Deciphering Vietnam’s New Crypto Regulatory Landscape Under Decree 284
On July 16, 2026, the Government of Vietnam promulgated Decree No. 284/2026/NĐ-CP (hereinafter referred to as “Decree 284”), establishing a systematic framework of administrative penalties for violations in the crypto asset and crypto asset market sectors. Officially taking effect on September 1, 2026, this decree serves as a core implementing regulation supporting Resolution No. 05/2025/NQ-CP regarding the pilot policy for the crypto asset market.（Vietnam crypto exchange）
I. Maximum Penalty Standards
Decree 284 establishes a clear dual-track penalty cap: a maximum fine of VND 200 million for organizations and VND 100 million for individuals. If an individual commits the same violation as an organization, the fine amount is set at half of that levied on the organization.
II. Key Violations and Penalty Tiers
(1) Unlicensed Provision of Crypto Asset Services Engaging in crypto asset trading market services without obtaining the requisite service license, or conducting unauthorized advertising and marketing activities for crypto assets, will incur a fine ranging from VND 180 million to VND 200 million. This constitutes one of the highest penalty brackets under the decree.
(2) Crypto Asset Issuance Violations Crypto asset issuing entities involved in any of the following acts face fines between VND 150 million and VND 200 million: issuing or offering crypto assets to non-compliant entities; failing to satisfy issuance conditions; failing to disclose the prospectus and related documentation; or failing to abide by the information disclosed in the prospectus. Additionally, issuers violating foreign ownership limits are subject to fines of VND 70 million to VND 100 million, while those providing inaccurate or incomplete information face fines ranging from VND 100 million to VND 150 million.
(3) Illegal Acquisition or Disclosure of Account Data For unauthorized collection, storage, exchange, purchase, sale, gifting, or public disclosure of crypto asset account data and information, organizations face fines between VND 150 million and VND 200 million, with fines for individuals halved. Offending parties will also be subject to a 1-to-3-month suspension of crypto asset trading activities and forced disgorgement of illegal gains.
(4) AML/CFT (Anti-Money Laundering & Countering the Financing of Terrorism) Violations Failure to identify, update, or verify customer information carries a fine between VND 100 million and VND 120 million. Failure to establish internal AML rules and regulations carries a maximum fine of up to VND 200 million.
(5) Investor Trading Violations Domestic investors trading crypto assets through service providers unlicensed by the Ministry of Finance face fines of VND 30 million to VND 50 million. This marks the first time Vietnam has imposed penalties on investors for using unlicensed platforms. Investors participating in issuance projects reserved exclusively for foreign investors face fines of VND 70 million to VND 100 million.
(6) Absence of Customer Identity Verification Crypto asset service providers failing to verify the identity of investors opening accounts will be fined between VND 50 million and VND 70 million.
III. Supplementary Penalties and Remedial Measures
In addition to monetary fines, Decree 284 prescribes a range of strict supplementary penalties and remedial measures, including:
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Revocation of licenses for 1 to 3 months;
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Suspension of issuance and trading activities for up to 12 months;
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Suspension of crypto asset service provision for up to 6 months;
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Mandatory recall or cancellation of issuances;
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Mandatory refunds to investors;
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Disgorgement of all illegal profits;
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Confiscation of assets and instrumentalities used in the violation.
Conclusion
The release of Decree 284 signals Vietnam’s transition from policy frameworks to active enforcement in crypto asset regulation. Grounded in the 5-year pilot market framework established by Resolution No. 05/2025/NQ-CP, the decree draws clear compliance boundaries through tiered penalties and diversified sanctions, sending an unequivocal signal of heightened regulation to all market participants.