SBV Formalises VND Correspondent Accounts for Foreign Banks, Effective September 19

Circular No. 39/2026/TT-NHNN, signed by State Bank of Vietnam Deputy Governor Pham Thanh Ha on August 5, 2026, amends Circular 16/2014/TT-NHNN to insert a new Article 2a — the first explicit black-letter permission for non-resident foreign credit institutions to process international customer payments through accounts held at Vietnamese licensed banks. It takes effect September 19, leaving institutions six weeks to get agreements in place.

What Circular 16/2014 Left Unresolved#

Circular 16/2014/TT-NHNN has governed how residents and non-residents use accounts at Vietnamese licensed banks for over a decade. Its coverage of resident transactions was reasonably complete. What it did not address explicitly was whether a non-resident foreign credit institution — a Korean commercial bank, a Singaporean trade finance house, a UAE lender — could open accounts at a Vietnamese bank specifically to route international payment and money-transfer transactions on behalf of its own customers.

That omission mattered. Foreign banks wanting to use Vietnam-domiciled accounts as settlement or clearing nodes occupied a grey zone: account-opening was technically possible, but the specific right to process third-party customer flows through those accounts was not codified. Compliance teams at both the foreign institution and the Vietnamese correspondent bank faced uncertainty about whether the arrangement fell within or outside the existing framework.

Circular 39 closes that gap with a single new article.

What Article 2a Permits — and Requires#

The core addition is direct: non-resident foreign credit institutions may use both foreign-currency accounts and VND accounts at Vietnamese licensed banks to conduct international payment and money-transfer transactions for their own customers.

The VND permission is the more consequential half. Foreign-currency correspondent accounts have operated under existing practice in Vietnam, as in other markets. A VND correspondent account — allowing a foreign bank to receive, hold, and remit Vietnamese dong on behalf of its customers through a Vietnamese counterpart — addresses a different structural problem: VND-denominated cross-border trade flows that currently require USD-intermediated clearing. Circular 39's Article 2a removes that intermediation step for qualifying transactions.

Two conditions attach to the new right. First, the foreign institution and the Vietnamese licensed bank must have a written agreement in place before international customer payments flow through the account. The circular mandates the agreement but does not — at least in the text published to the official gazette — specify minimum content requirements. Whether the SBV will issue implementing guidance on agreement formats remains open; institutions should not assume a template is forthcoming before September 19.

Second, all transactions must comply with Vietnamese foreign-exchange management law, specifically as grounded in Decree No. 70/2014/ND-CP, which the circular explicitly cites as its legal basis for the VND account permission.

The transactional scope for these accounts mirrors the existing Articles 5 and 7 of Circular 16/2014 — collection and spending transactions as already specified in those provisions — with the international payment and transfer right added on top.

Liability Rests with the Vietnamese Bank#

Amended Article 9 of Circular 16/2014 makes the Vietnamese licensed bank the primary bearer of legal responsibility for payment and money-transfer services conducted through non-resident foreign bank accounts. That responsibility cannot be contracted away to the foreign counterpart.

In practice, this means Vietnamese licensed banks acting as correspondent principals must specify, examine, and retain transaction documentation for the flows running through these accounts. Non-cash payment law, FX management law, and Vietnam's AML/CFT/counter-proliferation-financing obligations apply in full — to the licensed bank, to the foreign credit institution, and to all related organisations and individuals involved in the transaction chain.

For compliance teams at banks such as Vietcombank and Techcombank that already hold non-resident foreign bank accounts, the amended Article 9 formalises a liability position many have operated under informally. The difference from September 19 is that the framework is now explicit law, not practice by convention.

How This Fits the Broader VIFC Stack#

Circular 39 does not reference the VIFC by name. Its scope is national — any Vietnamese licensed bank, any non-resident foreign credit institution. But its timing and its subject matter place it squarely within the infrastructure build-out that VIFC-bound institutions need.

Decree No. 329/2025/ND-CP established the licensing menu for foreign banks entering the VIFC: representative office, branch, or subsidiary. What Decree 329 did not resolve was the operational account infrastructure those institutions need once licensed — specifically how they process cross-border customer flows before or alongside their VIFC entity's own operations.

Circular 39 provides that infrastructure. Together with Circular 72/2025/TT-NHNN (the dual-track FX framework for VIFC members, covered in our Circular 72 guide) and the SBV's Circular 34/2026 on outbound FX, the three instruments form the FX and payments plumbing stack that foreign institutions entering Vietnam — whether through the VIFC or as conventional licensed branches — need to understand as one coherent body of rules.

Whether VIFC-member foreign banks receive any enhanced terms or carve-outs under the new correspondent account framework relative to non-VIFC foreign banks is not addressed in Circular 39's text. That interaction with Decree 329's VIFC-specific provisions remains unsettled and warrants clarification from the SBV before institutions design their operating models.

Who Needs to Act Before September 19#

Foreign credit institutions that currently hold accounts at Vietnamese licensed banks and use them to process international customer payments need to verify whether a written bilateral agreement is in place that satisfies Circular 39's requirements. Processing flows without such an agreement is non-compliant from September 19.

Foreign institutions evaluating VIFC entry — particularly those in the Korea, Japan, Singapore, and UAE corridors that have publicly flagged interest in using Vietnam as a regional settlement node — now have explicit legal basis for the account structure. The written agreement requirement means that preparation work with prospective Vietnamese correspondent banks should begin now, not after licensing.

Vietnamese licensed banks holding non-resident foreign credit institution accounts must review their existing account documentation and update agreements to reflect the new framework before the effective date. The direct liability provision in amended Article 9 elevates AML/CFT documentation requirements from best practice to legal obligation.

What Remains Open#

Three questions the circular does not answer:

The agreement content standard — the circular requires a written agreement but does not prescribe minimum terms. Institutions negotiating these agreements before September 19 should build in provisions covering transaction monitoring, documentation retention, and FX compliance procedures, given that the Vietnamese bank cannot disclaim Article 9 liability regardless of what the agreement says.

The VIFC interaction — whether the new Article 2a right applies differently inside the VIFC zone, and whether it interacts with Decree 329's FX liberalisation provisions for VIFC members, is not addressed. This matters for institutions that plan to route international flows through a VIFC entity rather than through a conventional correspondent account.

The VND volume or transaction-type scope — the circular is permissive on its face, but any practical caps on what can flow through VND correspondent accounts appear to rest in the bilateral written agreements and in FX management regulations, not in Circular 39 itself. Institutions should seek SBV guidance on whether quantitative restrictions apply.

What to Monitor#

The six-week implementation window is short. Institutions should watch for SBV guidance on agreement formats and for any clarification on how Circular 39 interacts with the VIFC's distinct FX and banking entry framework under Decree 329. If no guidance appears before September 1, institutions should proceed on the basis of the circular's text alone and engage directly with the SBV or qualified Vietnamese legal counsel on agreement structure.

This article was last updated on 10 August 2026. We will update it when the SBV issues implementing guidance on bilateral agreement requirements or clarifies the circular's interaction with the VIFC framework.