Foreign financial institutions may use accounts at Vietnamese banks for payments and international money transfers
The State Bank of Vietnam (SBV) has just issued Circular No. 39/2026/TT-NHNN, amending and supplementing certain provisions of Circular No. 16/2014/TT-NHNN, which provides guidelines on the use of foreign currency accounts and Vietnamese dong accounts held by residents and non-residents at authorized banks. The circular takes effect on September 19, 2026.
Under the new regulations, foreign credit institutions (FCIs) that are non-residents may use foreign currency accounts and Vietnamese dong accounts opened at authorized banks to make payments and international money transfers on behalf of customers in accordance with a written agreement between the two parties.
In addition, foreign credit institutions may conduct receipt and disbursement transactions in accordance with the provisions of Articles 5 and 7 of Circular No. 16/2014/TT-NHNN.
The Circular also stipulates that the use of accounts and other related matters shall be carried out in accordance with a written agreement between the authorized bank and the foreign financial institution, subject to compliance with Vietnamese law. Thus, the written agreement between the two institutions serves as the direct basis for the use of accounts for the aforementioned payment and international money transfer activities, but must remain within the framework of Vietnamese law.
In addition to supplementing provisions on account usage, Circular No. 39/2026/TT-NHNN amends and supplements Article 9 of Circular 16, clarifying the responsibilities of authorized financial institutions and residents, as well as non-resident organizations and individuals.
Accordingly, authorized credit institutions are responsible for complying with and guiding customers to comply with the provisions of the Circular; at the same time, they must establish procedures, verify, and retain documents and supporting evidence consistent with actual transactions. This is intended to ensure that the provision of foreign exchange services is carried out for the proper purposes and in compliance with legal regulations.
Notably, authorized financial institutions must assume full responsibility for the provision of payment and money transfer services through accounts held by non-residents—specifically, foreign financial institutions—opened at that same authorized financial institution.
These activities must comply with relevant legal provisions on non-cash payments, foreign exchange management, the provisions of this Circular, and other relevant regulations. Authorized financial institutions must also fully comply with legal provisions on the prevention and combating of money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction.
With regard to customers and related parties, the Circular requires organizations and individuals to strictly comply with the regulations; to present documents and supporting evidence as required by the authorized financial institution when conducting foreign exchange transactions; and to bear legal responsibility for the authenticity of the documents and supporting evidence presented.
Relevant organizations and individuals must also fully comply with regulations on the prevention and combating of money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction.
Circular No. 39/2026/TT-NHNN also amends and supplements provisions on implementation responsibilities, stipulating that the heads of relevant units under the State Bank of Vietnam and authorized credit institutions are responsible for implementing the Circular. Credit institutions, foreign bank branches, and related organizations and individuals are responsible for complying with the new regulations effective from the date the Circular takes effect.