A regulated digital asset exchange in Vietnam moved from speculation to policy with Decree 323/2025/ND-CP, which directs the Da Nang location of the international financial centre to pioneer and expand digital asset products, digital payments, trading platforms and specialised exchanges. For an industry that has spent three years being pushed out of one Asian jurisdiction after another, a state that is actively inviting the sector is a material development.
What the mandate covers
The decree language is deliberately broad: digital asset products, digital payments, trading platforms and specialised exchanges, supported by supply chain finance, third-party services and non-deposit-taking lenders as complements to the traditional market. A digital asset exchange sits at the centre of that list rather than at its margins.
Behind the mandate sits the enabling provision – the ability to pilot models for which Vietnamese law has no rule, with liability exemption for good-faith implementation, as our fintech sandbox guide explains. That combination is what makes the proposition credible: an activity the law does not yet define, conducted with an express safe harbour, inside a supervised perimeter.
The four questions operators must answer
1. Custody
Who holds client assets, under what segregation, with which key management architecture and what insurance. Every serious digital asset exchange failure of the past cycle traces to custody rather than to trading technology, and supervisors know it.
2. Client money and settlement
Fiat legs interact with the currency regime, which is why our IFC foreign exchange guide should be read alongside this one. Mapping which settlement flows sit inside the perimeter is the first design decision, not an afterthought.
3. Listing and market integrity
Asset listing criteria, surveillance for manipulation, disclosure standards and a documented delisting process. These are the elements that distinguish an exchange from a venue.
4. AML and sanctions
Vietnam is responsive to international transparency standards, and a digital asset exchange licensed here will be expected to meet them fully. Under-investing in this function is the fastest route to losing a licence.
Why Da Nang rather than elsewhere
Three reasons. The mandate is explicit rather than tolerated. The cost base for engineering and compliance staff is a fraction of Singapore or Hong Kong, and the Da Nang financial centre can begin operations in existing buildings. And the licence carries identical authority to one issued in Ho Chi Minh City, because standards are uniform across both locations under the international financial centre framework.
Digital asset exchange FAQs
Is a digital asset exchange legal in Vietnam today?
Outside the centre the position remains restrictive and unsettled. The point of the centre is that it creates a defined space where such activity can be conducted with regulatory sanction rather than in ambiguity. Operators should not extrapolate from inside the perimeter to outside it.
What licensing route applies?
Application runs through the centre’s membership process under the fintech and innovation priority category, with sandbox authorisation where the product has no existing licensing home – see our membership guide.
How should international operators approach entry?
Engage before designing the entity. Custody model, settlement architecture and group structure all interact with licensing, tax and currency treatment, and they are far cheaper to align at the outset. Framework texts are published via the Ministry of Finance.
Building the digital asset exchange operating model first
Operators who succeed in new jurisdictions share a habit: they design the operating model first and shape the licence application around it, rather than obtaining permission and then discovering the permission does not fit the business. For a digital asset exchange that means fixing five things early. The matching engine and its location, because latency, resilience and data residency all carry regulatory weight. The custody stack, including whether hot and cold segregation is operated in-house or through a qualified third party.
The banking chain for fiat legs, agreed in writing with named institutions rather than assumed. The surveillance vendor and the escalation path when an alert fires. And the treasury policy governing the exchange’s own balance sheet, which is where several high-profile failures actually originated.
Each digital asset exchange decision has a legal consequence. In-house custody attracts a heavier prudential expectation than delegated custody. Offshore matching raises questions about where the regulated activity occurs. A single banking relationship creates a concentration risk supervisors dislike. Bringing counsel into these choices while they are still reversible is the difference between a licence that authorises the intended business and one that authorises a narrower version of it.
Realistic digital asset exchange timelines
Operators should budget six to twelve months from first engagement to authorised launch for a substantive venue, with the preparation phase – entity, custody design, policies, banking – consuming most of it. Teams arriving with a documented operating model and a completed risk assessment move materially faster than teams arriving with a pitch deck, and a digital asset exchange is judged on operational credibility rather than on market vision.
This article is provided for general information only and does not constitute legal advice for any specific case. Regulations may change – please consult a qualified professional before acting. Should further analysis be required, please contact one of our lawyers below.
