In comparison with the old Law, the 2022 Law on Anti-money laundering fully regulates in details entities that have to report doubtful transactions; cases in which the collection and verification of information of customers participating in transactions are required; signs of suspicious activity in each sector; requirements of transparency of information regarding legal persons, legal arrangements, etc.

According to Article 27 of this Law, common signs of suspicious activity requiring collection and verification of information of customers participating in transactions include:

1. The customer refuses to provide information or provide inaccurate, inadequate and inconsistent identities.

2. The customer induces the reporting entity not to report the transaction to the competent state authority.

3. It is unlikely to identify a customer based on the information provided by the customer or a transaction relating to an anonymous party.

4. The phone number provided by a customer does not work or exist after an account is created or a transaction is performed.

5. The transaction is performed by order or according to the authorization obtained from entities and persons defined in the Greylist.

6. The transaction can, based on the customer’s identification information or through examination of economic and legal concepts thereof, determine the connection between the parties involved and criminal activities or the association with the entities or persons appearing on the Greylist.

7. The natural or legal person participates in a transaction at great expense, which is deemed as incommensurate with their business situation and income.

8. The customer requests the reporting entity to carry out a transaction without conforming to the procedures and processes required by law.

In addition, depending on each sector such as banking sector, payment intermediary sector, life insurance business sector, securities sector, prize-awarding game business sector, real estate business sector, etc. there are particular signs of suspicious as regulated from Article 28 thru Article 33.

With regard to great value transactions that must report to the State Bank of Vietnam, the Prime Minister will regulates in details in other documents.

This Law shall enter into force as from March 1, 2023 and replaces the Law on Anti-money laundering No. 07/2012/QH13 dated June 18, 2012. To amend clause 1 of Article 49 in the Law on State Bank of Vietnam No. 46/2010/QH12 dated June 16, 2010; Article 34, Article 35 of Anti-Terrorism Law No. 28/2013/QH13 dated June 12th, 2013.