15 suspicious signs in the crypto-asset sector

This is a new provision under Law No. 23/2026/QH16 Amending the Law on the State Bank of Vietnam, which takes effect on December 1, 2026.

Clause 9, Article 1 of Law No. 23/2026/QH16 adds Article 33a after Article 33 of the Law on the State Bank of Vietnam, providing 15 suspicious signs in the crypto-asset sector:

(1) Splitting crypto-asset transactions into multiple amounts of lower value than the prescribed threshold for customer identification or reporting, or conducting multiple large-value crypto-asset transactions within a short period of time without a clear business purpose.

(2) The occurrence of any of the following cases that is inconsistent with the customer’s profile and characteristics: making deposits, conducting transactions and withdrawing crypto-assets consecutively within a very short period of time immediately after establishing the customer relationship; making a large-value initial deposit immediately after opening a crypto-asset account; or conducting transactions of a large value or at an unusual frequency through a crypto-asset account that has been inactive for a long period of time.

(3) Immediately transferring crypto-assets to multiple crypto-asset service providers in countries or territories included in lists published by the Financial Action Task Force for anti-money laundering, counter-terrorist financing and countering the financing of the proliferation of weapons of mass destruction, or in countries or territories that have not promulgated or have not fully promulgated legal frameworks on anti-money laundering, counter-terrorist financing and countering the financing of the proliferation of weapons of mass destruction applicable to crypto-assets and crypto-asset service providers and are included in lists concerning crypto-assets published by the Financial Action Task Force, while having no reasonable connection with the customer’s place of residence or place of operation.