With the objective of translating the Party’s and State’s policies and directives into concrete measures for the pilot implementation of the crypto asset market and the development of the digital technology industry; and to ensure the effective implementation of Government Resolution No. 05/2025/NQ-CP dated September 9, 2025 on the pilot implementation of the crypto asset market in Viet Nam (Resolution No. 05/2025/NQ-CP), Digital Technology Industry Law, Anti-Money Laundering Law, Counter-Terrorism Law, and Handling of Administrative Violations Law, while also establishing a legal basis for the timely detection, prevention, and sanctioning of violations related to crypto assets and the crypto asset market, thereby enhancing the effectiveness and efficiency of state management during the pilot implementation period, on July 16, 2026, the Government issued Decree No. 284/2026/ND-CP on administrative sanctions for violations related to crypto assets and the crypto asset market (Decree No. 284/2026/ND-CP). The Decree includes 04 chapters, 23 articles, effective from September 1, 2026, to the date Resolution No. 05/2025/NQ-CP expires, with the following contents:
1. Scope of regulation, subjects of application
This Decree stipulates administrative violations, forms and levels of sanctions, remedial measures, the enforcement of administrative penalties and remedial measures, the authority to prepare administrative violation records and impose administrative sanctions for violations related to crypto assets and the crypto asset market in Viet Nam in accordance with Resolution No. 05/2025/NQ-CP.
The Decree applies to Vietnamese and foreign organizations and individuals that commit administrative violations; persons authorized to prepare administrative violation records, persons authorized to impose administrative sanctions, and other relevant organizations and individuals. Organizations subject to this Decree include crypto asset issuers, crypto asset service providers, organizations established under Vietnamese law, and organizations established under foreign law that invest in crypto assets and operate in Viet Nam’s crypto asset market within the scope prescribed by Resolution No. 05/2025/NQ-CP, as well as other organizations involved in the offering and issuance of crypto assets and the organization and operation of crypto asset markets in Viet Nam.
2. Forms of sanctions, remedial measures, and maximum monetary penalties
The principal forms of administrative sanctions prescribed by the Decree are warnings and monetary fines. Supplementary sanctions include: temporary suspension of licenses for crypto asset market services; temporary suspension of crypto asset offering and issuance activities; temporary suspension of crypto asset service provision and confiscation of items used in violations.
Remedial measures include: requiring the withdrawal, correction, or provision of accurate and complete information; requiring the disgorgement of any unlawful gains; requiring the removal of websites, software, trading systems, and equipment used to commit the violation; requiring the cancellation of the crypto asset offering or issuance and the full refund of all funds raised; and requiring the payment of an amount equivalent to the value of exhibits or means of violation that have been unlawfully consumed, dissipated, or destroyed.
The maximum monetary penalty for violations prescribed under this Decree is 200 million VND for organizations and 100 million VND for individuals, corresponding to the maximum fines applicable in the digital technology industry under the Handling of Administrative Violations Law. The monetary penalties set out in Chapter II of the Decree apply to organizations. For the same violation, an individual is subject to a fine equal to one-half of the fine imposed on an organization.
3. Statute of limitations for imposing administrative sanctions
The statute of limitations for administrative sanctions related to crypto assets and the crypto asset market is one year. If a case is transferred by a competent criminal procedure authority for administrative handling, the statute of limitations is extended by one year. The Decree clearly defines when specific violations are considered to have ceased, including those involving information disclosure, reporting obligations, license amendments, and the segregation and management of clients’ funds and crypto assets. This ensures a consistent legal basis for determining the statute of limitations for administrative sanctions.
4. Categories of administrative violations and sanctioning provisions
4.1. Violations of regulations on the offering and issuance of crypto assets
Article 6 of Decree No. 284/2026/ND-CP sets administrative sanctions for violations in the offering and issuance of crypto assets, based on the conditions, obligations, and responsibilities of crypto asset issuers as stipulated in Resolution No. 05/2025/NQ-CP. A crypto asset issuer shall be subject to a fine from 70 million VND to 100 million VND for violating foreign ownership restrictions on underlying assets; from 100 million VND to 150 million VND for providing inaccurate, incomplete, untimely, or misleading information to authorities, service providers, or investors; and from 150 million VND to 200 million VND for offering or issuing crypto assets to ineligible investors, failing to meet prescribed conditions, failing to disclose the Prospectus and related documents, or not complying with disclosed information.
In addition to monetary fines, depending on the nature and severity of the violation, a crypto asset issuer may also be subject to the supplementary sanction of temporary suspension of offering and issuance activities for a period ranging from 3 to 12 months. The issuer may also be required to take remedial actions, such as providing accurate information or canceling the offering and fully refunding all proceeds.
4.2. Violations of regulations governing the organization of the crypto asset
Article 7 of Decree No. 284/2026/ND-CP sets administrative sanctions for violations related to the organization and operation of the crypto asset market, based on the principle that only crypto asset service providers holding a License to provide crypto asset trading market services issued by the Ministry of Finance are permitted to organize and operate a crypto asset market. A violating organization shall be subject to: 70 million VND to 100 million VND for failing to disclose the official commencement date of services; 100 million VND to 150 million VND for failing to fulfill or improperly fulfilling obligations after license revocation; 150 million VND to 180 million VND for not applying for a license amendment when required or operating beyond the licensed scope; and 180 million VND to 200 million VND for providing services or conducting advertising or marketing without the required license.
In addition to monetary fines, an organization operating beyond the scope specified in its License to provide crypto asset trading market services may be subject to the supplementary sanction of suspension of the License for a period of one to three months. An organization that provides such services without first obtaining the required License may also be subject to the confiscation of the exhibits and means used in the commission of the administrative violation. Depending on the violation, the organization may also be required to return unlawful gains, remove related websites, software, or equipment, pay an amount equal to the value of unlawfully used items, or withdraw or correct the relevant information.
4.3. Violations of the obligations of crypto asset service providers
Article 8 establishes a system of sanctions ranging from warnings to fines of up to 200 million VND for violations of the obligations and responsibilities of crypto asset service providers, as prescribed in clauses 2 and 3 of Article 15 of Resolution No. 05/2025/NQ-CP. These entities are directly responsible for organizing and operating the crypto asset market, verifying participants’ eligibility, managing clients’ funds and crypto assets, maintaining transaction records, monitoring trading activities, and providing information to competent state authorities. A warning shall be imposed for failure to fulfill the obligation to educate and raise investors’ awareness of crypto assets.
A fine of 30 million to 50 million VND will be imposed for failing to publish, within the prescribed time limit, the required operating procedures, audited annual financial statements, or audited reports on contributed charter capital; issuing amended or supplemented operating procedures without approval from the Ministry of Finance; failing to provide timely information to the Ministry of Finance, the State Bank of Vietnam, and the Ministry of Public Security regarding crypto asset issuances and market developments; or failing to disclose or properly notify clients of the service fee schedule as required. Failure to verify investor identities when opening accounts will result in a fine of 50 million to 70 million VND. For late disclosure of information, fines range from 50 million to 100 million VND, depending on the length of the delay.
A fine of 70 million to 100 million VND will be imposed for failing to submit required reports to regulatory authorities or for providing advertising and marketing information that is inaccurate, incomplete, unclear, or misleading.
Failure to manage each client’s funds and crypto assets separately from those of the service provider; failing to monitor transactions; failing to report to the Ministry of Finance when information may seriously affect investors’ rights and interests; failing to report the selection of crypto assets admitted for trading; failing to store data on servers located in Viet Nam; failing to prevent conflicts of interest; or failing to ensure third-party service providers meet required conditions.
A fine of 150 million to 200 million VND will be imposed for serious violations, including: failing to ensure issuance conditions and the completeness and accuracy of the Prospectus and required disclosures when providing a crypto asset issuance platform; failing to provide services that meet prescribed conditions or to ensure account opening complies with required principles; failing to ensure the accuracy, truthfulness, and completeness of dossiers submitted to regulatory authorities; or failing to ensure information system security and the protection of customer assets.
In addition to monetary fines, organizations fined between 100 million and 150 million VND will also face suspension of crypto asset service activities for one to three months. For violations subject to fines of 150 million to 200 million VND, the suspension period will be three to six months. Organizations that violate advertising or marketing regulations must also withdraw or correct the non-compliant information.
4.4. Violations of regulations on crypto asset transactions
Article 9 provides sanctions for domestic investors who violate regulations, ensuring that crypto asset trading occurs only within the pilot program, through licensed service providers, and by eligible participants as specified in Resolution No. 05/2025/NQ-CP. Domestic investors who trade crypto assets without using service providers licensed by the Ministry of Finance shall be subject to a fine from 30 million VND to 50 million VND.
If domestic investors trade crypto assets from issuances or offerings intended for foreign investors, as outlined in clause 1, Article 6 of Resolution No. 05/2025/NQ-CP, they shall be subject to a fine from 70 million VND to 100 million VND.
4.5. Violations of regulations on fund transfers by foreign investors
Article 10 outlines sanctions for violations involving fund transfers related to the purchase and sale of crypto assets. These sanctions are based on the responsibilities of foreign investors and authorized banks where dedicated accounts are opened, as specified in Article 13 of Resolution No. 05/2025/NQ-CP.
Foreign investors who violate regulations on opening, closing, or using payment accounts for transactions related to crypto asset purchases and sales in Vietnam will be fined between 30 million VND and 50 million VND. If foreign investors fail to ensure the authenticity, validity, or legality of documents and information provided to the authorized bank, or submit inaccurate or incomplete transaction details, the fine will range from 70 million VND to 100 million VND.
Authorized banks that do not promptly report account receipt and payment activities will be fined between 50 million VND and 100 million VND, depending on the length of the delay. A fine of 70 million VND to 100 million VND applies for failing to inspect, retain, or properly maintain transaction records; failing to issue or issuing incomplete internal regulations; not publicly disclosing internal regulations for foreign investors; or violating regulations when opening, closing, or conducting transactions through dedicated accounts.
4.6. Violations involving the unauthorized collection, storage, exchange, purchase, sale, donation, or disclosure of crypto asset account data and information
Article 11 imposes sanctions for the unauthorized collection, storage, exchange, purchase, sale, donation, or disclosure of crypto asset account data and information, to protect the confidentiality and security of such data, as well as the lawful rights of market participants. Organizations found in violation are subject to fines ranging from 150 million VND to 200 million VND. Individuals face fines equal to half the amount imposed on organizations.
In addition to monetary fines, organizations and individuals committing such violations shall also be subject to suspension of their crypto asset trading activities for a period of one to three months and shall be required to disgorge any unlawful profits obtained from the violations. The concurrent application of additional sanctions and remedial measures is intended to prevent the continued unauthorized exploitation and use of account information, while also depriving violators of any financial benefits derived from their unlawful conduct.
4.7. Violations involving obstruction of inspections, examinations, and requests for information
Article 12 imposes sanctions for obstructing inspections, examinations, or compliance with requests for the provision of information, to ensure that competent authorities and authorized officials can promptly access the information, documents, and evidence necessary to detect, verify, and handle violations. Accordingly, a fine of 50 million VND to 100 million VND applies for refusing or failing to provide information, documents, or electronic data in a timely, complete, or accurate manner; resisting, obstructing, or evading inspections or examinations; failing to comply with requests for explanations or to appear before authorities; or delaying or failing to comply with official decisions or requests.
A fine of 70 million VND to 150 million VND shall be imposed for more serious violations, such as concealing or altering documents or electronic data, tampering with evidence, removing official seals without authorization; concealing, misappropriating, or unlawfully destroying documents or physical evidence related to the case. In addition to monetary fines, depending on the nature of the violation, a crypto asset service provider may also face suspension of service activities for one to three months, and any instruments or materials used in the violation may be confiscated.
4.8. Violations of regulations on anti-money laundering, counter-terrorist financing, and counter-proliferation financing of weapons of mass destruction
Article 13 establishes specific sanctions for organizations and individuals in the crypto asset market who violate anti-money laundering, counter-terrorist financing, and counter-proliferation financing obligations. Violations include failure to conduct customer due diligence, inadequate risk assessment, lack of internal policies and procedures, insufficient enhanced due diligence for foreign politically exposed persons, improper customer risk classification, poor risk management for new products and technologies, inadequate monitoring of special transactions, failure to report large-value or suspicious transactions, improper retention or protection of information, and failure to delay transactions, freeze accounts, or seize assets as required. Other prohibited acts under applicable laws and regulations also apply.
Depending on the nature and severity of the violation, organizations may be subject to fines of 80 million VND to 200 million VND; individuals committing the same violations are subject to a fine equal to half the amount imposed on organizations. For prohibited acts specified in clause 9, Article 13, in addition to monetary fines, the crypto asset service provider may also be subject to suspension of crypto asset service provision activities for a period of one to three months; a crypto asset issuing organization shall also be subject to suspension of its crypto asset offering and issuance activities for a period of six to twelve months; organizations and individuals engaging in crypto asset transactions shall also be subject to suspension of their crypto asset trading activities for a period of six to twelve months.
5. Competence to impose administrative sanctions, prepare records of administrative violations, and apply additional sanctions and remedial measures
Chapter III of Decree No. 284/2026/ND-CP sets out the authority to impose administrative sanctions, the authority to prepare records of administrative violations, the principles for determining jurisdiction, and the implementation of additional sanctions and remedial measures.
The authority to impose administrative sanctions is granted to designated officials in finance, securities, and banking authorities, designated officers of the People’s Public Security Forces, and Chairpersons of Provincial People’s Committees, in accordance with the functions, duties, and scope of state management of their respective authorities.
The Head of an inspection or examination team may impose administrative sanctions only for violations within the scope and subject matter of the inspection or examination, and only during the legally prescribed period. If a case falls under the jurisdiction of multiple authorities, the official who first accepts the case is responsible for imposing the sanction. If the sanction, fine, or remedial measure exceeds that official’s authority, the case must be referred to the competent authority. Authorized officials, civil servants in finance and banking, officers of the People’s Public Security Forces on duty, and members of inspection or examination teams may prepare records of administrative violations within their assigned duties and powers.
The Decree also details the implementation of sanctions for suspending crypto asset offerings, issuances, or service provision activities, and outlines the enforcement of remedial measures specified in Articles 17, 18, and 19.