Viet Nam introduces special mechanisms to strengthen anti-money laundering framework

Resolution No. 66.23/2026/NQ-CP, issued on July 24, amends and supplements a number of provisions of the 2022 Law on Anti-Money Laundering and related guiding documents regarding the identification of beneficial ownership, customer due diligence, transparency of legal arrangements, risk-based customer classification, and the frequency of updating customer information.

Under the resolution, reporting entities shall be required to collect additional customer information in specified cases. For customers participating in trust arrangements or similar legal structures, reporting entities must obtain information on all parties performing roles equivalent to those in trust arrangements.

In the life insurance sector, reporting entities must collect beneficiary information once beneficiaries are designated by the policyholder or the insured.

The resolution also strengthens transparency requirements for legal arrangements. Trustees and persons performing equivalent roles are required to collect, update and maintain information on all relevant parties and retain such information for at least five years after they cease participating in the legal arrangement.

The State Bank of Viet Nam and competent law enforcement agencies shall be authorized to request access to such information for anti-money laundering purposes and criminal investigations.

The revised regulations further clarify the criteria for identifying beneficial owners of individuals, organizations, foreign-established funds, legal arrangements and life insurance contracts.

For corporate customers, a beneficial owner is generally defined as an individual who directly or indirectly owns at least 25 percent of charter capital or voting shares, or who ultimately exercises control through other legal or practical means. Where no such individual can be identified, the person holding the highest executive authority may be recognized as the beneficial owner, except in cases involving representatives of State capital.

According to the Government, the temporary special mechanisms are intended to ensure the timely implementation of Viet Nam's international obligations while amendments to the relevant laws, decrees and circulars are being finalized.

The resolution takes effect on July 24, 2026, and remains valid until February 28, 2027, or until the amended legal documents take effect, whichever comes first.

During its validity period, the resolution shall prevail over any conflicting provisions in other legal documents. Information and records lawfully collected, verified and retained under previous regulations will remain legally valid and continue to be used in accordance with the law./.