Commercial Banks Providing Crypto-Related Services: The Permitted Boundary During the Pilot Phase

Commercial banks are the indispensable fiat infrastructure of the crypto-asset market: every dong entering or leaving an exchange passes through a bank account. But the legal boundary for banks during the pilot phase is clear: banks serve the money flows and customers of the ecosystem — they do not themselves become crypto-asset businesses.

Governing Instruments

The permitted part: banks as the fiat infrastructure of the pilot market

In the design of the Resolution 05/2025 pilot framework, crypto-asset trading at licensed organisations is settled in fiat money through the banking system. Commercial banks may and must therefore provide ordinary banking services to this ecosystem: opening dong and foreign currency payment accounts for licensed service organisations and their clients; executing deposit and withdrawal orders between client accounts and the service organisation accounts; and providing ordinary corporate banking services (credit, guarantees, foreign exchange, cash management) to ecosystem enterprises under current credit and FX rules, provided the credit is not structured on crypto assets as a separate permitted business line.

A second participation channel is the controlled testing mechanism in the banking sector under Decree 94/2025/ND-CP: credit institutions approved by the State Bank test fintech solutions within a defined scope, term and supervisory conditions. If a bank wishes to pilot a digital-asset-related solution — for example distributed-ledger customer verification, or payments supporting trading at the pilot market — the lawful route is a proposal inside this testing mechanism, not self-deployment as a regular business line.

The prohibited boundary: no dealing, no issuance, no crypto custody by banks

The Law on Credit Institutions 32/2024/QH15 defines banking activities as deposit taking, credit extension and provision of payment services via accounts; crypto assets belong to none of these business groups. Consequently a commercial bank may not buy, sell or deal in crypto assets with its own funds as a business line; may not issue tokens or crypto-based products to clients outside products permitted by the State Bank; and may not use mobilised public deposits to invest in crypto assets. A crypto asset is also not money and not a lawful payment instrument in Vietnam — a bank may not accept it as a payment instrument within its payment system.

On custody: the custody business a bank may perform is securities custody under securities law, applying to securities — an asset class entirely different in legal nature. Crypto-asset custody (holding private keys, administering wallets for platforms and clients) is not within the licensed business catalogue of banks during the pilot phase; at a crypto-asset service organisation, the custody function belongs to that organisation itself under the licensing conditions of the pilot framework. Banks hold only the fiat part: the platform and client accounts, including accounts serving client money segregation under the pilot market mechanism.

Application Analysis

The point where banks are scrutinised most is not the business catalogue but anti-money laundering. Under the Law on Anti-Money Laundering 14/2022/QH15, credit institutions are reporting entities: they must identify customers, assess risk, monitor transactions and report suspicious transactions to the anti-money laundering authority. Crypto-related money flows are classed by banks as a high-risk group in internal policy: high-frequency large deposits and withdrawals, money coming from or going to unlicensed platforms, and customers unable to explain the source of funds are all enhanced-diligence triggers. A bank may refuse to open accounts or terminate the relationship with a client serving an off-framework platform — and in practice this is the most effective control tool over the unlicensed market.

For a bank wanting to position ahead of the market, the lawful strategy has three steps: building a dedicated risk policy for clients that are organisations licensed within the pilot framework (clearly distinguished from unlicensed platforms); preparing transaction-monitoring infrastructure able to connect with pilot market data when the information-sharing mechanism is set up; and piloting new products only through the Decree 94/2025 controlled testing mechanism with State Bank approval. A bank that moves first on compliance infrastructure will be the bank chosen when the pilot market truly operates, without touching the prohibited business part.

Recommended Actions

Classify crypto-ecosystem clients in internal policy: organisations licensed within the pilot framework and off-framework platforms — two groups, two different service regimes.
Keep services within the ordinary banking business catalogue (accounts, payments, corporate credit under general rules); no dealing, issuance or custody of crypto assets.
Apply enhanced diligence to crypto-related money flows under the Law on Anti-Money Laundering 14/2022: source of funds, purpose, platform counterparty.
Route every new digital-asset-related product through the Decree 94/2025 controlled testing mechanism with State Bank approval before deployment.

Frequently Asked Questions

What crypto-asset-related services may a commercial bank provide during the pilot phase?

Ordinary banking services serving the fiat flows of the pilot market: opening dong and foreign currency payment accounts for licensed crypto-asset service organisations and their clients; executing deposit and withdrawal payments between clients and licensed organisations; and providing corporate banking services (credit, guarantees, foreign exchange, cash management) to ecosystem enterprises under current rules. A bank may also propose piloting a digital-asset-related technology solution within the Decree 94/2025 controlled testing mechanism when approved by the State Bank.

May a bank open accounts and provide custody for a crypto-asset platform?

Account opening, yes — that is core business: dong and foreign currency accounts for a licensed service organisation, including accounts serving client money segregation under the pilot market mechanism. Crypto-asset custody is not a bank business during the pilot phase: bank custody business is securities custody under securities law, while holding crypto assets and private keys for a platform belongs to the service organisation itself under the licensing conditions of the pilot framework. Banks hold the fiat part, not the digital assets.

What is the boundary of what a bank may not do with crypto assets under current rules?

Three prohibitions: (1) no dealing — no buying or selling crypto assets with bank funds as a business line, because banking activities under the Law on Credit Institutions 32/2024 comprise only deposit taking, credit extension and payment services; (2) no issuing tokens or crypto-based products to clients outside State-Bank-permitted products, and no using mobilised deposits to invest in crypto assets; (3) no accepting crypto assets as a payment instrument — they are not money and not a lawful payment instrument in Vietnam. Serving unlicensed platforms is also outside the boundary due to legal and money-laundering risk.

How are crypto-asset transactions through bank accounts controlled for anti-money laundering?

Under the Law on Anti-Money Laundering 14/2022/QH15, banks are reporting entities: they must identify and risk-assess customers, monitor transactions and report suspicious transactions. Crypto-related flows are usually classed high-risk in bank internal policy: large-value or abnormal-frequency deposits and withdrawals, transactions with unlicensed platforms, and customers unable to explain the source of funds trigger enhanced diligence, additional document requests, and — where matters cannot be clarified — the bank may restrict or terminate the transaction relationship. Clients trading through organisations licensed within the pilot framework with a clear source-of-funds file pass this process far more smoothly.

This article has been quality-reviewed by the FLAW AI Legal Council