Vietnam’s New Crypto Sanctions To Impact Offshore Exchanges

A new decree on penalties for violations related to the crypto asset market creates compliance risks for offshore crypto asset exchanges in Vietnam that do not hold, and practically cannot obtain, a Vietnamese license, and for Vietnamese users who continue to transact on those platforms.

Decree No. 284/2026/ND-CP (Decree 284), issued by the government of Vietnam on July 16, 2026, formally establishes an administrative penalty framework for violations related to crypto assets and the crypto asset market. The decree takes effect on September 1, 2026, and will remain in force for the duration of the five-year pilot program under Resolution No. 05/2025/NQ-CP, which is scheduled to end in September 2030.

Direct Penalties on Vietnamese Users

The most immediate commercial risk to offshore platforms is that their Vietnamese users now face direct personal liability for using their exchanges. Vietnamese users who trade crypto assets outside of a Ministry of Finance-licensed service provider face fines of up to VND 50 million (approximately USD 1,900). Vietnamese users trading in crypto assets that are offered or issued to foreign users face higher penalties of up to VND 100 million (approximately USD 3,800).

It is expected that Vietnamese users will be more willing to migrate away from offshore platforms now that there is a risk of real enforcement against them.

Penalties on Unlicensed Service Providers

Violations of providing crypto asset services or advertising crypto-related services without a license face fines of up to VND 200 million (approximately USD 7,700). Operating a crypto asset trading market without proper authorization falls within the same highest penalty bands.

Organizations that violate issuance, provision, or disclosure rules may face fines of up to VND 200 million.

Although the maximum administrative fine per violation is capped at VND 200 million for organizations and VND 100 million for individuals, these are per-violation caps, and repeated violations are treated as aggravating circumstances, allowing authorities to escalate penalties within statutory ranges.

Supplementary Sanctions and Remedial Measures

Beyond monetary fines, Decree 284 empowers authorities to impose a range of supplementary and corrective measures that can cause significantly more operational harm to an offshore exchange than the headline fines alone. These include:

• Temporary suspension of activities for defined periods (more applicable to unlicensed local exchanges)
• Disgorgement of unlawful gains derived from noncompliant activities
• Confiscation of assets used in or connected to violations
• Orders to remove, suspend, or rectify noncompliant platforms, systems, or information
• Mandatory corrective disclosures
• Orders requiring the return of investor funds

With the maximum per-violation administrative fine for organizations set at approximately USD 7,700, the fines themselves could be viewed as modest by global standards. However, there is a greater potential for risk due to user attrition, platform blocking, banking channel closure (as Vietnamese banks gain explicit grounds to refuse transactions), disgorgement of profits from serving Vietnamese users without authorization, and criminal referral for AML violations and unlicensed operations. Additionally, an enforcement action by Vietnamese authorities may attract scrutiny from regulators in the exchange’s home jurisdiction or other markets where it operates.

Outlook

Decree 284 takes effect on September 1, 2026. All Vietnamese users must migrate their trading activities to licensed local exchanges within six months after the first local exchange is licensed or face penalties. Offshore exchanges should get ahead of this and plan accordingly.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.