Large Cash Transaction Reporting Duties for FDI Enterprises Under Vietnam's AML Law

When an FDI enterprise deposits or withdraws cash of VND 400 million at a bank, who must report the transaction? The answer surprises many businesses: not the enterprise, but the bank. This article corrects a common misunderstanding — shifting the lens from “must report” to “gets reported” — and guides FDI enterprises on what to prepare when their transactions are reported.

1. Who reports, and what is reported?

1.1. The reporting entity: the bank, not the enterprise

Under Article 4 of the Law on Anti-Money Laundering 14/2022/QH15 (in force), reporting entities include credit institutions, foreign bank branches and certain designated non-financial businesses and professions (DNFBPs). When an FDI enterprise conducts a cash transaction of VND 400,000,000 or more, the bank — as the reporting entity — must report it to the Anti-Money Laundering Department (State Bank of Vietnam).

In other words: the enterprise is the subject of the reported transaction; the bank is the party performing the reporting duty under Article 25 of Law 14/2022.

1.2. The VND 400 million cash threshold

The reportable threshold for cash transactions is VND 400,000,000 per Decision 11/2023/QD-TTg (in force). The threshold applies per cash deposit/withdrawal transaction — note that for foreign currency, sectoral guidance counts cash deposits (including cash foreign currency deposited to buy VND), not every foreign-exchange transaction.

1.3. New wire-transfer thresholds: VND 500 million / USD 1,000

Circular 27/2025/TT-NHNN (effective 1 November 2025) sets wire-transfer reporting thresholds in Article 9: VND 500 million or more for domestic transfers and USD 1,000 or more (or equivalent in other currencies) for international transfers. The large-value reporting regime — including ATM/CDM transactions — is set out in Article 6 of this Circular.

1.4. Suspicious transactions: no threshold

Under Article 26 of Law 14/2022, transactions showing suspicious signs must be reported regardless of value. A VND 50 million transaction with red flags must be reported, while a normal VND 500 million transaction is reported only under the large-value threshold.

1.5. Reporting deadlines

Under Article 37 of Law 14/2022: electronic reports within 1 working day; paper reports within 2 working days of the transaction date.

2. What should an FDI enterprise do when its transaction is reported?

2.1. Cooperate on customer identification (KYC)

Banks must know their customers. FDI enterprises should provide fully and promptly: the enterprise’s legal documents, information on the legal representative, authorised representatives and the beneficial owner. Outdated KYC files are a common reason transactions get held for additional verification.

2.2. Prepare source-of-funds documentation

For large cash transactions, proactively prepare: contracts, invoices and vouchers proving the fund source; profit distribution decisions, loan contracts (for borrowed funds); customs declarations (for import/export-related funds). Banks may refuse or suspend transactions showing suspicious signs that cannot be clarified.

2.3. Note on depositing foreign currency to buy VND

Under sectoral guidance, the reporting duty applies to cash deposits (including cash foreign currency deposited to purchase VND). FDI enterprises routinely depositing cash foreign currency should watch the VND 400 million equivalent threshold and keep source documents ready.

3. When the FDI enterprise itself is a reporting entity

An FDI enterprise is not always merely “reported on”. Under Article 4 of Law 14/2022, certain businesses are direct reporting entities, including:

Real estate businesses;
Precious metals and gemstone traders;
Providers of accounting, notarization and lawyer services (within the prescribed scope).

These must adopt internal AML regulations and complete an electronic reporting system — required to be completed from 1 January 2026. FDI enterprises in these sectors should check their compliance status immediately.

4. Context: FATF and the tightening trend

As the Financial Action Task Force (FATF) intensifies regional monitoring, Vietnam is tightening AML enforcement. The trend is clear: more granular thresholds (as in Circular 27/2025), digitised reporting, and heavier reporting-entity responsibilities. FDI enterprises should treat AML compliance as ongoing risk management, not a reactive formality.

Breaches of monetary and banking obligations may draw administrative sanctions under Decree 88/2019/ND-CP (specific fines apply per violation as prescribed in the Decree).

5. Frequently asked questions

Can sub-threshold transactions ever be reported?

Yes — transactions showing suspicious signs under Article 26 of Law 14/2022 must be reported regardless of value.

Will the enterprise know its transaction was reported?

Reporting entities are strictly prohibited from disclosing that a report was made (the “tipping-off” principle). Enterprises only sense it indirectly when banks request additional information or documents.

Can transactions be split to avoid the threshold?

No. Structuring transactions to evade reporting thresholds is itself a classic suspicious indicator and may draw more scrutiny.

6. Conclusion

In short: for cash transactions of VND 400 million, the bank reports — the enterprise cooperates. For wire transfers, remember the new VND 500 million / USD 1,000 thresholds from 1 November 2025. And never forget: suspicious transactions have no threshold. Keeping KYC files and source-of-funds documents ready is the only way to move large transactions through the bank smoothly.

If your FDI enterprise needs an AML compliance review, contact FLAT Law Firm for advice.

This article has been reviewed by the QA Council.

Transparency note: this article was prepared by the FLAW AI Legal Council based on legislation in force at the time of writing (14 October 2026). It is for general information only, is not an official legal text, and does not replace legal advice for your specific case. Specific fines apply per violation under Decree 88/2019/ND-CP.