Which Groups Need to Report Asset Status Regularly Under Vietnam’s Crypto Pilot Program?
Under the framework of Vietnam’s cryptocurrency pilot program, the Ministry of Finance is seeking public feedback on a draft circular regarding reporting and information disclosure requirements for the crypto pilot market. The following groups may be required to regularly report their asset status and transactions:
1. Crypto Asset Service Providers (Exchanges and Custody Platforms): Semi-Annual Customer Asset Reports
According to the draft, service providers must submit custody data to the State Securities Commission on a weekly basis. Additionally, enterprises must regularly submit audited semi-annual reports on customer assets by July 31 and January 31, respectively.
The reports must detail the quantity and value of assets at the beginning and end of the reporting period, custody wallet information, Proof of Reserves (PoR), and audit opinions (if any).
If operational changes affect the segregation of customer assets, enterprises must provide notification at least 3 days in advance. If adopting a new third-party custody service, a 7-day advance notice is required.
2. Crypto Asset Issuers: Market Trading and Information Must Be Transparent
During trading hours, exchanges must disclose the latest price, trading volume, highest price, lowest price, average price, and volatility for each cryptocurrency.
Every trading day before 9:00 AM, enterprises must publish data for the preceding 24 hours, including the number, volume, and total value of buy and sell orders.
If an enterprise adds or removes an asset from its platform, it must notify the Ministry of Finance, the Ministry of Public Security, and the State Bank of Vietnam within 24 hours.
The draft also outlines four reporting thresholds for transactions: under $1,000; $1,000 to $5,000; $5,000 to $10,000; and above $10,000.
3. Major Shareholders and Key Investors of Exchanges: Executives and Owners Holding 1% or More Must Give Advance Notice (Vietnam crypto exchange)
Organizations and individuals holding 1% or more of a service provider’s registered capital must give at least 3 days’ advance notice prior to any change in their shareholding ratio.
Members of the Board of Directors, directors, general managers, Chief Technology Officers (CTOs), and related parties must also provide 3 days’ advance notice when trading crypto assets hosted or held in custody by the organization.
In addition, enterprises must retain reported data for at least 10 years and keep disclosed information available on their official websites for at least 5 years, published in both Vietnamese and English.
Annually before March 31, service providers must also submit a comprehensive compliance evaluation report covering licensing, customer asset protection, Anti-Money Laundering (AML) measures, system security, and any deficiencies requiring remediation.