Circular 25/2025/TT-NHNN Amending Certain Provisions of Circular 17/2024/TT-NHNN on Opening and Using Payment Accounts

STATE BANK OF VIETNAM

No.: 25/2025/TT-NHNN

SOCIALIST REPUBLIC OF VIETNAM
Independence - Freedom - Happiness

Hanoi, January 3, 2025

CIRCULAR

Amending Certain Provisions of Circular 17/2024/TT-NHNN on Opening and Using Payment Accounts at Payment Service Providers

Pursuant to the Law on the State Bank of Vietnam No. 32/2024/QH15; Pursuant to the Law on Credit Institutions No. 32/2024/QH15; Pursuant to the Law on Prevention and Combating Money Laundering No. 32/2022/QH15; Pursuant to Decree No. 52/2024/ND-CP of the Government on non-cash payments; Pursuant to Decree No. 123/2025/ND-CP of the Government amending certain provisions of the Law on Prevention and Combating Money Laundering; Pursuant to Decree No. 26/2025/ND-CP of the Government defining the functions, tasks, powers, and organizational structure of the State Bank of Vietnam;

At the proposal of the Head of the Payment Department; The Governor of the State Bank of Vietnam hereby issues the Circular amending certain provisions of Circular 17/2024/TT-NHNN on Opening and Using Payment Accounts at Payment Service Providers.

Article 1. Amendment and Supplementation of Clause 2, Article 7

2. The State Bank of Vietnam shall authorize regional branches to open payment accounts for:
   Sub-branches of the State Bank of Vietnam, credit institutions, and branches of foreign banks.

Article 2. Amendment, Supplementation, and Abolition of Certain Articles and Clauses of Article 9

1. Abolish the provisions at point (iv) and point (iv) of Clause 3, Article 9.

2. Replace the term "State Bank of Vietnam branch" with the term "State Bank of Vietnam regional branch" at Clause 3, Clause 4, Article 9.

Article 3. Amendment and Supplementation of Certain Points and Clauses of Article 12

1. Amend and supplement point a, Clause 2, Article 12 as follows:
   "a) In case the account holder is a Vietnamese citizen: Citizen identification card, household registration book, or birth certificate relative to a person under 14 years of age who does not yet have a citizen identification card."

2. Amend and supplement point (i), Clause 2, Article 12 as follows:
   "(i) Foreign passport or other identity document issued by a competent authority of a foreign country, relative to a foreigner; or entry permit, or identity document replacing entry permit, or document exempt from entry permit; or"

3. Amend and supplement Clause 3, Article 12 as follows:
   "3. Documents, information, and data of the customer at the institution: Documents, information, and data to be recognized as customer identification information according to the provisions of the Law on Prevention and Combating Money Laundering, along with the documents, information, and data of the representative of the institution or the accountant (if any) according to the provisions at point a, Clause 1, Article 16 of this Circular; and documents, information, and data of the person using the electronic identification and authentication service, online banking, or branch of a foreign bank, including the documents, information, and data of the customer of the institution."

Article 4. Supplementation of Point c after Point b, Clause 1, Article 13

"c) Account name at the payment account, account name at the payment account. In that regard, the name of the payment account shall be set as follows:
(i) For individual payment accounts, the name of the payment account shall be set according to the information of the surname and name on the customer's identity document; (ii) For institutional payment accounts, the name of the payment account must include the full name of the institution as shown on the Certificate of Establishment, Operation License, or other legal documents of the institution; (iii) For general payment accounts, the name of the payment account set by the bank, branch of a foreign bank, must clearly reflect the names of the sub-accounts and not conflict with the payment account names of the owners, institutions."

Article 5. Amendment and Supplementation of Certain Clauses of Article 15

1. Amend and supplement Clause 2, Article 15 as follows:
   "2. Banks, branches of foreign banks shall perform checks on the legality, appropriateness, and consistency of the documents, information, and data provided by the customer to verify customer identification information according to the provisions of the Law on Prevention and Combating Money Laundering and the following provisions:

a) For payment account owners who are individuals:
(i) In case the account holder or the representative of the individual uses a passport or citizen identification card (with stored information part) or electronic identity, the bank, branch of a foreign bank must meet face-to-face with the account holder or the representative of the account holder and perform checks to compare identity documents, cross-check biological information of the account holder or the representative of the account holder according to the provisions at point b, Clause 1, Article 16 of this Circular; (ii) In case the account holder or the representative of the individual uses a citizen identification card (with stored information part) or a birth certificate relative to a person under 14 years of age who does not yet have a citizen identification card, or a passport, the bank, branch of a foreign bank must meet face-to-face with the account holder or the representative of the account holder and perform checks to compare identity documents, cross-check biological information of the account holder or the representative of the account holder with the biological information displayed on the identity document of that person; (iii) In case the account holder is a foreign individual without presence in Vietnam, the bank, branch of a foreign bank may perform verification of customer identification information through a third party or through another institution; (iv) In case the representative is an institution, perform according to the provisions at point b, Clause 1 of this Article.

b) For payment account owners who are institutions:
(i) In case the account holder is an institution established and operating in Vietnam (except for the case specified at point d, Clause 1 of this Article), the bank, branch of a foreign bank must meet face-to-face with the legal representative of the account holder, perform checks to verify the information of the legal representative of the account holder according to the provisions at points a(i), a(ii), a(iii) of Clause 1 of this Article; (ii) In case the account holder is a foreign legal entity (except for the case specified at point d, Clause 1 of this Article), the bank, branch of a foreign bank may perform verification of the information of the legal representative of the account holder through a third party or another institution, but must meet face-to-face with the legal representative of the account holder to perform checks to compare identity documents, cross-check biological information of the legal representative with the biological information displayed on the identity document of that person.

c) For general payment accounts:
(i) In case the owner of the general payment account is an individual, perform according to the provisions at point a, Clause 1 of this Article; (ii) In case the owner of the general payment account is an institution, perform according to the provisions at point b, Clause 1 of this Article.

d) Banks, branches of foreign banks are not required to perform according to the provisions at point b, Clause 1 of this Article for the following institutions:
(i) State agencies, public service units;
(ii) Credit institutions, branches of foreign banks; (iii) Securities companies according to the provisions of the Securities Law; (iv) Institutions included in the Fortune Global 500 list published by Fortune magazine in the previous year; (v) Other institutions selected by the bank, branch of a foreign bank, assuming full responsibility for the risks arising from this selection. The list of institutions selected by the bank, branch of a foreign bank must comply with the criteria specified in the internal regulations on opening and using payment accounts of the unit. Banks, branches of foreign banks must ensure accurate verification and assume full responsibility for customer identification when opening payment accounts at their units.

d) In case the customer regularly transacts on the software application "Viettel Money" or other online banking applications in the banking sector, the bank, branch of a foreign bank must check information on the time of registration of the account holder (for individual customers), the legal representative of the account holder (for institutional customers), ensuring that the information matches the information on the identity document of that person."

2. Supplement Clause 7 as follows:
   "7. The provisions of Clause 2 of this Article do not apply to cases where payment accounts are opened according to the provisions of Article 15a, Article 16 of this Circular."

Article 6. Supplement Article 15a after Article 15

"Article 15a. Opening and Using Payment Accounts of Foreign Investors who are Non-Residents Engaging in Indirect Investment Activities in Vietnam

1. Foreign investors who are non-residents (hereinafter referred to as foreign investors) engaging in indirect investment activities in Vietnam have the right to choose an institution to provide foreign exchange services to open, close, and use payment accounts at banks, branches of foreign banks.
   Banks, branches of foreign banks must perform customer identification for foreign investors and the chosen institution according to the provisions of the Law on Prevention and Combating Money Laundering.

2. The opening and use of payment accounts of foreign investors engaging in indirect investment activities in Vietnam shall be performed according to the provisions of this Circular, regulations on foreign exchange management, and the following provisions:

a) The provisions on legalization of orders at point b, Clause 6, Article 12 of this Circular do not apply. For documents in the account opening dossier issued by competent authorities of foreign countries, they must be notarized, legalized, and conform to the provisions of Vietnamese law or foreign law within 12 months calculated from the date the bank, branch of a foreign bank receives the dossier;

b) Banks, branches of foreign banks shall perform checks on the legality, appropriateness, and consistency of the documents, information, and data provided by the customer to verify customer identification information according to the provisions of the Law on Prevention and Combating Money Laundering;

c) The provisions at point b, Clause 1, Article 5; Clause 3, Article 19; point b, Clause 2, Article 21 of this Circular do not apply.

3. Banks, branches of foreign banks are allowed to use the SWIFT system in opening and using payment accounts for foreign investors engaging in indirect investment activities in Vietnam. The opening of payment accounts through the SWIFT system shall be performed according to the provisions of this Article."

Article 7. Amendment and Supplementation of Certain Points and Clauses of Article 16

1. Amend and supplement point c, Clause 2, Article 16 as follows:
   "c) Store, preserve hard copies, corresponding to the documents, information, and data to be recognized as customer identification information, through the process of opening and using payment accounts using electronic means, such as: customer identification information; the elements of biological information of individual payment account holders, legal representatives of institutions opening payment accounts; audio, video, recording, telephone numbers for each transaction on online banking software applications; unique identification number of the transaction device; transaction journal; results of cross-checking biological information according to the provisions at point b, Clause 1, Article 16 of this Circular. The information and data must be stored securely, protected, backed up to ensure integrity, completeness of the data for inspection, comparison, verification of accounts in the process of using payment accounts, for inspection, complaints, disputes, and providing information when requested by competent authorities. The time of performance shall be according to the provisions of the Law on Prevention and Combating Money Laundering and electronic transactions."

2. Amend and supplement Clause 3, Article 16 as follows:
   "3. The opening of payment accounts by electronic means does not apply to the following cases:
   a) General payment accounts; b) Individual customers according to the provisions at points b, c, Clause 1, Article 11 of this Circular."

Article 8. Amendment and Supplementation of Certain Points and Clauses of Article 17

1. Amend and supplement point d, Clause 5, Article 17 as follows:
   "d) Apply electronic transaction confirmation forms for each type of transaction in payments using electronic means according to the provisions of the State Bank of Vietnam and ensure security, confidentiality for the provision of online banking services."

2. Supplement point e, Clause 5, Article 17 as follows:
   "e) The provisions at point c, Clause 5, Article 17 of this Circular do not apply to the following cases:
   (i) Customers withdrawing cash using physical cards at ATMs; (ii) Banks, branches of foreign banks deducting fees according to the provisions at point a(iv), Clause 1, Article 21 of this Circular; (iii) Customers who are institutions specified at point d, Clause 2, Article 15 of this Circular; (iv) Customers who are foreign investors opening payment accounts according to the provisions of Article 15a of this Circular."

Article 9. Amendment and Supplementation of Certain Points and Clauses of Article 19

1. Amend and supplement point a(i), Clause 1, Article 19 as follows:
   "(i) Measures to check legality, appropriateness and cross-check to ensure consistency, accuracy of documents, information, data in the payment account opening dossier of the customer; the process of performing checks to cross-check, verify again customer identification information in the process of using payment accounts."

2. Amend and supplement point b, Clause 1, Article 19 as follows:
   "b) List of criteria for identifying payment accounts with signs of suspicious transactions, fraud, and violation of the law (hereinafter referred to as the list of criteria) must include at least the following criteria: Legality, appropriateness of the documents, information, data in the payment account opening dossier; quantity, value of transactions at the payment account not consistent with the customer identification information provided for the account (including information related to the business, profession of the customer who is an individual); the payment account or the legal representative of the institution opening the account is included in the warning list of competent agencies; payment accounts with payment transactions but cannot be processed normally. Banks, branches of foreign banks must regularly inspect, update, supplement the list of criteria based on documents, information, data in the process of opening and using customer payment accounts."

3. Amend and supplement point c(iii), Clause 1, Article 19 as follows:
   "(iii) Cases applying the criteria or signs of suspicious transactions using electronic means, including cases where payment accounts have payment transactions but are not related to the customer according to the contact information provided by the customer."

Article 10. Amendment and Supplementation of Certain Points and Clauses of Article 21

1. Amend and supplement point d, Clause 2, Article 21 as follows:
   "d) Update customer information periodically or when the customer notifies changes in information in the account opening dossier or when there is suspicion about the accuracy and completeness of the previously collected customer identification information, to ensure that updated information is verified thoroughly and promptly, verify customer identification information when determining that the customer has a high risk level according to criteria issued by the bank, branch of a foreign bank. Archive the payment account dossier and transaction documents through the account according to the provisions of the law."

2. Amend and supplement point i, Clause 2, Article 21 as follows:
   "i) Guide customers to use payment accounts securely, use online banking services, general payment accounts, comply with payment transactions, notify, explain to customers about rights and obligations in opening and using payment accounts, and promptly resolve complaints and disputes of customers in opening and using payment accounts according to the provisions of this Circular and the agreement between the payment account holder and the bank, branch of a foreign bank."

3. Amend point k, Clause 2, Article 21 as follows:
   "k) Issue and implement internal regulations on opening and using payment accounts at banks, branches of foreign banks; publicly notify the contents of the dossier, account name, use of payment accounts, and regulations on inspection, complaints, appeals to allow customers to know and implement. Internal regulations must include at least the following contents:
   (i) Regulations on dossiers, procedures, time limits for opening payment accounts, including the time limit for opening payment accounts by electronic means and opening payment accounts for customers who are residents, persons without full civil capacity, persons with limited civil capacity; (ii) Regulations and agreements on opening and using payment accounts and principles for naming general payment accounts; (iii) Regulations on the use of payment accounts; (iv) Regulations on inspection, complaints, appeals to request inspection of complaints; (v) Regulations on risk management in opening and using payment accounts in compliance with the provisions at Clause 1, Article 19 of this Circular; (vi) Criteria for selecting and listing customers who are institutions specified at point d(v), Clause 2, Article 15."

Article 11. Amendment and Supplementation of Clause 2, Article 22

"2. Periodically, before the 10th day of each month, banks, branches of foreign banks shall report to the State Bank of Vietnam according to the requirements of the State Bank of Vietnam information on payment accounts with signs of suspicious transactions, fraud, and violation of the law according to Appendix 02, Appendix 03 attached to this Circular. The provision of information shall be performed by electronic means according to the technical connection guidelines of the State Bank of Vietnam.

In case of changes to information in Appendix 02, Appendix 03, banks, branches of foreign banks must promptly update and send to the State Bank of Vietnam; assume responsibility for the timeliness, accuracy of the information and data provided to the State Bank of Vietnam."

Article 12. Amendment and Supplementation of Article 25

"Article 25. Responsibilities of Organizations

The heads of units belonging to the State Bank of Vietnam, credit institutions, branches of foreign banks shall assume organizational responsibilities for implementing this Circular."

Article 13. Amendment and Supplementation of Appendices to Circular 17/2024/TT-NHNN

1. Replace Appendix 02 issued together with Circular 17/2024/TT-NHNN with Appendix 02 issued together with this Circular.
2. Supplement Appendix 03.

Article 14. Responsibilities of Organizations for Implementation

The heads of units belonging to the State Bank of Vietnam, credit institutions, branches of foreign banks shall assume organizational responsibilities for implementing this Circular.

Article 15. Provisions on Effect

1. This Circular takes effect from January 3, 2025, except for the cases specified at Article 2, Article 3 of this Circular.
2. Article 4 of this Circular takes effect from March 1, 2026.
3. Article 5, Article 9, Clause 2, Clause 3, Article 10 of this Circular take effect from December 1, 2025."

This Circular has 08 pages.

Place of issue: Hanoi, date January 3, 2025

The Governor of the State Bank of Vietnam

Pham Thi Dieu Hoa