Circular No. 09/2023/TT-NHNN guiding the implementation of certain provisions of the Law on Prevention and Combating Money Laundering

CIRCULAR

Guidelines for Implementing Certain Provisions of the Law on Anti-Money Laundering

Pursuant to the Law on the State Bank of Vietnam dated June 16, 2010;

Pursuant to the Law on Prevention and Combating Money Laundering dated November 15, 2022;

Pursuant to Decree No. 102/2022/NĐ-CP dated December 12, 2022 of the Government stipulating the functions, tasks, powers, and organizational structure of the State Bank of Vietnam;

At the proposal of the Director of Banking Inspection and Supervision;

The Governor of the State Bank of Vietnam issues this Circular guiding the implementation of certain provisions of the Law on Anti-Money Laundering.

Article 1. Scope of Regulation

This Circular stipulates criteria and methods for assessing money laundering risks of reporting entities; risk management procedures and customer classification based on money laundering risk levels; internal regulations on preventing and combating money laundering; reporting regimes for large-value transactions that must be reported; suspicious transaction reporting regimes; electronic fund transfer transactions; reporting regimes for electronic fund transfer transactions; forms and deadlines for reporting electronic data.

Article 2. Applicability

1. Financial organizations.

2. Non-financial business sectors related enterprises and individuals.

3. Vietnamese organizations and individuals, foreign organizations, foreigners, and international organizations conducting transactions with financial organizations and non-financial business sectors related enterprises and individuals.

4. Other organizations and individuals related to anti-money laundering activities.

Article 3. Criteria and Methods for Assessing Money Laundering Risks of Reporting Entities

1. Criteria for assessing money laundering risks of reporting entities include money laundering risk criteria and the appropriateness level criteria of internal policies and regulations on preventing and combating money laundering at reporting entities.

2. Money laundering risk criteria include money laundering risk criteria from the business environment of reporting entities and money laundering risk criteria from their business activities, specifically as follows:

a) Money laundering risk criteria from the business environment of reporting entities include money laundering risks from industries and sectors; countries and regions where reporting entities operate, based on national money laundering risk assessment results and self-assessment by reporting entities.

b) Money laundering risk criteria from the business activities of reporting entities include money laundering risks from customers; money laundering risks from products and services provided to customers; money laundering risks from distribution methods of products and services.

3. Appropriateness level criteria of internal policies and regulations on preventing and combating money laundering at reporting entities include the comprehensiveness of internal policies and regulations on preventing and combating money laundering and the effectiveness of implementing such policies and regulations, specifically as follows:

a) The comprehensiveness of internal policies and regulations on preventing and combating money laundering at reporting entities includes the completeness of internal policies and regulations on preventing and combating money laundering; compliance with laws and regulations on preventing and combating money laundering; suitability with the money laundering risk level of reporting entities; periodic review of such policies and regulations to align with changes in laws and practical operations.

b) The effectiveness of implementing internal policies and regulations on preventing and combating money laundering at reporting entities includes the effectiveness of anti-money laundering measures; the level of understanding and adherence to professional rules and standards by relevant leaders and employees regarding preventing and combating money laundering; the effectiveness of managing anti-money laundering work.

4. The method for assessing money laundering risks of reporting entities is a scoring method. The scoring method is implemented based on scoring each criterion specified in Clause 2 and Clause 3 of this Article, specifically as follows:

a) The score for each criterion specified in Clause 2 of this Article is determined on a scale from 1 to 5, with the principle that lower scores indicate lower money laundering risks.

b) The score of each criterion specified in Clause 3 of this Article is determined according to a scale from 1 to 5, following the principle that the lower the score value, the higher the level of appropriateness of internal policies and regulations on preventing and combating money laundering.

c) The weight of each criterion specified in Clause 2 and Clause 3 of this Article is a percentage (%) determined based on the importance of each criterion in anti-money laundering work. Reporting entities determine the weights based on their scale, scope, and specific operational characteristics.

d) The money laundering risk score is determined based on calculating the total score of each money laundering risk criterion specified in point a of this clause after multiplying by the weight specified in point c of this clause. Low money laundering risk if the score is less than or equal to 1; low-medium money laundering risk if the score is greater than 1 and less than or equal to 2; medium money laundering risk if the score is greater than 2 and less than or equal to 3; high-medium money laundering risk if the score is greater than 3 and less than or equal to 4; high money laundering risk if the score is greater than 4 and less than or equal to 5.

đ) The level of appropriateness score of internal policies and regulations on preventing and combating money laundering is determined based on calculating the total score of each appropriateness level criterion of internal policies and regulations on preventing and combating money laundering specified in point b of this clause after multiplying by the weight specified in point c of this clause. High level of appropriateness of internal policies and regulations on preventing and combating money laundering if the score is less than or equal to 1; high-medium level of appropriateness of internal policies and regulations on preventing and combating money laundering if the score is greater than 1 and less than or equal to 2; medium level of appropriateness of internal policies and regulations on preventing and combating money laundering if the score is greater than 2 and less than or equal to 3; low-medium level of appropriateness of internal policies and regulations on preventing and combating money laundering if the score is greater than 3 and less than or equal to 4; low level of appropriateness of internal policies and regulations on preventing and combating money laundering if the score is greater than 4 and less than or equal to 5.

e) The money laundering risk score is determined by averaging the money laundering risk score and the appropriateness level score of internal policies and regulations on preventing and combating money laundering. The lower the score, the lower the money laundering risk level: low money laundering risk if the score is less than or equal to 1; low-medium money laundering risk if the score is greater than 1 and less than or equal to 2; medium money laundering risk if the score is greater than 2 and less than or equal to 3; high-medium money laundering risk if the score is greater than 3 and less than or equal to 4; high money laundering risk if the score is greater than 4 and less than or equal to 5.

5. The period for collecting information and data to serve the assessment and updating of money laundering risks of reporting entities runs from January 1 to December 31 of the assessment year. Reporting entities must complete the report on the assessment and updating of money laundering risks no later than March 31 of the following year.

Article 4. Process for Managing Money Laundering Risks and Classifying Customers Based on Money Laundering Risk Levels

1. Based on the results of the assessment and updating of money laundering risks as stipulated in Article 3 of this Circular, the reporting entity shall develop and promulgate the anti-money laundering risk management process at the reporting entity. The anti-money laundering risk management process must be reflected in steps appropriate to the scale, scope, and specific characteristics of the reporting entity's operations to manage money laundering risks. The anti-money laundering risk management process includes the following minimum contents:

a) Determining the scope and objectives of money laundering risk management activities;

b) Identifying and assessing the impact of money laundering risks at the reporting entity;

c) Classifying customers according to low, medium, and high levels of money laundering risk based on the following factors: customer; products, services the customer is currently using or intends to use; geographic location where the customer resides or has its main office, and other factors determined by the reporting entity, classified in accordance with actual occurrences and specified in the anti-money laundering risk management process;

d) Procedures for identifying and assessing money laundering risk levels before providing new products or services; existing products or services applying new technology;

d) The process for managing risks to implement, refuse, suspend, control transactions after transactions, or review and report suspicious transactions involving inaccurate or incomplete information on electronic fund transfers as required;

e) Measures corresponding to different levels of money laundering risk of customers, including the frequency of updating and verifying customer identification information, the level of monitoring customer transactions according to the level of money laundering risk, measures for reduced customer due diligence and enhanced measures prescribed in Clause 2, 5 of this Article., the customer identification measures at a reduced level and the enhanced measures provided for in Clauses 2 and 5 of this Article.

2. For customers with low levels of money laundering risk, after establishing a relationship with the customer for the first time, when applying customer due diligence measures as prescribed by the Law on Anti-Money Laundering and the Government Decree detailing certain provisions of the Law on Anti-Money Laundering, the reporting entity may choose to apply one or all of the following reduced customer due diligence measures:

a) Not collecting information about the purpose and nature of business relationships if through established transactions or business relationships, the purpose and nature of the business relationship can be determined;

b) Reducing the frequency of updating customer identification information compared to customers with medium money laundering risk levels;

c) Reducing the level of monitoring customer transactions compared to customers with medium money laundering risk levels.

3. The reporting entity shall not apply reduced customer due diligence measures in cases of suspicion related to money laundering.

4. For customers with medium levels of money laundering risk, the reporting entity must apply customer due diligence measures as prescribed by the Law on Anti-Money Laundering and the Government Decree detailing certain provisions of the Law on Anti-Money Laundering.

5. For customers with high levels of money laundering risk, in addition to applying customer due diligence measures as prescribed by the Law on Anti-Money Laundering and the Government Decree detailing certain provisions of the Law on Anti-Money Laundering, the reporting entity must also apply enhanced measures, including:

a) Requiring approval from a higher management level by at least one level above the approval level applied for customers with medium levels of money laundering risk regarding the establishment or continuation of business relationships with high-risk customers;

b) Collecting, updating, and verifying additional information about individual customers to serve the evaluation and management of customer risks, including the following minimum information: the average monthly income of the customer over the last six months prior to the evaluation date; contact information of the organization or institution or owner of the workplace or primary source of income of the customer (if applicable); information related to the sources of funds or assets in the customer's transactions;

c) Collecting, updating, and verifying additional information about organizational customers to serve the evaluation and management of customer risks, including the following minimum information: the main industry, profession, production, business, service generating revenue; total revenue in the two most recent years prior to the evaluation date; information related to the sources of funds or assets in the customer's transactions;

d) Collecting, updating, and verifying other relevant information (if any) to serve the purpose of assessing and managing customer risk;

d) Strengthened monitoring of transactions conducted by customers through the reporting entity, business relationships through the application of control measures and selecting transaction samples for inspection to ensure that the customer's transactions are consistent with the purpose and nature of the business relationship between the customer and the reporting entity, the customer's business activities; promptly identifying suspicious signs and reviewing and reporting suspicious transactions;

e) Increasing the frequency of updating customer due diligence information compared to customers with medium-level money laundering risk;

Article 5. Internal regulations on anti-money laundering;

The internal regulations on anti-money laundering of the reporting entity as stipulated in Points b, c, e, g, h, i, k Clause 1 Article 24 of the Law on Anti-Money Laundering are as follows:

1. The customer due diligence process and procedures include the collection, updating, and verification of information as prescribed by laws on anti-money laundering and include provisions on situations requiring customer due diligence, customer due diligence information, updates; classification of responsibilities for customer due diligence according to risk levels and according to the scale, scope, and specific characteristics of the reporting entity's operations.

2. The anti-money laundering risk management process at reporting entities must include the contents prescribed in Clause 1 of Article 4 of this Circular.

3. Provisions on the storage and security of information as stipulated in Articles 38 and 40 of the Law on Anti-Money Laundering.

4. Provisions on the application of provisional measures as prescribed in Article 44 of the Law on Prevention and Combating Money Laundering and the Government Decree detailing certain provisions of the Law on Prevention and Combating Money Laundering.

5. Provisions on the reporting and provision of information to the State Bank of Vietnam and competent state agencies, including provisions on the method and process of reporting and providing information to ensure compliance with deadlines and content as prescribed by law.

6. Provisions on recruitment must include provisions to identify and select recruited personnel who meet job position requirements; training basic knowledge on anti-money laundering within six months from the date of recruitment.

7. Content of training and professional development in anti-money laundering, including: legal and internal regulations on anti-money laundering; responsibility for non-compliance with legal and internal regulations on anti-money laundering; methods and techniques of money laundering; money laundering risks related to products and services; tasks assigned to leaders and employees to perform.

8. The content of internal audit on anti-money laundering includes: independently and objectively examining, reviewing, and evaluating the internal control system, compliance with internal regulations and laws on anti-money laundering; recommending measures to enhance the effectiveness and efficiency of anti-money laundering activities. Internal audit on anti-money laundering may be conducted independently or combined with other contents but must be a separate item in the audit report. In cases where the reporting entity is not required to conduct internal audit according to the law, the reporting entity must ensure the implementation of controls for compliance with internal regulations and laws on anti-money laundering.

9. Responsibilities of individuals and departments involved in implementing anti-money laundering work must ensure:

a) Assigning a manager of the reporting entity or a person authorized by the manager to be responsible for organizing, directing, and supervising compliance with laws on anti-money laundering (hereinafter referred to as the person responsible for anti-money laundering).

b) Depending on the scale, scope, and specific nature of operations, the reporting entity shall establish a specialized department (team, office, division) or designate a department or a person responsible for anti-money laundering at the headquarters; assigning one or more persons or departments to be responsible for anti-money laundering at branches or subsidiaries related to anti-money laundering activities (if any).

10. Reporting entities have the responsibility:

a) Annually, conducting training and capacity building for leaders and employees related to anti-money laundering work (including employees assigned tasks directly related to transactions involving money and assets with customers).

b) Annually, reviewing and updating laws, policies, and risk management procedures on anti-money laundering that are appropriate to the results of risk assessments regarding money laundering at the reporting entity and actual implementation conditions to evaluate internal regulations and consider amendments, supplements, or replacements as necessary; submitting internal regulations on anti-money laundering to the Agency performing anti-money laundering functions under the State Bank of Vietnam (hereinafter referred to as the Agency performing anti-money laundering functions) within thirty days from the date of issuance or amendment, supplementation, or replacement of internal regulations on anti-money laundering.

c) Annually, submitting the internal audit report on anti-money laundering at the reporting entity to the Agency performing anti-money laundering functions within sixty days from the end of the fiscal year, except for reporting entities not required to conduct internal audit according to the law.

d) Registering information about the name, workplace address, phone number, email address for contact when necessary of the person responsible for anti-money laundering as stipulated in point a Clause 9 of this Article and the person responsible for anti-money laundering or the focal point of the department as stipulated in point b Clause 9 of this Article; the email address of the department as stipulated in point b Clause 9 of this Article (if any) to the Agency performing anti-money laundering functions.

đ) Notifying the Agency performing anti-money laundering functions in writing of changes to the information specified in point d Clause 10 of this Article within fifteen days from the date of change in information.

11. Reporting entities that are micro-enterprises or individuals shall issue internal regulations on anti-money laundering containing the provisions stipulated in Clause 1, 2, 3, 4 of this Article and point a, đ Clause 1 of Article 24 of the Anti-Money Laundering Law.

Article 6. Reporting regime for large-value transactions that must be reported

1. Reporting entities that have the responsibility to report large-value transactions must report according to the provisions of Clause 1 of Article 25 of the Anti-Money Laundering Law to the Agency performing anti-money laundering functions through electronic data as stipulated in Clause 1 of Article 10 of this Circular or report in paper form according to Appendix I attached to this Circular until such time as a compatible information technology system is established for reporting purposes.

2. In cases where customers deposit foreign currency cash in large amounts to purchase Vietnamese dong or deposit Vietnamese dong cash in large amounts to purchase foreign currency cash, only the cash deposit transaction shall be reported.

Article 7. Reporting regime for suspicious transactions

1. Reporting entities that discover suspicious transactions as stipulated in Article 26 of the Anti-Money Laundering Law have the responsibility to report to the Agency performing anti-money laundering functions. Reports shall be made in paper form according to Appendix II attached to this Circular or electronically when a compatible information technology system for electronic reporting has been established as stipulated in Clause 1 of Article 10 of this Circular and shall not apply in cases of reporting to other competent state agencies as stipulated in Clause 3 of Article 37 of the Anti-Money Laundering Law.

2. Reporting suspicious transactions as stipulated in Article 26 of the Anti-Money Laundering Law does not depend on the amount of customer transactions or whether the transaction has been completed.

3. The Agency performing anti-money laundering functions shall confirm receipt of reports of suspicious transactions by sending an email to the email address of the individual or department as stipulated in point b Clause 9 of Article 5 of this Circular or by paper within five working days from the date of receiving the report of suspicious transactions; discussing with the reporting entity any arising issues (if any).

4. Organizations and individuals providing accounting services; supplying notarization services; providing legal services of lawyers, law firms must examine, collect, and analyze information to report suspicious transactions when providing accounting services; performing notarization procedures, preparing conditions on behalf of customers to carry out transactions or representing customers to perform transactions transferring land use rights, ownership of houses, other assets attached to land; managing money, securities, or other customer assets; managing customer accounts at banks, securities companies; operating and managing companies; participating in buying and selling businesses on behalf of customers.

Article 8. Electronic money transfer transactions

1. Financial organizations participating in electronic money transfer transactions include:

a) Initiating financial organization is the organization initiating the electronic money transfer order and performing the transfer on behalf of the initiator;

b) Financial intermediaries are organizations that receive and transfer electronic fund transfer orders on behalf of initiating financial institutions and receiving financial institutions or on behalf of other financial intermediaries.

c) Beneficiary financial organization is the organization directly receiving the electronic money transfer order from the initiating financial organization or through an intermediary financial organization and making payment to the beneficiary.

2. Domestic financial organizations are initiating financial organizations in electronic fund transfer transactions and can only execute such transactions when the electronic fund transfer order contains complete and accurate information in accordance with the laws on non-cash payment and foreign exchange management.

3. Domestic financial organizations acting as intermediary financial organizations participating in electronic money transfer transactions must ensure:

a) Measures to identify electronic money transfer transactions that lack complete or accurate information as required by the laws on cashless payments and foreign exchange management;

b) Apply appropriate measures including refusing or temporarily suspending transactions or applying post-transaction control measures or examining and reporting suspicious transactions for electronic fund transfer transactions that lack complete and accurate information as required by the laws on non-cash payment and foreign exchange management.

4. Domestic financial organizations acting as beneficiary financial organizations in electronic money transfer transactions must ensure:

a) Measures to identify electronic money transfer transactions that lack complete or accurate information as required by the laws on cashless payments and foreign exchange management;

b) Apply appropriate measures including refusing or temporarily suspending transactions or applying post-transaction control measures or examining and reporting suspicious transactions for electronic fund transfer transactions that lack complete and accurate information as required by the laws on non-cash payment and foreign exchange management.

Article 9. Reporting regime for electronic money transfer transactions

1. Reporting entities are responsible for collecting information as stipulated in Clause 3 of this Article and reporting to the agency implementing anti-money laundering functions by electronic data as prescribed in Clause 1 of Article 10 of this Circular when conducting electronic fund transfer transactions in the following cases:

a) Electronic fund transfers where all financial institutions participating in the electronic fund transfer transactions specified in Clause 1 of Article 8 of this Circular are located in Vietnam (hereinafter referred to as domestic electronic fund transfers) with a transaction value of VND 500,000,000 (five hundred million) or more or equivalent foreign currency value;

b) Electronic fund transfers where at least one of the financial institutions participating in the electronic fund transfer transactions specified in Clause 1 of Article 8 of this Circular is located in countries or territories outside Vietnam (hereinafter referred to as international electronic fund transfers) with a transaction value of US$ 1,000 (one thousand) or more or equivalent foreign currency value.

2. In the case where the reporting entity is an intermediary financial organization in an electronic money transfer transaction, it is not required to report in accordance with Clause 1 of this Article.

3. The minimum contents of the report on electronic money transfer transactions include the following information:

a) Information about the initiating and receiving financial institutions includes: trading name of the organization or branch; main office address (or bank code for domestic electronic fund transfers, SWIFT code for international electronic fund transfers); country receiving and transferring funds;

b) Information about individual customers participating in electronic fund transfer transactions: full name, date of birth; identification card number or citizen identity card number or personal identification number or passport number; entry visa number (if applicable); registered place of residence or current place of residence (if applicable); nationality (according to transaction documents);

c) Information about organizational customers participating in electronic fund transfer transactions: full trading name and abbreviation (if any); main office address; establishment license number or business code or tax code; country where the main office is located;

d) Transaction information: account number (if available); amount; type of currency; amount converted to Vietnamese Dong (if the transaction currency is foreign currency); reason, purpose of the transaction; transaction code; transaction date;

e) Other information as required by the agency implementing anti-money laundering functions to serve state management of anti-money laundering during specific periods;

4. The information about date of birth, identification card number or citizen identity card number or personal identification number or passport number, entry visa number (if applicable) as stipulated in Point b Clause 3 of this Article; establishment license number or business code or tax code as stipulated in Point c Clause 3 of this Article are not mandatory for:

a) Beneficiaries in international electronic money transfer transactions from Vietnam to overseas;

b) Initiators in international electronic money transfer transactions from overseas to Vietnam.

5. Electronic money transfer transactions that do not require reporting include:

a) A transaction transferring funds originating from a transaction using a debit card, credit card, or prepaid card to pay for goods and services;

b) Electronic fund transfers and payments between financial institutions where both the initiator and the recipient are financial institutions.

Article 10. Form and deadline for reporting electronic data

1. Form of reporting electronic data:

a) Reporting entities establish a transmission network and connect to the State Bank of Vietnam's communication network through the Department of Information Technology to submit reports and information on anti-money laundering;

b) Electronic data reports are transmitted through the communication network established as stipulated in Point a of this Clause. Electronic data reports must comply with the data format and file structure as guided by the agency implementing anti-money laundering functions;

c) Reporting entities permitted to conduct electronic fund transfers must build an appropriate information technology system to support electronic data reporting and must have software systems to scan and filter according to blacklists, warning lists, politically exposed persons lists as prescribed in Clause 9, Clause 10 of Article 3 and Clause 1 of Article 17 of the Anti-Money Laundering Law, to detect and warn of suspicious signs for the purpose of preventing and combating money laundering.

2. Deadline for submitting electronic data reports: reporting entities must submit reports on large-value transactions and electronic fund transfer transactions before 16:00 on the next working day immediately following the transaction date. If the submission date coincides with a public holiday, Tet holiday, or weekend, then the submission date will be the next working day immediately following the holiday or weekend.

3. Amending and supplementing electronic data reports:

a) When the reporting subject discovers that a report has been submitted incompletely, the reporting subject must provide an explanatory document and submit a supplementary report within one working day following receipt of the confirmation document from the agency responsible for anti-money laundering functions. If the reporting subject discovers errors in the information or data already submitted to the agency responsible for anti-money laundering functions, the reporting subject must provide an explanatory document or email and resubmit the corrected report within one working day from the date of discovery;

b) When the reporting subject receives a notification from the agency responsible for anti-money laundering functions regarding missing or erroneous reports, the reporting subject must provide an explanatory document or email and resubmit or correct the report no later than seven working days from the date of receipt of the notification;

c) When the reporting subject receives a notification from a competent state authority pursuant to the law regarding the review and supplementation of reports, the reporting subject must notify the agency responsible for anti-money laundering functions and provide an explanatory document, submitting a corrected and supplemented report after receiving the confirmation document from the agency responsible for anti-money laundering functions;

4. The reporting subject must register in writing with the agency responsible for anti-money laundering functions regarding the person in charge of electronic data reporting, including the following information: full name, position, workplace address, telephone number, email address, and must notify in writing when there is a change in the information about this person in charge;

Article 11. Effective Date

1. This Circular takes effect from July 28, 2023, except for the provisions stipulated in Clause 2 of this Article;

2. The provisions on the risk management process against money laundering at Clause 2 of Article 5, the provisions on the reporting regime for large-value transactions at Article 6, the provisions on the reporting regime for electronic fund transfer transactions at Article 9, and the templates for suspicious transaction reports attached as Appendix II under this Circular take effect from December 1, 2023. During the period before these provisions at Clause 2 of Article 5, Article 6, Article 9, and Appendix II under this Circular come into effect, the reporting subjects shall continue to implement the provisions on the risk management process, reporting regime for large-value transactions, reporting regime for electronic fund transfer transactions, and templates for suspicious transaction reports in paper form as stipulated in Clause 2 of Article 3a, Article 5, Article 7, Article 10, and Form No. 01 of Circular No. 35/2013/TT-NHNN dated December 31, 2013, issued by the Governor of the State Bank of Vietnam guiding the implementation of certain provisions on anti-money laundering (amended and supplemented at Clause 3 of Article 1 of Circular No. 31/2014/TT-NHNN dated November 11, 2014, issued by the Governor of the State Bank of Vietnam to amend and supplement certain articles of Circular No. 35/2013/TT-NHNN and Clause 2 and Clause 4 of Article 1 of Circular No. 20/2019/TT-NHNN dated November 14, 2019, issued by the Governor of the State Bank of Vietnam to amend and supplement certain articles of Circular No. 35/2013/TT-NHNN);

3. From the date this Circular takes effect as stipulated in Clause 1 of this Article, the following Circulars cease to be effective;

a) Circular No. 35/2013/TT-NHNN dated December 31, 2013, issued by the Governor of the State Bank of Vietnam, except for the provisions on the reporting regime for large-value transactions, reporting regime for electronic fund transfer transactions, and templates for suspicious transaction reports in paper form at Articles 5, 7, 10, and Form No. 01 which cease to be effective from December 1, 2023;

b) Circular No. 31/2014/TT-NHNN dated November 11, 2014, issued by the Governor of the State Bank of Vietnam, except for the provisions on the reporting regime for electronic fund transfer transactions at Clause 3 of Article 1 which cease to be effective from December 1, 2023;

c) Circular No. 20/2019/TT-NHNN dated November 14, 2019, issued by the Governor of the State Bank of Vietnam, except for the provisions on the risk management process and electronic fund transfer transactions at Clause 2 and Clause 4 of Article 1 which cease to be effective from December 1, 2023;

Article 12. Responsibility for Implementation

1. The Director of the Office, the Head of Banking Inspection and Supervision, the Heads of agencies responsible for anti-money laundering functions, the Heads of units under the State Bank of Vietnam, and the organizations that are reporting subjects are responsible for implementing this Circular;

2. During the implementation of this Circular, if there are any difficulties, organizations, individuals, and reporting subjects are requested to reflect them to the State Bank of Vietnam (through the agency responsible for anti-money laundering functions)./