleneck is a foreign representative with no population data — the bank then applies the passport mechanism and may limit limits until supplementary verification completes.
How is biometric spoofing prevented?
Through liveness detection, presentation-attack and deepfake detection, plus data matching against the national identification database under Decree 69/2024/ND-CP. On governance, the bank must appraise eKYC vendors periodically — a weak anti-spoofing system is the bank’s own compliance risk, not merely a technical one.
eKYC for foreigners with passports?
Foreigners use a passport (preferably chip passports for electronic data reading) combined with visa and entry-exit information. Because Vietnam’s population database cannot be matched, the process usually adds a bank confirmation step and prudent initial limits — a structural difference from citizen eKYC, not arbitrary discrimination.
This article has been quality-reviewed by the FLAW AI Legal Council