Required content of money laundering risk management process in Vietnam

Required content of money laundering risk management process in Vietnam
Le Truong Quoc Dat

On July 28, 2023, the State Bank of Vietnam issued Circular 09/2023/TT-NHNN guiding Law on Anti-Money Laundering, which specifies the required content of money laundering risk management process.

Required content of money laundering risk management process in Vietnam

Based on money laundering risk assessment and update results under the regulations in Vietnam, reporting entities shall develop and promulgate internal money laundering risk management procedures.

Money laundering risk management procedures must be a step-based process appropriate to operational scale, scope, and characteristics of reporting entities which serves to manage money laundering risks.

Money laundering risk management procedures must contain:

- Scope and objectives of money laundering risk management;

- Identified and evaluated impact level of money laundering risks at reporting entities;

- Low, moderate, high customer risk ratings which are determined by reporting entities based on: customers; products, services used or to be used by customers; geographic locations of customers’ residence or head office and other factors depending on practical situations, and stated under risk management procedures;

- Procedures for identifying and assessing money laundering risks before providing new products and services; existing products and services applying new, innovative technology;

- Risk management procedures for executing, rejecting, suspending, controlling post-transaction, reviewing, reporting suspicious transactions for electronic fund transfers that contain inaccurate or inadequate required information;

- Measures taken corresponding to customer risk ratings, including customer identification information update and verification frequency, level of supervision of customers’ transactions corresponding to money laundering risk levels, simplified due diligence and enhanced due diligence as prescribed.

More details can be found in Circular 09/2023/TT-NHNN effective as of July 28, 2023.

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