The risk of money laundering through crypto-assets

On September 15, the Governor of the State Bank of Vietnam (SBV) issued Circular No. 27/2025/TT-NHNN (effective from November 1), replacing Circular 09/2023/TT-NHNN, guiding the implementation of a number of articles of the Law on Anti-Money Laundering and disseminating the content of Resolution 05 of the Government on piloting the crypto-asset market.

The document also updates the results of the national risk assessment on money laundering and terrorist financing.

At the dissemination workshop on the morning of October 16, Ms. Nguyen Thi Minh Tho, Deputy Director of the Anti-Money Laundering Department (SBV), said that Circular 27 emphasizes the principle of risk-based management. Accordingly, organizations must periodically assess money laundering risks and develop a process for identifying and verifying customers, including customers without accounts or with few transactions.

Reporting entities must also regularly monitor business relationships, ensuring transactions are consistent with legitimate sources of funds and customer identification records.

At the workshop, Mr. To Tran Hoa - Deputy Head of the Securities Market Development Department, State Securities Commission, warned that many money laundering tricks through crypto assets are popular in the world .

According to Mr. Hoa, organizations and individuals have bypassed the authentication system of service platforms by providing fake documents to carry out illegal money transfers. The subjects also take advantage of transactions between individuals through the "black market" to directly buy and sell crypto assets with cash.

However, the most difficult to identify is the act of “mixing” crypto assets when service providers can only identify the individual who owns the crypto assets, while the origin of the crypto assets is often not authenticated.

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The workshop was attended by management agencies, securities companies, fund managers, insurance, real estate businesses, notaries, accountants, auditors, casinos, gold traders...

Additionally, the subjects also transferred crypto assets through blockchains, creating many different transactions with values ​​below the warning threshold, leading to difficulties in tracing.

Another method of money laundering through crypto assets is for subjects to create “clean” projects, then use illegal crypto assets to buy back these projects and transfer the money back before “crashing” the project to erase all traces.

According to Lieutenant Colonel Dam Van Minh, Legal Reporter of the Central Department of Internal Security ( Ministry of Public Security ), with the development of the Internet and digital assets, the number of Vietnamese people participating in buying and selling digital assets is very large, with an estimated 26 million accounts owned by Vietnamese people.

Mr. Dam Van Minh said that up to this point, Vietnam has not recorded any cases of using digital assets to finance terrorism. “The risk of financing terrorism through digital assets in Vietnam is low,” Mr. Minh said.

However, the representative of the Ministry of Public Security said that the risk of money laundering is still at a worrying level. Therefore, it is necessary to assess the capacity of the organization and the source of customers with specific risk factors of money laundering and terrorist financing, instead of just assessing in a general way like businesses and professional associations as at present.

Prevent price inflation and money laundering through real estate

Representative of Ho Chi Minh City Real Estate Association (HoREA), Chairman Le Hoang Chau said that Circular 27 is a big step forward to help the real estate market become more transparent and safer.

The reason is that real estate is a high-risk area for money laundering because it is a large-scale investment channel with complex transactions that can easily be exploited to legalize illegal sources of money. Therefore, Circular 27 was issued at the right time, helping to create a tighter legal corridor, contributing to preventing risks and strengthening investor confidence.

The representative of the Real Estate Association said that the most important message of Circular 27 is to promote compliance and transparency. “If strictly implemented, this document will help the market operate more healthily, while limiting the phenomena of speculation, price inflation, and money laundering through real estate trading,” he emphasized.

In the context of real estate credit accounting for nearly 24% of total outstanding debt of the entire system, according to this person, transparent cash flow management is extremely necessary.

“In the first nine months of the year, real estate consumer credit increased by more than 12%, mainly for home purchases and repairs - reflecting the real needs of the people. But that is why management agencies and credit institutions must monitor more closely to avoid taking advantage of consumer credit to conceal money laundering,” he warned.

The Chairman of HoREA proposed to promote training, guidance and legal dissemination for businesses, especially brokerage companies, trading floors and investors, to raise awareness of compliance.

Source: https://vietnamnet.vn/rua-tien-thoi-tai-san-so-mua-du-an-sach-bang-tien-ban-danh-sap-de-xoa-dau-vet-2453415.html