Vietnam Strengthens Beneficial Ownership and AML Requirements

Vietnam has introduced temporary measures to strengthen its anti-money laundering (AML) framework and address legal gaps affecting the country’s international commitments on tax information exchange.

Resolution No. 66.23/2026/NQ-CP (“Resolution 66.23”), issued on July 24, 2026, amends selected provisions of the 2022 Law on Anti-Money Laundering and related regulations. The changes focus on beneficial ownership, customer due diligence, legal arrangements, risk classification, and customer information updates.

The resolution is particularly relevant for businesses and financial institutions subject to AML reporting requirements, as it expands the information they must collect and clarifies how beneficial owners are identified.

Beneficial ownership rules clarified

One of the key changes is a revised definition of a beneficial owner. The resolution defines a beneficial owner as one or more individuals who ultimately own or control a customer, directly or indirectly, or an individual on whose behalf a customer conducts a transaction.

For corporate customers, the rules generally identify as beneficial owners individuals who:

• Directly or indirectly own at least 25 per cent of charter capital or voting shares;
• Ultimately control the company through other legal or practical means; or
• Where no such person can be identified, hold the highest level of executive authority, subject to specific exceptions.

Reporting entities must review ownership structures across multiple layers where indirect ownership is involved. This is particularly relevant for companies with complex corporate structures, including those involving foreign entities or legal arrangements.

The rules also establish beneficial ownership criteria for foreign-established funds, trusts and similar legal arrangements, and life insurance contracts.

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Vietnam’s new beneficial ownership rules

The latest AML measures build on Vietnam’s broader push to strengthen corporate ownership transparency. Decree No. 296/2026/ND-CP, effective July 23, 2026, introduced mandatory beneficial ownership identification and disclosure requirements for enterprises, including a sequential process for tracing ownership and effective control through multi-layer corporate structures.

For a detailed overview of the new requirements and their implications for businesses, see Vietnam Introduces Mandatory Beneficial Ownership Disclosure Rules for Enterprises

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Expanded customer due diligence requirements

The resolution expands the information that reporting entities must collect when conducting customer due diligence (CDD).

For customers participating in trust arrangements or similar legal structures, reporting entities must collect information on relevant parties, including settlors, trustees, beneficiaries, potential beneficiaries, protectors, and individuals exercising ultimate control.

Additional requirements apply to life insurance policies. Beneficiary information must be collected once a beneficiary is designated, with verification required when the benefit is paid.

For corporate customers, CDD documentation can include enterprise registration or establishment documents, electronic identification information, organisational documents, appointment decisions or employment contracts for key executives, and information relating to founders, legal representatives, authorised representatives, and beneficial owners.

These requirements increase the importance of maintaining accurate ownership and control information as part of ongoing AML compliance.

Greater transparency for legal arrangements

The resolution also strengthens transparency requirements for trusts and other legal arrangements with similar characteristics.

Trustees and persons performing equivalent roles must collect, update, and retain identifying information on the parties involved, including beneficial owners of any corporate entities or legal arrangements participating in the structure.

Relevant information must generally be retained for at least five years after the trustee or equivalent party ceases to participate in the legal arrangement.

The State Bank of Vietnam and competent authorities may request this information for AML supervision, investigation, prosecution, or adjudication purposes.

Risk-based customer classification updated

The resolution also adjusts how reporting entities classify customers according to money laundering risk.

Customers must be classified as low, medium, or high risk based on factors including the customer, products and services used, geographic location, and other risk factors identified under the reporting entity’s internal procedures.

The initial risk classification must be completed immediately or within 10 working days of customer identification.

The frequency for updating customer information is also linked to risk:

Information must also be updated when new risks arise or when the reporting entity becomes aware that existing customer information has changed. Enhanced due diligence is required where there are suspicions of money laundering, terrorist financing, proliferation financing, or other high-risk scenarios.

What businesses should consider

For businesses subject to Vietnam’s AML reporting requirements, the changes may require adjustments to customer onboarding, ownership verification, internal risk assessments, and record-keeping procedures.

Companies with multi-layered ownership structures or overseas shareholders should pay particular attention to how beneficial ownership is identified and documented. Financial institutions and other reporting entities may also need to review their CDD procedures to ensure that required information can be obtained and updated within the new timeframes.

The measures are temporary and are intended to address urgent legal gaps while broader amendments to Vietnam’s AML-related laws and implementing regulations are being finalised.

Resolution 66.23 took effect on 24 July 2026, and will remain effective until 28 February 2027, or until the relevant amended legal documents take effect, whichever comes first. During this period, the resolution prevails where its provisions conflict with other applicable legal documents.