Market Structure and Products: What Can Be Traded, Cleared, and Settled in the VIFC

Reading the product map#

International financial centres are defined by what you can do inside them. The legal framework matters, the tax incentives matter, the governance structure matters — but the question that determines whether capital actually flows through a centre is: what products and services can be originated, traded, cleared, and settled here?

The VIFC's answer to that question is unusually broad for a centre that has been operational for less than three months. Resolution 222 and the eight implementing decrees authorise a product range that extends well beyond the conventional banking-securities-insurance triad. The priority sector annex to Decree 323 names specific product categories with a level of detail that most IFC frameworks delegate to subordinate rules issued years after launch.

This guide walks through the full product universe, organised by market segment. For each segment, it identifies the legal basis, the current state of infrastructure, and the practical questions that remain open. The honest assessment is that the VIFC has created an ambitious legal canvas with relatively little painted on it yet. But for firms evaluating early-mover opportunities, understanding that canvas is the starting point.

Banking and money markets#

What the framework permits#

The VIFC creates a distinct category of IFC member banks — commercial banks and foreign bank branches licensed to operate within the IFC under a more flexible regime than Vietnam's domestic banking rules. Under Decree 329 and Circular 72, IFC member banks can:

Conduct foreign currency transactions with IFC members and offshore counterparties without the standard Vietnamese dong conversion requirements. Offer foreign currency capital accounts and payment accounts under a dual-track system. Provide cross-border lending and borrowing with streamlined declaration-based procedures (replacing the standard SBV registration process). Apply their parent entity's accounting standards, debt classification, risk provisioning, and prudential ratios — rather than Vietnam's domestic standards — subject to SBV approval.

Resolution 222 also authorises the development of money market products within the IFC, and the VIFC-HCMC website identifies an "International Interbank and Global Financial Infrastructure" hub as one of four strategic pillars. The vision is an interbank system connecting IFC member banks to global financial institutions, payment systems, and cross-border capital flows, optimised through blockchain and smart contracts.

What exists today#

Several of the VIFC's founding and strategic members are major Vietnamese commercial banks — MB, TPBank, SHB — that may seek IFC member bank status. No international bank has publicly committed to establishing an IFC member bank branch. The interbank system is a stated objective with no operational infrastructure. The SBV has issued Circular 72 providing the FX framework, but detailed member bank licensing procedures and prudential guidelines are still being developed.

Key constraint#

Domestic commercial banks seeking to buy or sell foreign currency-denominated bonds abroad through the IFC must demonstrate three consecutive years of profitability (independently audited, no exceptions), fulfilment of all tax obligations, and compliance with safety ratios. The transaction volume cannot exceed 7% of equity capital. This is not a blanket liberalisation — it is a supervised opening with clear risk guardrails.

Capital markets and securities#

What the framework permits#

Resolution 222 and Decree 324 authorise a comprehensive capital markets ecosystem within the IFC:

Equities and bonds. Stocks, bonds, and fund certificates can be issued and traded within the IFC. The framework permits the establishment of securities exchanges and trading platforms separate from Vietnam's existing Ho Chi Minh City Stock Exchange (HOSE) and Hanoi Stock Exchange (HNX).

Financial derivatives. The priority sector annex explicitly lists financial derivatives as a development priority. This covers standardised exchange-traded products as well as over-the-counter structures.

Fund management and asset management. Investment funds and asset management entities are eligible for IFC membership. Decree 324 provides the regulatory basis for fund operations, including the application of international accounting standards (IAS/IFRS).

Crowdfunding. Resolution 222 introduces an equity crowdfunding mechanism — a licensed platform for capital-raising by innovative startups through private placement or crowdfunding. This is one of the more novel provisions; Vietnam's general legal framework does not have a comprehensive crowdfunding regime.

Green finance instruments. The framework authorises market organisation, support services, and trading of green and ESG debt and equity instruments, green/ESG financial products, and green certification services. This includes green bonds, sustainability-linked loans, and ESG-compliant investment funds.

What exists today#

No securities exchange or trading platform has been established within the VIFC. No fund management entity has publicly announced operations. The crowdfunding mechanism has not been operationalised. Green finance is referenced as a priority but no green bond has been issued through the IFC framework.

Vietnam's existing capital market infrastructure — HOSE, HNX, and the Vietnam Securities Depository and Clearing Corporation (VSDC) — operates outside the IFC framework. Whether and how the IFC's capital market infrastructure will connect to or operate alongside these existing institutions is one of the open structural questions.

Benchmark comparison#

The DIFC's capital markets ecosystem took years to mature. NASDAQ Dubai (originally DIFX) launched in 2005 but remained a small venue for years before gaining traction with sukuk listings and dual-listed equities. GIFT City's exchange infrastructure is still nascent after a decade. The AIFC's Astana International Exchange reached $2 billion in trading turnover in 2025 — seven years after launch. Capital markets infrastructure is the hardest component of an IFC to build, because liquidity begets liquidity and new venues face a cold-start problem.

Insurance and reinsurance#

What the framework permits#

Insurance and reinsurance enterprises are explicitly listed as eligible IFC members under Resolution 222. Decree 324 provides the regulatory framework for insurance operations within the IFC, including:

Establishment of insurance and reinsurance companies under the IFC's dedicated licensing regime. Application of international accounting and actuarial standards. Cross-border reinsurance placement with reduced regulatory friction compared to Vietnam's domestic insurance regime.

The priority sector annex includes aviation insurance and marine insurance as specific development priorities, linked to the VIFC-HCMC's Aviation Financial Hub and Maritime Financial Hub strategies.

What exists today#

No dedicated insurance or reinsurance entity has been announced as a VIFC member. The Aviation Financial Hub announcement (February 7, 2026) referenced aviation insurance as a component of the $6.1 billion mobilisation target, but no specific insurer commitments have been made public.

Vietnam's domestic insurance market is regulated by the Ministry of Finance under the Insurance Business Law. The interaction between this domestic regime and the IFC's insurance framework — particularly for reinsurance ceded offshore — is an area where implementing guidance is needed.

Commodity exchanges and derivatives#

What the framework permits#

Decree 330 provides the most detailed product framework of any single decree. It creates a dedicated legal basis for commodity exchanges within the IFC, permitting:

Commodity trading platforms. Establishment of organised exchanges for physical commodities and commodity derivatives. The framework covers futures, options, and other derivative instruments.

Tradeable products. The scope is deliberately broad. Resolution 222 authorises trading of commodities, commodity derivatives, carbon credits, cultural and artistic products (structured as NFTs), rare metals, and green financial products. Da Nang's development plan specifically targets a centralised commodity exchange for base metals linked to global markets.

Carbon credits. The framework authorises establishment of a carbon credit exchange. Da Nang's Executive Authority has identified a pilot carbon credit exchange as one of two or three specialised exchanges it plans to explore, with the aim of directing investment toward sustainability-focused projects.

NFT-structured cultural products. One of the VIFC's more distinctive provisions: Decree 330 clarifies that cultural and artistic products structured as non-fungible tokens are tradeable on commodity exchanges. This creates a regulated pathway for NFT trading that does not exist under Vietnam's general legal framework.

What exists today#

No commodity exchange has been established within the VIFC. No carbon credit trading platform exists. No NFT marketplace operates under the Decree 330 framework.

Da Nang has signalled intent to move first on specialised exchanges, consistent with its innovation-driven orientation. The base metals commodity exchange concept is linked to the Da Nang Free Trade Zone and the broader logistics infrastructure including the Lien Chieu deep-water port (under development). But these are stated plans, not operational realities.

Why this matters for commodity practitioners#

Vietnam is the world's second-largest coffee producer, a major rice exporter, and a significant player in rubber, pepper, cashews, and seafood. It has substantial rare earth mineral deposits. The domestic commodity derivatives market is underdeveloped — most Vietnamese commodity hedging occurs offshore through Singapore or Hong Kong intermediaries.

A functioning commodity exchange within the VIFC could capture a portion of this flow. The combination of commodity derivatives with the IFC's FX liberalisation (allowing foreign currency settlement between members) and the planned free trade zone connectivity in Da Nang creates, on paper, a compelling proposition for physical commodity traders and their financial counterparts.

The practical challenge is that commodity exchanges require liquidity, and liquidity requires market makers, clearing infrastructure, price discovery mechanisms, delivery logistics, and warehouse receipt systems. None of this exists yet. The Decree 330 framework is a foundation, not a market.

"Vietnam is essentially building a financial centre and a commodity market simultaneously — something most countries have done sequentially over decades." — A regional commodity exchange executive, speaking at a January 2026 industry conference

Digital assets, fintech, and the sandbox#

What the framework permits#

Digital assets occupy a unique position in the VIFC's architecture — they are named as a founding priority, not an afterthought. The Decree 323 priority sector annex explicitly lists:

Digital asset infrastructure and products, including decentralised finance (DeFi) protocols. Asset tokenisation — converting real-world assets (property, commodities, receivables) into blockchain-based tokens. Stablecoins — both fiat-backed and algorithm-based varieties. Web3-based applications in financial services. Regulatory technology (regtech) for compliance and surveillance. Non-fungible tokens as tradeable cultural and artistic products.

The sandbox mechanism, established by Resolution 222 and detailed in Decree 324, provides the testing environment for products and business models not yet prescribed by Vietnamese law. Sandbox licences can be issued for up to five years by the IFC Executive Authorities. Participants receive liability shields — exemption from liability for damage to the state during the testing period.

Additionally, the national crypto pilot under Resolution 05/2025/NQ-CP operates in parallel. The Ministry of Finance began accepting licence applications for crypto trading platforms in January 2026 under Decision 96/QĐ-BTC. This creates two concurrent regulatory pathways for digital asset activities in Vietnam.

What exists today#

Da Nang approved its first sandbox trial — Basal Pay, a digital asset conversion project — making it the first sandbox participant in the VIFC. Binance signed an MOU with the HCMC Department of Finance in November 2025. The MOF is processing crypto trading platform licence applications under the national pilot.

No digital asset exchange operates within the VIFC. No tokenisation platform has been licensed. No stablecoin issuer has received approval. The sandbox implementing rules — the specific admission criteria, testing boundaries, consumer protections, and exit procedures — have not been formally published by the IFC Executive Council, though Da Nang's approval of Basal Pay suggests the Executive Authorities are willing to act ahead of the formal framework.

The parallel-framework question#

Firms interested in digital assets in Vietnam now face a structural choice: operate under the national pilot (MOF-supervised, nationwide scope, specific licensing requirements) or within the VIFC sandbox (IFC Executive Authority-supervised, geographically limited to IFC zones, potentially broader product scope). Whether firms can operate under both simultaneously, and how the two frameworks interact, is not yet clear. This is one of the most consequential open questions for digital asset operators evaluating Vietnam.

Aviation and maritime finance#

What the framework permits#

Two of the VIFC-HCMC's four strategic pillars are sector-specific financial hubs that represent distinct product categories:

Aviation Financial Hub. Aircraft purchase financing, leasing and hire-purchase, aviation insurance, aviation logistics finance, and transport-linked derivatives. The model follows established IFC precedents — the DIFC hosts multiple aircraft leasing operations, and GIFT City has attracted 33 registered lessors with 242 aviation assets.

Maritime Financial Hub. Trade finance, ship financing, marine insurance, logistics finance, and global supply chain finance. This leverages Vietnam's position as a major trading nation (goods exports exceeding $370 billion in 2024) with an extensive coastline and developing port infrastructure.

What exists today#

The Aviation Financial Hub was formally announced on February 7, 2026, with Vietjet and VIFC-HCMC citing $6.1 billion to be mobilised through the IFC. Boeing, Airbus, and IATA were named as supporting partners. The Maritime Financial Hub is referenced on the VIFC-HCMC website as a development priority.

These are the most commercially advanced of the VIFC's product verticals — not because exchanges or platforms exist, but because they are linked to existing Vietnamese industries with demonstrated demand for financial services. Vietnam's airlines (Vietjet, Vietnam Airlines, Bamboo Airways) have historically financed aircraft through Singapore, Hong Kong, or Dublin-based structures. The VIFC offers a pathway to repatriate a portion of this activity.

Clearing, settlement, and market infrastructure#

What the framework permits#

The priority sector annex includes a specific line item for the "construction and operation of multi-asset depository, clearing, and settlement centres." This signals intent to build post-trade infrastructure within the IFC — the plumbing that makes trading possible.

Resolution 222 also authorises "entities organising market infrastructure" as eligible IFC members. This covers exchanges, clearing houses, central securities depositories, trade repositories, and payment system operators.

What exists today#

No clearing house, central counterparty, or securities depository has been established within the VIFC. Vietnam's existing post-trade infrastructure (VSDC) operates outside the IFC framework.

This is the gap that matters most. Trading platforms can be built relatively quickly. Clearing and settlement systems — with their requirements for risk management, margining, default waterfalls, interoperability with global systems, and regulatory recognition — take years to develop and require significant capital commitment. Until clearing infrastructure exists, the VIFC's product framework remains aspirational for exchange-traded products.

For over-the-counter products (bilateral contracts, structured products, bespoke derivatives), clearing infrastructure is less critical. OTC activity can commence once counterparties, legal documentation standards, and master agreement frameworks are in place. This is likely where the VIFC's market activity will begin.

The product matrix#

To give practitioners a single reference point, the following matrix maps the VIFC's product universe against its current state of readiness:

The pattern is clear: banking, digital asset sandboxes, and sector-specific finance (aviation) are the near-term opportunities. Exchange-traded products — securities, derivatives, commodities — require infrastructure that does not yet exist and will take years to build. OTC activity sits in between: legally possible now, practically dependent on counterparties establishing operations.

What to watch#

First IFC member bank licensing. The first Vietnamese bank to receive formal IFC member bank status will signal that the SBV's implementing machinery is operational. This is the prerequisite for most other market activity.

Da Nang's specialised exchanges. Da Nang has committed to exploring two or three specialised exchanges (digital assets, carbon credits, base metals). The first formal exchange licence application will be a significant market structure milestone.

Clearing house establishment. Any announcement of a central counterparty or clearing house — whether domestic or through a partnership with an international clearing organisation — would transform the VIFC from a regulatory framework into a functioning market.

International master agreement adoption. For OTC markets, the adoption of ISDA documentation standards (or equivalent) within the IFC framework, combined with the Specialised Court and International Arbitration Centre's ability to enforce such agreements, would enable bilateral trading well before exchange infrastructure is built.

First green bond issuance. Vietnam has significant green finance demand (energy transition, infrastructure, climate adaptation). The first green bond issued under the IFC framework would open a product category with strong international investor appetite.

This guide will be updated as market infrastructure is established and product offerings are announced. Last verified: February 15, 2026.