On 30 October 2026, the State Bank of Vietnam issued Circular No. 57/2026/TT-NHNN prescribing the procedures for supervising anti-money laundering activities in the monetary and banking sector (“Circular 57”), taking effect on 1 December 2026 and applies to reporting entities under the Law on Anti-Money Laundering that fall within the scope of the State Bank of Vietnam’s state management responsibilities in the monetary and banking sector.
Circular 57 establishes a supervisory framework combining compliance-based supervision and risk-based supervision, thereby clarifying the process for collecting information, assessing risk levels and proposing supervisory measures applicable to entities within its scope. Where an enterprise falls within the category of supervised entities under Circular 57, it is advisable to proactively review its compliance with anti-money laundering regulations and prepare relevant records, information and data for the State Bank of Vietnam’s supervisory activities. In particular, enterprises should pay attention to maintaining risk control mechanisms and ensuring their ability to provide information and explanations upon request by the competent authorities.
- Combination of Compliance-Based Supervision and Risk-Based Supervision
One of the notable provisions of Circular 57 is the combination of two supervisory methods: compliance-based supervision and risk-based supervision. Supervisory activities are conducted in accordance with the characteristics and risk levels of each group of supervised entities, available resources and the practical requirements of supervision.
In addition, the State Bank of Vietnam combines off-site supervision with on-site inspections and examinations, while strengthening coordination and information sharing between supervisory units and units responsible for inspection and examination when formulating and implementing annual inspection and examination plans on anti-money laundering.
Accordingly, supervisory activities are carried out through the following three steps:
- Step 1: Collecting, consolidating and processing documents, information and data;
- Step 2: Conducting compliance-based supervision and risk-based supervision;
- Step 3: Preparing supervisory reports and proposing supervisory measures.
- Contents of Compliance-Based Supervision
In conducting compliance-based supervision, the supervisory unit reviews, monitors, evaluates, analyses and assesses the supervised entity’s compliance with anti-money laundering regulations, focusing on the following matters:
- Information and reporting obligations: Compliance with information and reporting requirements under Articles 15, 25, 26, 34, 36 and 37 of the Law on Anti-Money Laundering and relevant implementing and guiding regulations;
- Internal regulations: The formulation and implementation of internal regulations on anti-money laundering in accordance with Article 24 of the Law on Anti-Money Laundering and relevant implementing regulations;
- Compliance with requests from state authorities: Compliance with directions and requests concerning anti-money laundering issued by competent state authorities to the supervised entity (if any).
- Assessment, Scoring and Classification of Money Laundering Risk Levels
With respect to risk-based supervision, Circular 57 provides for the assessment of the supervised entity’s money laundering risk level based on three groups of criteria:
First, structural risk: This is assessed based on the scale of operations and organisational structure of the supervised entity. The information considered includes operating licences, total assets, management structure, domestic and overseas operating networks, and information on the parent bank of a foreign bank branch, parent companies and subsidiaries (if any).
Second, inherent risk: This is assessed based on four factors: customers; products and services provided to customers; distribution channels for products and services; and geographical areas.
Third, money laundering risk control and prevention mechanisms: These are assessed through the entity’s governance and management practices, as well as the formulation and implementation of anti-money laundering policies and internal regulations. The information considered includes:
- The assignment and allocation of personnel responsible for anti-money laundering activities;
- The annual assessment and updating of money laundering risks, and the formulation and issuance of money laundering risk control policies;
- Transaction monitoring procedures and suspicious transaction reporting mechanisms;
- Anti-money laundering training and professional development activities;
- Internal control and internal audit activities relating to anti-money laundering, and the monitoring and remediation of audit findings (if any).
Periodically, the supervisory unit requests and guides supervised entities in providing documents, information and data for the assessment, analysis, scoring and classification of money laundering risk levels. Scoring is conducted in accordance with the assessment criteria, methodology and risk-scoring tools determined by the Governor of the State Bank of Vietnam for each group of supervised entities from time to time.
Based on the results of the assessment and classification of money laundering risk levels, the supervisory unit reports to the Governor of the State Bank of Vietnam for consideration of supervisory resource allocation and the proposal of supervisory measures corresponding to the identified risk levels.
In addition, the supervisory unit combines the assessment results with available documents, information and data, as well as other sources of information (if any), to determine the entities subject to supervision and the frequency, content and scope of supervision and inspection. These results also serve as a basis for developing periodic or ad hoc inspection plans.
