Since 19 September 2026, non-resident foreign credit institutions have been expressly permitted to use foreign currency or Vietnamese dong payment accounts at authorised banks in Vietnam to make international payments and money transfers for their customers. The arrangement must be set out in a written agreement with the bank that holds the account and comply with Vietnamese law.
The State Bank of Vietnam issued Circular No. 39/2026/TT-NHNN on 5 August 2026. It amends Circular No. 16/2014/TT-NHNN, which governs the use of foreign currency and Vietnamese dong payment accounts by residents and non-residents at authorised banks.
Plan Cross-Border Payments
Speak with Ascentium Vietnam about the documentation and compliance requirements for processing customer payments through a local bank.What changes under Circular 39?
Circular 39 expressly permits non-resident foreign credit institutions to use their payment accounts in Vietnam to process international payments and money transfers for their customers. These institutions can also use the accounts for the receipts and payments already permitted under Circular 16 for the relevant account currency.
The amendment supports correspondent banking arrangements, in which a foreign credit institution uses an account with a bank in Vietnam to facilitate customer payments. The transactions remain subject to applicable Vietnamese foreign exchange and non-cash payment rules.
Which institutions and accounts are covered?
The rule applies to non-resident foreign credit institutions with foreign currency or Vietnamese dong payment accounts at authorised banks in Vietnam. Under Circular 16, authorised banks are commercial banks and foreign bank branches authorised to conduct foreign exchange business and provide foreign exchange services.
Fintech companies and payment service providers assessing this route should verify whether the entity that would hold the account qualifies as a non-resident foreign credit institution under Vietnamese law. They should also confirm with the account bank which transaction types and currencies it can support and what documents it requires.
What should the written agreement address?
The authorised bank and the foreign credit institution must agree in writing on the use of the account, including international payments and money transfers for customers. The agreement must comply with Vietnamese law.
In practice, the parties should agree on which transactions and currencies the bank will support, how to submit payment instructions, and when funds must be available for settlement. If the bank requires advance funding, the agreement should address how it handles instructions when the balance is insufficient.
The agreement should also specify who supplies customer and transaction documents, who responds to requests for additional evidence, and how the parties resolve discrepancies. Commercial terms can cover fees, intermediary charges, exchange rates, and how to handle delayed, rejected or returned transfers. Suspension and termination terms can address pending payments, remaining balances and access to records.
Review Payment Routes
Ascentium Vietnam can help your finance team review payment documentation and update reconciliation procedures before switching routes.What compliance responsibilities apply?
Authorised credit institutions must comply with the circular and guide their customers on its requirements. They must specify, check and retain supporting documents appropriate to the transactions they process to ensure that foreign exchange services are provided for the proper purpose and in compliance with applicable law. They are responsible for payment and transfer services they provide through covered accounts held with them and must comply with applicable non-cash payment and foreign exchange rules.
Other relevant organisations and individuals must comply with the circular, present the documents required by the authorised credit institution when carrying out foreign exchange transactions, and take legal responsibility for the authenticity of those documents. Both groups must comply with applicable laws on combating money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction.
For example, if a payment instruction names a beneficiary different from the supplier on the invoice, the parties should clarify who will obtain an explanation and what evidence the processing bank needs before it can proceed.
What should businesses check before using a new payment route?
Businesses considering a new route for payments to or from Vietnam should ask their overseas financial institution which services it offers through its banking partner in Vietnam and what supporting documents it requires. Before switching, compare total charges, exchange rates, processing cut-off times, expected settlement times, and options for tracking payments. Confirm how the institution handles a rejected or returned transfer and who will follow up if a payment is delayed.
