Remittance Compliance Vietnam: Why a Licensed Payout Partner Matters

For international money transfer operators (MTOs), remittance compliance with Vietnamese requirements should come before fees and speed when choosing a local partner. Every transfer passes through at least two legal regimes: Vietnam's foreign exchange rules and international anti-money laundering standards. Both have tightened since 2023. This guide summarizes the current legal framework, anti-money laundering obligations, the new e-wallet rules, and six criteria for assessing a payout partner.

What Remittance Compliance Means and Why It Matters More in 2026

Three layers of obligations in a single remittance

Remittance compliance is the set of legal obligations a receiving and payout provider must meet. These obligations fall into three layers:

Foreign exchange rules: who may receive and pay out foreign currency, under what conditions, and through which accounts.
Anti-money laundering and counter-terrorist financing (AML/CFT): customer identification, screening, monitoring, and transaction reporting.
Payout channel rules: the specific requirements of banks, e-wallets, and cash payout networks.

A transaction is only compliant when it satisfies all three layers on both the sending and the receiving side.

Context: Vietnam is under increased FATF monitoring

The Financial Action Task Force (FATF) placed Vietnam on its list of jurisdictions under increased monitoring, commonly called the "grey list", in June 2023. Vietnam committed to address AML/CFT deficiencies under an agreed action plan. As of the June 2026 plenary, Vietnam remained on the list.

FATF stresses that the grey list is not a sanctions list. It also does not call for enhanced due diligence on a jurisdiction simply because it is grey-listed. In practice, however, international banks and financial institutions often take a closer look at transactions involving these jurisdictions. For MTOs sending money to Vietnam, this means a local payout partner must be able to demonstrate clear compliance capability.

In addition, at its June 2026 plenary, FATF launched a consultation on guidance for stronger cross-border payment transparency under Recommendation 16. Expectations on the information that travels with each transfer are likely to keep rising.

The Legal Framework for Remittance Payouts in Vietnam

Who may provide foreign currency receipt and payout services?

In Vietnam, foreign currency receipt and payout services are governed mainly by two instruments:

Decree 89/2016/ND-CP sets the conditions for business entities. It was amended by Decree 16/2019/ND-CP and Decree 23/2023/ND-CP, with a consolidated version effective from 1 July 2023.
Circular 34/2015/TT-NHNN guides the provision of these services and took effect on 1 March 2016.

These instruments distinguish two types of providers:

Credit institutions licensed for foreign exchange services. They do not need separate SBV approval to provide foreign currency receipt and payout services.
Business entities (non-bank companies). They must meet the conditions in Decree 89/2016 and obtain approval from the State Bank of Vietnam (SBV) before operating.

Direct receipt and payout vs payout agency

Business entities can operate under two models:

Direct receipt and payout: the company is approved by the SBV to contract directly with foreign partners, receive funds, and pay beneficiaries in Vietnam.
Payout agent: the company acts as a payout agent for one or more credit institutions. Under Circular 34/2015, a business entity may act as an agent for one or several credit institutions licensed for foreign exchange services.

For MTOs, this distinction shapes the contract structure. With a direct provider, the MTO contracts with that provider. With an agent, the main legal relationship sits with the credit institution the agent represents.

The scope of a foreign currency receipt and payout license

This type of license covers receiving foreign currency sent from abroad and paying it out to beneficiaries in Vietnam. It does not cover banking activities, deposit-taking, card issuance, or foreign exchange trading. When assessing a partner, MTOs should check the services the partner offers against the exact scope of its approval.

Anti-Money Laundering Obligations in Remittance Payouts

The AML legal framework

The Law on Anti-Money Laundering No. 14/2022/QH15 took effect on 1 March 2023. The main implementing instruments are:

Decree 19/2023/ND-CP, which details several articles of the Law.
SBV guidance circulars. Circular 27/2025/TT-NHNN, issued on 15 September 2025 and effective from 1 November 2025, replaces Circular 09/2023/TT-NHNN.

Identification and information accompanying each transfer

A payout provider must identify the beneficiary and match their details against the information in the transfer instruction. Under the implementing rules, an originating financial institution may only execute an electronic funds transfer when the instruction carries complete and accurate information as required. For remittances, this means the MTO and the payout partner need to agree upfront on the mandatory data fields for each instruction.

Reporting thresholds

Three reporting thresholds matter most for remittance payout providers:

Large-value transactions: under Decision 11/2023/QĐ-TTg, transactions of VND 400 million or more must be reported to the SBV from 1 December 2023.
Domestic electronic funds transfers: transfers of VND 500 million or more are reportable.
International electronic funds transfers: transfers of USD 1,000 or more, or the equivalent in another currency, must also be reported.

Electronic funds transfer reports must be submitted before 4 p.m. on the working day after the transaction. The USD 1,000 threshold sits below the value of many remittances, so automated reporting capability is a core requirement rather than an extra feature.

Suspicious transactions and list screening

Beyond threshold reporting, payout providers must identify and report suspicious transactions. They must also screen senders and recipients against terrorism and terrorist-financing blacklists. When a reporting entity detects a party on these lists, it must promptly report to the competent anti-terrorism authorities and to the SBV.

E-Wallet Rules for 2025–2026 That Affect Remittance Payouts

Payouts into e-wallets must also meet wallet-specific rules. Circular 41/2025/TT-NHNN, which amends Circular 40/2024/TT-NHNN and took effect on 5 November 2025, introduced several notable requirements:

Stronger identity verification for wallet users, including biometric verification when opening a wallet.
Minimum information in each transfer. In transfers between wallets, or between a wallet and a bank account, the sender's provider must pass minimum information to the recipient's provider.
No cash top-ups or withdrawals. E-wallets may not accept cash to top up a wallet or let customers withdraw cash.

For remittance payouts, these rules require the recipient's name in the instruction to match the identity data on the wallet. Payout providers also need a fallback to a bank account or a cash channel when a wallet payout cannot be completed.

Six Criteria for Assessing a Remittance Payout Partner in Vietnam

1. SBV approval with the right scope

Ask the partner for its SBV license or approval number, the issue date, and any renewal decisions. Check whether the approval covers direct receipt and payout or payout agency. Compare the services the partner offers against that scope.

2. A documented AML/CFT program

The partner should have written internal procedures for customer identification (KYC), business verification (KYB), list screening, transaction monitoring, and risk assessment. Ask who is responsible for compliance and how often the procedures are reviewed.

3. Reporting capability that meets thresholds and deadlines

With a USD 1,000 threshold for international electronic funds transfers and a next-working-day deadline, the partner needs automated reporting systems. Manual reporting cannot keep up with remittance volumes.

4. Reconciliation and record-keeping

The partner should provide standardized reconciliation data across all payout channels and keep transaction and identification records for the legally required period. MTOs need this data when regulators in the sending country request explanations.

5. A payout network built on licensed providers

Every payout channel, whether a bank, e-wallet, post office, or ATM network, should run through a provider holding the relevant license. Ask the partner to describe each party's role in the payout chain.

6. Transparent fees, exchange rates, and personal data handling

The partner should disclose its fee structure and how exchange rates are determined. It should also handle recipients' personal data in line with Vietnam's personal data protection laws, especially when data is shared among several parties.

How FinFan Approaches Remittance Compliance

FinFan is the commercial brand of Nhat Phuong Joint Stock Company (Best Way Corporation), founded in 2007. On 4 July 2014, the company was licensed by the State Bank of Vietnam for direct foreign currency acceptance and payment under License No. 973/GP-HCM. The license has been renewed twice: under Decision No. 49/QĐ-HCM dated 10 January 2017 and under Decision No. 21/QĐ-HCM dated 10 January 2022, which is currently in effect. In July 2026, FinFan marked 12 years of operating under this license.

"Compliance First" is FinFan's first core value. SBV licensing and AML/KYC standards are the foundation of every product, and the company does not trade compliance for growth. In day-to-day operations, this shows in three ways:

The right model: FinFan operates under the direct receipt and payout model, and MTO partners contract with FinFan directly.
Payouts through licensed providers: FinFan receives and coordinates payouts. Partner banks, e-wallets, and cash payout networks carry out the payout to beneficiaries.
Full AML/KYC processes for both remittance payouts and mass disbursement.

FinFan is currently the payout partner in Vietnam for more than 30 international MTOs, including MoneyGram and Remitly, across a network covering more than 150 countries.

Conclusion

Remittance compliance in Vietnam has three layers: foreign exchange rules, anti-money laundering obligations, and the specific rules of each payout channel. All three are tightening. Vietnam remains under increased FATF monitoring, the reporting threshold for international electronic transfers starts at USD 1,000, and new e-wallet rules raised identity requirements from late 2025. For international MTOs, choosing a payout partner is not just about picking the fastest or cheapest channel. It is about choosing a provider with SBV approval of the right scope, a documented compliance program, and the operational capability to keep pace with regulatory change.

If your organization is looking for, or reviewing, a payout partner in Vietnam, the FinFan team can share information on our license, compliance processes, and integration documentation to support your due diligence. Contact FinFan today so our team will guide you to fast, secure financial solutions.

Website: https://finfan.io
Email: support@finfan.vn
Phone: +84 2866.853.317

Disclaimer

FinFan is the commercial brand of Nhat Phuong Joint Stock Company (Best Way Corporation), licensed by the State Bank of Vietnam for foreign currency acceptance and payment under License No. 973/GP-HCM. FinFan provides the technology platform; partner banks in Vietnam handle collection and foreign currency conversion. FinFan is not a bank and does not provide deposit services.

This content is general information and does not constitute legal advice. Regulatory information reflects the position at the time of writing and may change. Please consult a legal adviser about your organization's specific situation.

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