Not every company must report suspicious transactions — and not every large transaction must be reported. This article covers the legal duties of companies as “reporting entities” in anti-money laundering: when to report to the State Bank of Vietnam, plus the two related reporting duties (large-value transactions, electronic fund transfers). This is the administrative–preventive angle, distinct from the crime of money laundering (Article 324 of the Penal Code).
1. Legal framework: cite the version in force
- Law on Anti-Money Laundering 14/2022/QH15 (effective 1 March 2023) — in force; the cited text in this article;
- Law 23/2026/QH16 (amending several articles of the Law on the State Bank, the Law on Anti-Money Laundering and the Law on Credit Institutions) — effective 1 December 2026, not yet in force. Its amendments (amending Article 26 on suspicious-transaction reporting; adding suspicious signs in the crypto-asset sector; adding crypto-asset service providers to reporting entities) are noted only as “upcoming”, not applied early;
- Circular 27/2025/TT-NHNN (15 September 2025, effective 1 November 2025) — guiding the reporting regime, replacing Circular 09/2023/TT-NHNN. Do not cite Circular 09/2023 as a text still in force;
- Decree 340/2025/ND-CP (25 December 2025, effective 9 February 2026) — administrative sanctions in the monetary and banking sector, replacing Decrees 88/2019/ND-CP and 143/2021/ND-CP. Do not cite Decree 88/2019;
- Decision 11/2023/QD-TTg (large-value threshold), Decree 19/2023/ND-CP (guiding the Law).
2. Who is a “reporting entity”? — not every company
Under Article 4 of Law 14/2022, reporting entities comprise financial institutions and organisations and individuals conducting relevant non-financial businesses and professions, including:
- Prize-winning gaming businesses;
- Real estate businesses (excluding leasing, sub-leasing and real estate consultancy services);
- Precious metals and gemstones businesses;
- Accounting, notarisation and legal services (lawyers, law-practising organisations);
- Company formation, management and administration services…
The boundary must be stated up front: not every company has a duty to report suspicious transactions — only the entities listed in Article 4. An ordinary manufacturing company outside the list is not a reporting entity under this Law.
3. Three reporting duties (kept distinct, not merged)
3.1. Large-value transactions (Article 25)
Large-value threshold: VND 400 million or more (Decision 11/2023/QD-TTg, applicable from 1 December 2023).
3.2. Suspicious transactions (Article 26) — the focus
Reporting entities report to the State Bank of Vietnam where:
- They know the transaction is carried out at the request of a criminal suspect, defendant or convicted person and have reasonable grounds to suspect the assets are owned or controlled by them;
- They have reasonable grounds to suspect the assets are linked to money laundering — determined through the suspicious signs in Articles 27, 28, 29, 30, 31, 32 and 33 (Article 33 covers suspicious signs in the real estate business sector) and other signs identified by the reporting entity itself.
The detailed reporting regime follows Circular 27/2025/TT-NHNN (not Circular 09/2023).
3.3. Electronic fund transfers (Article 34)
Threshold for reporting to the Anti-Money Laundering Department: domestic transfers of VND 500 million or more (verified under Circular 27/2025). Thresholds for cross-border transfers must be cross-checked against Circular 27/2025 before application.
4. Reporting deadlines (Article 37)
- Large-value and electronic fund transfer transactions: 01 working day (electronic reporting) or 02 working days (paper reporting) from the transaction date;
- Suspicious transactions: 03 working days from the transaction date or 01 working day from the date of detection;
- Where signs of a crime are detected: report to the competent state authority and the State Bank of Vietnam within 24 hours.
5. Sanctions for failure to report
Breaches of reporting duties are subject to administrative sanctions in the monetary and banking sector under Decree 340/2025/ND-CP (effective 9 February 2026; replacing Decrees 88/2019 and 143/2021); fines for organisations are double those for individuals (Article 5 of Decree 340). Specific fine levels for each act must be cross-checked against the verbatim Decree.
6. Confidentiality duty and interim measures
- Confidentiality: reporting entities and related persons must not disclose that a report has been made to the State Bank of Vietnam;
- Interim measures (brief note — Articles 44 and 45 of Law 14/2022): delaying transactions, freezing accounts, sealing and temporarily seizing assets in cases prescribed by law.
On customer due diligence in M&A transactions (KYC), see: Anti-money laundering: KYC duties in M&A.
Reference information only — not legal advice. Companies that are reporting entities should review their internal procedures to meet reporting deadlines and confidentiality duties under the Law on Anti-Money Laundering.
For reference only, not legal advice. Content quality-checked by the AI Legal Council; not yet reviewed by a human lawyer.