Agenda
02
Part I
Fintech Business
in Vietnam
Part II
Vietnam Regulation on
Selected Fintech Sectors
Part I
Fintech Business in
Vietnam
Fintech ecosystem
in Vietnam
03
Funds raised by
Fintech Startups
Fintech in Vietnam
Population size (2021)
Urban population (2021)
Unemployment rate (2021)
Population have saving (2020)
Internet penetration rate (2020)
Smartphone penetration rate (2020)
98.5 million
36.6 million
3.2%
69%
70%
62% (2025, 85%)
FinTech ecosystem in Vietnam is developing fast, with more
than 200 companies in operation
2019, Vietnam ranks second in Asean in terms of fintech
funding, attracting 36% of region’s fintech investment
Q1-2020, electronic payments increased by 76%, total value of
transactions jumping 124% compared to Q1-2019
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Fintech in Vietnam
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Source: fintechnew.sg
Fintech in
Vietnam
Funds raised by
Fintech Startups
Jan 2019, Momo raised $100 mil in the Series C funding
rounded by Warburg Pincus
Apr 2019, Utop secured a $3 mil investment from FPT and SBI
Holdings
Jul 2019, e-wallet VNPAY's parent company raised $300 mil
from SoftBank's Vision Fund and GIC
Nov 2019, Axie Infinity raised $1.5 mil from Pangea Blockchain
Fund, Hashed, ConsenSys, and 500 Startups
Dec 2019, Interloan secured $500,000 in investment from
Phoenix Holdings
(Source: fintechnews.sg)
Sep 2020, Fvndit raised $30 mil for its Vietnamese P2P lending
firm
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Part II
Vietnam Regulation on
Selected Fintech Sectors
Regulators
Sandbox mechanism
07
Payment
P2P lending
Data protection, cybersecurity,
electronic transactions
Blockchain
Anti-money laundering
& Anti-terrorism
Vietnam Regulation
Fintech Regulators
State Bank of Vietnam (SBV): licensing mechanism, fintech business activities, problems arising
Ministry of Information and Communication (MIC): fintech standards, certificate of technical eligibility,
technical standards on application for pilot license
Ministry of Science and Technology (MST): fintech standards, certificate of technology eligibility and
technology solutions
Ministry of Planning and Investment (MPI): conditions on charter capital and ownership structure of
fintech firms
Ministry of Public Security (MPS), Ministry of Finance (MoF), and Ministry of Industry and Trade (MIT):
co-ordinate with SBV to give opinions on application for pilot license
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Vietnam Regulation
Payments
E-wallets
Require a bank account to use and pay
Maximum transaction: VND100 mil/month/account
(around $4,000)
Regulatory: Degree 80/2016/ND-CP, Cir
39/2014/TT-NHNN, Cir 23/2019/TT-NHNN
Business eligible: (i) commercial banks, (ii) foreign
bank branches, non-credit institutions having
minimum charter capital of VND50 bil ($2 mil) &
appropriate technical and IT system
Foreign investor: no limitation
20 e-wallets available, Momo, ZaloPay, AirPay
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Mobile Money
Does not require a bank account to use and pay
Maximum transaction: VND10 mil/month/account
(around $400)
Prime Minister approved 2-year-pilot application
Business eligible: (i) intermediary e-wallet
payment services, (ii) telecommunications
network
Foreign investor: 1st license no limitation, 2nd
license joint venture with capital not exceed 49%
3 carriers participating pilot: Viettel, VNPT,
Mobifone
Vietnam Regulation
P2P Lending
Not governed by specific legislation in Vietnam
In practice, fintech companies operate P2P lending obtain enterprise registration certificates with general
business lines of supporting financial services
Comply with Civil Code 2015, Law on Investment 2020 and Law on Enterprises 2020
Lending interest rate be agreed but must not exceed 20%/year of loan under Civil Code
Sandbox: P2P lending is part of 2-year pilot ---> P2P lending companies must register to operate in new pilot
mechanism, or will be suspended
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Vietnam Regulation
Blockchain
No clear legal framework in Vietnam on blockchain
Sandboxing mechanism for blockchain, small-scale testing platform with a select number of monitored service
providers
2018, banks and payment service intermediary companies experimented with implementing blockchain
technology in interbank money transfer transactions
2019, Blockchain technology has been applied in international payments in Vietnam market, beginning with
letter of credit (L/C) transaction of HSBC's Vietnamese branch via Voltron
Blockchain assets/blockchain currencies are not listed as recognised financial instruments & prohibited by
SBV
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Vietnam Regulation
Sandbox mechanism
Controlled testing mechanism (sandbox) for fintech activities
First introduced in Decision No 999/QD-TTg dated 12 Aug 2019, limited-time testing of novel platformprovisioning activities & creativity of the technology business
New Law on Investment creates room to recognise new forms of investment in sandbox
Second draft of Decree on Regulatory Sandbox for Fintech activities be released in Apr 2022, expect to be
effective in 2022
7 fintech solutions be applied on pilot basis: payment, credit, P2P lending, eKYC, open API, innovative
technology application solutions (blockchain), other supporting services
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Vietnam Regulation
Data protection, cybersecurity, electronic transactions
Law on Cyberinformation Security, 2015; Fintech businesses:
Duties in relation to collection, storage and usage of data within the scope of consent
Duties to have adequate systems in place to protect the collected data
Law on Electronic Transactions, 2006; Fintech businesses:
Take necessary measures to verify the reliability of an e-signature before accepting it
Take necessary measures to verify the legal validity of an e-certificate
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Vietnam Regulation
Anti-Money Laundering (AML) & Anti-terrorism
Law on Anti-Money Laundering 2012, Decree 116/2013/ND-CP, Decree 87/2019/ND-CP
Fintech providers are liable as gatekeepers in AML, having duties to collect information, carry out KYC, screen
suspicious and high-value transactions, report to SBV
Obligation to report to authorities on anti-terrorism if they discover transactions of blacklisted individuals,
transactions related to terrorism/terrorist organisations
Large-value transactions (more than VND300 mil, around $12,000), suspicious transactions
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Vietnam’s fintech industry has grown significantly (i)
rising adoption of digital transactions & (ii) booming ecommerce industry
Conclusion
E-wallets and online payments are the leaders,
followed by P2P lending and blockchain entities
Legal framework, in the process of developing
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