The design of the crypto-asset pilot market in Resolution 05/2025/NQ-CP has an unusual point that must be understood correctly: during the pilot phase, crypto-assets issued in Vietnam are offered only to foreign investors, and all transactions must be conducted in Vietnamese dong through a licensed organisation. This article clarifies what a foreign investor may buy, why this offering limit exists, through which channel purchase money flows, and under what mechanism resale and outward remittance are handled.
Applying the Rules
The purchase scope of a foreign investor in the pilot programme has two boundaries. Boundary one is the asset type: only a crypto-asset issued within the Resolution 05/2025/NQ-CP framework and listed and traded by a licensed service provider — an “in-programme” crypto-asset; tokens issued outside the programme, on a foreign exchange, do not become valid in Vietnam merely because a foreign investor buys them from Vietnam. Boundary two is buyer status: the foreign investor is the sole offering audience of the pilot phase — read correctly, foreign institutional and individual investors as defined by the programme may buy domestically issued crypto-assets, while a domestic investor (including a wealthy Vietnamese individual) is not within the offering audience for this asset type during the pilot. This is a rare “open to foreign capital, closed to domestic investors” design, arising from the programme twin goals: attracting foreign capital and technology into a controlled market, while not yet opening crypto-asset risk to domestic retail investors when the protection framework is incomplete.
An asset offered only to foreign investors differs from an ordinarily offered asset in the issuance conditions themselves: it is issued under the pilot programme conditions — attached to underlying assets permitted under Resolution 05/2025/NQ-CP, with the issuance file through a licensed service provider, and the distribution circle limited to foreign investors. The consequence is that the liquidity of these assets during the pilot exists only within the group of foreign investors trading through a licensed exchange in Vietnam: a foreign investor buying a domestically issued asset cannot assume resale to a domestic investor, and the asset price reflects a market with buyers limited by design. When the programme is legislated or its audience expanded, this scope may change — but at pilot time, a foreign investor valuation model and exit strategy must be built on the current distribution limit.
On the money channel: transactions on the pilot market are conducted in Vietnamese dong — a foreign investor remits money through a lawful banking channel into Vietnam under foreign exchange law and programme rules, converts to Vietnamese dong and trades through an account at the licensed service provider. The point an investor must lock with its bank and the exchange from the start is the cash flow file: the inward remittance order with the correct investment purpose wording, the on-exchange transaction file, and tax documents — this file set is precisely the basis for the outward flow (selling the asset, remitting money home) to be processed by the bank as a lawful investment flow when the investor exits the position. Trading in foreign currency directly on the exchange, or through money channels outside the banking system, both sit outside the programme design and break the validity proof chain of the capital flow.
Resale and outward remittance follow the logic of a permitted investment channel: the foreign investor sells the crypto-asset on the licensed exchange to another foreign investor in the programme, receives Vietnamese dong into the trading account, completes tax duties for income arising in Vietnam under tax law, then remits money abroad through the bank on the basis of a valid transaction file — the pilot programme sets no separate quantitative limit on this lawful proceeds flow beyond the general rules on foreign exchange, anti-money laundering and tax. The substantive limit is on the market side: the buyer is also only a foreign investor in the programme, so liquidity depends on the size of this investor group on the licensed exchange. An institutional investor should agree in advance with the service provider on liquidity, custody and outward remittance processes — in writing in the account opening file set — rather than handling them after holding a large position.
Legal Foundations
- Resolution 05/2025/NQ-CP of 9 September 2025 — the offering scope in the pilot: a crypto-asset created, offered and issued in Vietnam within the pilot programme is offered and issued only to foreign investors; domestic investors are not yet within the offering audience of the pilot market.
- Resolution 05/2025/NQ-CP — transaction channel and currency: a foreign investor trades crypto-assets through a service provider licensed by the Ministry of Finance in Vietnam, and transactions on the pilot market are conducted in Vietnamese dong — trading outside a licensed organisation is not within the valid framework of the programme.
- Crypto-asset issuance conditions in the pilot under Resolution 05/2025/NQ-CP: a crypto-asset is issued against underlying assets under the programme rules (not issued on the basis of securities and fiat currency as underlying assets, under the pilot prudent design) and distributed only to foreign investors through a licensed service provider.
- The foreign exchange framework for a foreign investor cash flow: investment money in and proceeds from crypto-asset transactions in the pilot must go through a lawful banking channel under foreign exchange law and programme rules, with the transaction file at the licensed organisation as the basis proving validity when remitting money abroad.
- Accompanying tax and compliance duties: a foreign investor trading on the Vietnamese market bears tax duties under Vietnamese tax law for income arising in Vietnam and anti-money laundering duties through the service provider (customer identification) like every permitted investment channel — tax details for crypto-asset transactions follow tax authority guidance at the time the market operates.
Immediate Next Steps
- Trade only crypto-assets issued within the Resolution 05/2025 framework through an organisation licensed by the Ministry of Finance — an out-of-programme asset is not within the valid scope in Vietnam.
- Build the valuation and exit model on the current distribution limit: the resale buyer is also only a foreign investor in the programme.
- Lock the cash flow file with the bank and the exchange from the start (inward remittance with the right purpose, trading in VND, tax documents) so the outward flow is processed as lawful investment capital.
- Agree in writing with the service provider on custody, liquidity and the outward remittance process before holding a large position.
Frequently Asked Questions
Which crypto-assets may a foreign investor in Vietnam buy in the pilot programme?
Only a crypto-asset created, offered and issued within the Resolution 05/2025/NQ-CP framework and traded through a service provider licensed by the Ministry of Finance: during the pilot phase, this asset type is offered and issued only to foreign investors, traded in Vietnamese dong. A crypto-asset issued outside the programme (on foreign exchanges, outside the pilot framework) is not within the valid market scope in Vietnam under this resolution, and a domestic investor is not yet within the offering audience for a programme-issued crypto-asset.
How does a crypto-asset offered only to foreign investors differ from a domestically offered asset in issuance conditions?
It differs in both issuance conditions and the distribution circle: an asset offered to foreign investors is issued under the pilot programme conditions in Resolution 05/2025/NQ-CP — attached to underlying assets permitted under the programme, effected through a licensed service provider — and distributed only to foreign investors throughout the pilot phase. The consequence is that no equivalent “domestic offering” currently exists for Vietnamese investors for this asset type; the asset liquidity forms only within the group of foreign investors trading through a licensed exchange in Vietnam.
Through which banking channel does a foreign investor transfer money to buy crypto-assets, in VND or foreign currency?
In Vietnamese dong on the pilot market, through a lawful banking channel: the foreign investor remits money into Vietnam under foreign exchange law and the rules of the Resolution 05/2025/NQ-CP programme, converts to Vietnamese dong and trades through an account at the licensed service provider. All trades on the licensed exchange are conducted in Vietnamese dong — no direct foreign currency trading on the exchange. The inward remittance file with the correct purpose together with the transaction file is the basis for the bank to process the outward flow when the investor sells the asset and remits money home.
Is a foreign investor restricted in reselling crypto-assets and remitting profits abroad?
Under the mechanism of a permitted investment channel: the investor sells the asset on the licensed exchange (the buyer is also a foreign investor in the programme), receives Vietnamese dong, completes tax duties for income arising in Vietnam, then remits money abroad through the bank on the basis of a valid transaction file — the pilot programme sets no separate quantitative limit on this lawful proceeds flow beyond the general rules on foreign exchange, anti-money laundering and tax. The substantive limit is market liquidity: the buyer group is limited to foreign investors in the programme, so the investor should agree the liquidity and remittance mechanism with the service provider in advance.
This article has been quality-reviewed by the FLAW AI Legal Council