As Vietnam actively participates in the global economic system, anti-money laundering (AML) has become a critical component of enterprise compliance management that cannot be ignored. Whether for local enterprises or multinational companies, establishing robust anti-money laundering mechanisms is not only a legal requirement but also a necessary measure to win customer trust and protect the enterprise.

However, with the increasingly complex financial environment and constantly updated regulatory requirements, many enterprises feel at a loss. How can one effectively assess whether their anti-money laundering measures comply with Vietnam’s latest regulations? Which aspects are most easily overlooked? And how can continuous improvement be ensured to maintain long-term compliance?

This guide aims to provide you with a comprehensive and practical framework to systematically assess the compliance of your enterprise’s anti-money laundering measures. We will delve into Vietnam’s latest anti-money laundering regulations, analyze key assessment areas, and provide specific and feasible suggestions. Whether you are a startup just beginning or a mature enterprise seeking to optimize your compliance system, this guide will become your indispensable tool for compliant operations in the Vietnamese market.

Let us work together to maintain the healthy development of Vietnam’s financial system and safeguard the sustainable growth of enterprises.

Overview of Vietnam’s Anti-Money Laundering Legal Framework

Vietnam has undergone dramatic economic transformation over the past decade, accompanied by the rapid development and increasing complexity of its financial system. As an emerging economic powerhouse in Southeast Asia, Vietnam recognizes the importance of establishing a robust anti-money laundering legal framework to maintain national financial security and enhance its international reputation. Therefore, the Vietnamese government has been actively improving its anti-money laundering legal system in recent years to address the increasingly severe risks of money laundering and terrorist financing.

The core of Vietnam’s anti-money laundering legal framework is the Anti-Money Laundering Law of 2012 (Law No. 39/2012/QH13), which laid a solid legal foundation for Vietnam’s anti-money laundering efforts. Additionally, to further detail and strengthen anti-money laundering requirements, the Vietnamese government has issued a series of important regulations, with key ones being Decree No. 20/2019/ND-CP and Decree No. 87/2019/ND-CP of 2019. These regulations not only clarify the anti-money laundering obligations of financial institutions and specific non-financial businesses but also introduce a risk-based approach, requiring enterprises to adopt appropriate anti-money laundering measures based on their risk profiles.

Under this increasingly comprehensive legal framework, enterprises face mounting compliance pressure. Whether local enterprises or multinational companies, all need to establish reliable anti-money laundering internal control mechanisms, including but not limited to customer due diligence, suspicious transaction reporting, and record-keeping. However, establishing these mechanisms is not enough. Enterprises also need to regularly assess the effectiveness of their anti-money laundering measures to ensure they always comply with the latest legal requirements and regulatory expectations.

The importance of assessing anti-money laundering measures goes beyond mere compliance. It directly relates to enterprise risk management, reputation maintenance, and sustainable development. An effective anti-money laundering assessment system can help enterprises identify potential risks in a timely manner, optimize resource allocation, improve operational efficiency, and win the trust of customers and partners in fierce market competition. Moreover, against the backdrop of Vietnamese regulatory authorities significantly strengthening enforcement efforts, proactive and comprehensive anti-money laundering assessments can also help enterprises demonstrate initiative in potential regulatory inspections.

Legal Foundations in Vietnam

Vietnam’s anti-money laundering legal system is built on a multi-tiered framework, with its core consisting of the 2012 Anti-Money Laundering Law and its subsequent amendments, as well as two key implementing decrees. This framework not only provides a comprehensive legal basis for Vietnam’s anti-money laundering efforts but also reflects the Vietnamese government’s active response to international anti-money laundering standards.

The 2012 Anti-Money Laundering Law (Law No. 39/2012/QH13) is the cornerstone of Vietnam’s anti-money laundering system. This law systematically defined money laundering behaviors for the first time, clarified the basic principles and measures for anti-money laundering, and stipulated the anti-money laundering obligations for various financial institutions and specific non-financial businesses. The law requires enterprises to establish reliable customer identification systems, implement risk assessments, report large and suspicious transactions, and maintain relevant records. The 2020 amendment further refined these provisions, particularly adding new requirements in risk assessment and international cooperation to address evolving money laundering risks and international standards.

Decree No. 20/2019/ND-CP is an important supplement to the 2012 Anti-Money Laundering Law. This decree details specific measures for anti-money laundering and counter-terrorist financing. It introduces a risk-based approach, requiring enterprises to adopt appropriate anti-money laundering measures based on their business characteristics and risk profiles. The decree also clarifies the standards and procedures for suspicious transaction reporting, as well as specific requirements for internal control and training. This provides clearer guidance for enterprises to formulate and implement anti-money laundering policies.

Decree No. 87/2019/ND-CP focuses on customer due diligence (CDD), a core stage of anti-money laundering work. This decree details the procedures for customer identification and verification, including differentiated requirements for customers of different risk levels. It also clearly proposes ongoing monitoring standards, requiring enterprises to regularly update customer information and monitor changes in transaction patterns. Notably, this decree strengthens due diligence requirements for politically exposed persons (PEPs), reflecting Vietnam’s determination to prevent power-related corruption and crime.

These three legal documents collectively construct a comprehensive and systematic anti-money laundering framework. They not only clarify the legal obligations of enterprises but also provide legal basis for regulatory enforcement. This framework embodies Vietnam’s international perspective in anti-money laundering efforts. It incorporates recommendations from the Financial Action Task Force (FATF) while also considering Vietnam’s economic and social environment.

For enterprises operating in Vietnam, a deep understanding of this legal framework is crucial. It is not only a basic requirement for compliance but also a guide for enterprises to formulate anti-money laundering strategies and measures. Enterprises need to establish reliable internal control mechanisms based on the requirements of these regulations, covering various aspects such as risk assessment, customer due diligence, transaction monitoring and reporting, and record-keeping. At the same time, enterprises should closely monitor updates and interpretations of these regulations to ensure their anti-money laundering measures always comply with the latest legal requirements.

By comprehensively complying with this legal framework, enterprises can not only effectively prevent money laundering risks but also contribute to the healthy development of Vietnam’s financial system, while laying a solid foundation for their own sustainable development in the Vietnamese market.

Key Areas for Assessing Enterprise Anti-Money Laundering Measures

When assessing an enterprise’s anti-money laundering measures, there are 5 key areas that need focused attention. These areas not only reflect the core requirements of Vietnam’s anti-money laundering regulations but are also crucial for enterprises to effectively defend against money laundering risks. Let’s delve into the specific content and assessment points of each area.

1. Risk Management

Risk assessment is the foundation of the entire anti-money laundering system. Enterprises must establish a comprehensive internal risk assessment procedure to identify, analyze, and understand the money laundering and terrorist financing risks they face. This procedure should consider multiple factors, including customer types, geographical areas, product and service characteristics, and delivery channels.

During assessment, focus should be on whether the enterprise has established a systematic risk assessment method and whether it covers all relevant risk factors. The frequency and scope of risk assessments are equally important. According to Vietnamese regulatory requirements, enterprises should conduct a comprehensive risk assessment at least annually, with additional assessments when introducing new products, services, or entering new markets. The assessment process should ensure that risk assessment results are reviewed and approved by senior management and used to guide the allocation of anti-money laundering resources and the formulation of measures.

2. Customer Due Diligence (CDD)

Customer due diligence is the core of anti-money laundering work. Enterprises need to formulate comprehensive CDD policies and procedures, including customer identification, verification, and risk classification. These policies should clearly stipulate when to conduct simplified, standard, or enhanced due diligence.

When assessing CDD measures, focus should be on checking whether the enterprise’s customer identity verification methods comply with Vietnamese regulatory requirements. This includes using reliable, independent documents, data, or information to verify customer identities. For high-risk customers, such as politically exposed persons (PEPs), stricter due diligence measures should be implemented.

Ongoing monitoring is an important component of CDD. Enterprises should establish mechanisms to regularly update customer information, monitor transaction patterns, and ensure transactions are consistent with customer profiles. Assessment should focus on whether the enterprise has the ability to identify abnormal transactions and how to handle these abnormal situations.

3. Suspicious Transaction Reporting (STR)

An effective suspicious transaction reporting mechanism is key to preventing money laundering. Enterprises need to establish clear STR identification criteria, including standards and methods for identifying suspicious transactions. These criteria should cover various possible abnormal situations, such as unusual transaction amounts, frequencies, or transactions inconsistent with customer backgrounds.

Assessment should focus on whether the enterprise’s reporting process is clear and efficient. According to Vietnamese regulations, enterprises must report suspicious transactions to Vietnam’s Financial Intelligence Unit within 48 hours of detection. Therefore, enterprises should establish mechanisms that can timely identify, review, and report suspicious transactions. At the same time, assessment should evaluate whether the enterprise has measures to protect reporters and how to ensure the confidentiality of reports.

4. Record Keeping

Sound record keeping is an important foundation supporting anti-money laundering work. Enterprises should keep a wide range of information types, including customer identity information, transaction records, risk assessment reports, suspicious transaction reports, etc. These records are not only used for internal risk management but also for cooperating with regulatory inspections and law enforcement investigations.

Assessment should focus on whether the enterprise’s record-keeping system complies with Vietnamese regulatory requirements. According to regulations, relevant records should be kept for at least 5 years. At the same time, assessment should evaluate whether the record-keeping method is secure, easily retrievable, and protects customer privacy. Enterprises should be able to quickly provide complete customer and transaction information upon receiving authorized requests.

5. Internal Control

A robust internal control mechanism is key to ensuring the effective implementation of anti-money laundering measures. Firstly, enterprises should designate a senior management member as the anti-money laundering compliance officer, responsible for coordinating and overseeing anti-money laundering work. Assessment should focus on whether the compliance officer has sufficient authority, resources, and independence to fulfill their duties.

Employee training is an important component of internal control. Enterprises should develop comprehensive training programs to ensure all relevant employees understand the latest anti-money laundering requirements and enterprise policies. Training should be tailored to the specific needs of different positions, conducted regularly, and training records should be maintained.

The internal audit mechanism is the last line of defense for anti-money laundering. Enterprises should establish independent audit functions to regularly assess the effectiveness of anti-money laundering measures. Assessment should focus on the frequency, scope, and depth of internal audits, as well as follow-up measures after audit findings.

Through comprehensive assessment of these five key areas, enterprises can fully understand the effectiveness of their anti-money laundering measures, identify potential vulnerabilities and areas for improvement. This not only helps to improve compliance levels but also enhances the overall risk management capabilities of enterprises, laying a foundation for long-term stable development in the Vietnamese market.

Assessment Methods – Document Review – Employee Interviews – System Testing

Assessing the effectiveness of an enterprise’s anti-money laundering measures requires a comprehensive and systematic approach. To ensure the accuracy and comprehensiveness of the assessment, we recommend adopting complementary assessment methods: document review, employee interviews, and system testing. This differentiated approach, when combined, can provide a comprehensive perspective on the actual operation of an enterprise’s anti-money laundering measures. Let’s discuss in detail the specific content and implementation points of each method.

Document review is the foundational stage of the assessment process. It involves a comprehensive review of all relevant anti-money laundering policies, procedures, and records of the enterprise. This includes, but is not limited to, anti-money laundering policy manuals, risk assessment reports, customer due diligence procedures, suspicious transaction reporting mechanisms, training materials, and internal audit reports. When conducting document review, assessors should focus on whether these documents comply with Vietnam’s latest regulatory requirements, whether they are clear, and whether they cover all necessary anti-money laundering areas. At the same time, they should also check whether these policies and procedures are up-to-date and approved by senior management. Document review should also include checking actual implementation records, such as customer files, transaction monitoring records, suspicious transaction reports, etc., to verify whether policies are actually being implemented.

Employee interviews are a means to assess the actual implementation of anti-money laundering measures. Through in-depth communication with employees at different levels and departments, one can understand employees’ level of understanding of key anti-money laundering policies and the actual application of these policies in daily work. Interview subjects should include senior management, anti-money laundering compliance officers, frontline staff, internal audit personnel, etc. During the interview process, assessors should focus on whether employees clearly understand their responsibilities in anti-money laundering work, whether they have received adequate training, and whether they can identify and report suspicious activities. Additionally, they should understand employees’ views on existing anti-money laundering measures, including challenges they encounter in implementation and suggestions for improvement. This first-hand information can help identify potential vulnerabilities in policy implementation, as well as needs in employee training and awareness raising.

System testing is a key method for assessing the effectiveness of anti-money laundering technical infrastructure. This involves actual testing of the enterprise’s IT systems used for customer identity verification, transaction monitoring, risk scoring, and report generation. Assessors should design a series of test scenarios, including simulating different types of customer account openings, conducting various transactions, and creating suspicious activities. Through these tests, they can evaluate whether the system can accurately identify high-risk customers, effectively monitor transactions, and timely detect and report suspicious activities. System testing should also include assessment of data integrity and security to ensure customer information and transaction data are adequately protected. Additionally, assessors should check the system’s report generation functionality to ensure it can timely and accurately generate various reports required by regulators.

When implementing this comprehensive assessment method, it’s important to adopt a holistic perspective, cross-verifying and complementing results from different methods. For example, policies found in document review might be verified as not fully implemented through employee interviews, or system testing might reveal actual operational processes not explicitly stated in documents. Through such cross-verification, strengths and weaknesses in anti-money laundering measures can be more accurately identified.

The assessment process should be continuous and dynamic. It is recommended that enterprises conduct regular assessments and consider inviting external experts to conduct independent assessments to strengthen the perspective of scrutiny. Through regular assessments, enterprises can timely identify and address issues and continuously improve their anti-money laundering systems, ensuring they always comply with regulatory requirements and best practice standards.

Finally, assessment results should be formed into a report, clearly pointing out identified issues and improvement suggestions. This report should be submitted to senior management for review and used to formulate specific action plans. Through a systematic assessment method, enterprises can not only improve compliance levels but also enhance overall risk management capabilities, laying a solid foundation for long-term stable development in the Vietnamese market.

Compliance Scoring Criteria

To systematically assess the effectiveness of an enterprise’s anti-money laundering measures, establishing a comprehensive and accurate scoring criterion is crucial. This criterion not only helps enterprises clearly understand their compliance status but also provides clear directions for continuous improvement. The scoring system is divided into two levels: indicators for each area and overall compliance determination method.

First, let’s explore in detail the scoring indicators for each area. Based on the five key assessment areas mentioned earlier, we have set specific scoring indicators for each area:

1.Risk Assessment (20 points)

• Comprehensiveness and applicability of risk assessment methods (5 points)
• Coverage of risk entities (5 points)
• Assessment frequency and timeliness (5 points)
• Application of assessment results and implementation (5 points)

2.Customer Due Diligence (CDD) (25 points)

• Comprehensiveness of CDD policies and procedures (5 points)
• Effectiveness of customer identity verification methods (5 points)
• Accuracy of risk classification (5 points)
• Effectiveness of ongoing monitoring measures (5 points)
• Appropriateness of additional measures for high-risk customers (5 points)

3.Suspicious Transaction Reporting (STR) (20 points)

• Comprehensiveness of STR identification criteria (5 points)
• Clarity and efficiency of reporting processes (5 points)
• Timeliness of reporting (5 points)
• Quality and completeness of reports (5 points)

4.Record Keeping (15 points)

• Comprehensiveness of record scope (5 points)
• Compliance with retention periods (5 points)
• Ease of retrieval and security of records (5 points)

5.Internal Control (20 points)

• Authority and responsibilities of AML compliance officer (5 points)
• Comprehensiveness and effectiveness of employee training programs (5points)
• Independence and adequacy of internal audit mechanisms (5 points)
• Timeliness and effectiveness of issue rectification (5 points)

For each sub-item, the scoring criteria are further detailed as:

• 5 points: Fully compliant with requirements, with innovation or excellent practices
• 4 points: Fully compliant with requirements
• 3 points: Basically compliant with requirements, with minor deficiencies
• 2 points: Partially compliant with requirements, with obvious deficiencies
• 1 point: Serious deficiencies
• 0 points: Completely non-compliant with requirements or abandoned

Next, let’s discuss the overall compliance determination method. The total score is 100 points, based on the sum of scores from each area. We use the following criteria to determine the overall compliance level:90-100 points: Excellent The enterprise’s anti-money laundering measures are comprehensive and effective, not only fully complying with regulatory requirements but also demonstrating best practices in some aspects.

• 80-89 points: Good The enterprise’s anti-money laundering measures generally comply with requirements, with possible minor deficiencies in individual aspects, but not affecting overall effectiveness.
• 70-79 points: Satisfactory The enterprise’s anti-money laundering measures meet basic compliance requirements but have room for improvement in multiple aspects.
• 60-69 points: Needs Improvement The enterprise’s anti-money laundering measures have obvious deficiencies and need significant improvements in multiple key areas.
• Below 60 points: Non-compliant The enterprise’s anti-money laundering measures have serious defects, do not comply with regulatory requirements, and face high compliance risks.

When conducting overall assessment, in addition to the total score, we also need to consider the following factors:

Key indicator thresholds: Even if the total score reaches a high level, if the score for any key indicator (such as STR reporting or high-risk customer management) is below 2 points, the overall rating will automatically be downgraded by one level.

Improvement trends: If the enterprise shows a continuous improvement trend in past assessments, this can be given appropriate positive consideration in the final rating.

Industry benchmarking: Compare the enterprise’s score with the industry average to understand the enterprise’s relative position in the industry.

Faced risks: Consider the nature and scale of the enterprise’s business, assess the actual level of money laundering risk faced, and incorporate this factor into the final judgment.

Innovative practices: For enterprises that adopt innovative methods or technologies in anti-money laundering management, additional points can be given in relevant areas.

Through this comprehensive and guided scoring system, enterprises can clearly understand the strengths and weaknesses of their anti-money laundering measures. This not only helps meet regulatory requirements but also guides enterprises to make targeted improvements, continuously enhancing their anti-money laundering management level. At the same time, this scoring system also provides enterprises with a standardized basis for horizontal comparison and long-term tracking.

Finally, it needs to be emphasized that compliance scoring should not be viewed as a one-time task. Enterprises should incorporate it as part of their continuous improvement process, regularly conducting self-assessments and external assessments to ensure anti-money laundering measures always remain effective and up-to-date. Through continuous assessment and improvement, enterprises can not only reduce compliance risks but also enhance overall risk management capabilities, laying a solid foundation for long-term stable development in the Vietnamese market.

Common Deficiencies and Improvement Suggestions

After assessing anti-money laundering measures of Vietnamese enterprises, we have identified some common deficiencies and also summarized some best practice recommendations. This section aims to provide enterprises with practical improvement directions to help them continuously enhance their anti-money laundering compliance level.

1. Common Deficiencies

Risk assessments are formalistic: Many enterprises conduct risk assessments, but they often remain superficial, failing to deeply analyze specific risks in particular business lines and customer groups. Risk assessment results are also often not effectively guiding actual anti-money laundering measures.

Customer Due Diligence (CDD) is not deep enough: Some enterprises only stay at the level of collecting basic identity information, failing to adopt corresponding enhanced or simplified measures based on customer risk levels. For high-risk customers, such as politically exposed persons (PEPs), there is generally a lack of effective identification and management mechanisms.

Transaction monitoring systems are inefficient: Many enterprises’ transaction monitoring systems are improperly set up, leading to a large number of false positives or false negatives. System parameters are not timely adjusted according to newly emerging risk patterns, affecting the accuracy of suspicious transaction identification.

Quality of Suspicious Transaction Reports (STRs) is not high: Some enterprises experience delays in submitting STRs, and report contents are often not detailed or accurate enough, affecting the analysis effectiveness of financial intelligence units.

Insufficient employee training: Anti-money laundering training is often superficial, failing to provide targeted content for specific job needs. Insufficient training frequency leads to employees’ lack of awareness of the latest regulatory requirements and money laundering techniques.

Weak internal mechanisms: In some enterprises, anti-money laundering compliance officers lack sufficient authority and resources, and internal audits also fail to play an effective role in assessing anti-money laundering measures. Rectification of identified issues is not timely or thorough enough.

2. Recommendations

In response to these common deficiencies, we propose the following best practice recommendations:

Strengthen risk assessment: Establish a dynamic risk assessment mechanism, regularly assessing specific risks in various business lines, products, and customer groups. Ensure assessment results directly influence resource allocation and control measure formulation. Consider involving external experts in assessments to provide a more detailed scrutiny perspective.

Optimize customer due diligence: Implement a tiered CDD strategy, adopting corresponding measures based on customer risk levels. For high-risk customers, establish specialized management processes, including regular reviews and enhanced due diligence procedures. Utilize advanced technologies such as artificial intelligence to assist in customer risk assessment, improving accuracy and efficiency.

Enhance transaction monitoring capabilities: Invest in advanced transaction monitoring systems, ensuring system parameters can be flexibly adjusted to address new risk patterns. Regularly evaluate system deficiencies and optimize rules to reduce false positive rates. Consider introducing machine learning technology to improve the accuracy of abnormal transaction identification.

Improve STR quality: Establish a robust STR review and submission process to ensure reports are timely and accurate. Regularly communicate with financial intelligence units to understand their feedback on STR quality and make continuous improvements accordingly.

Strengthen employee training: Design multi-level, targeted training programs, including basic knowledge, job-specific content, and case studies. Utilize online learning platforms to provide flexible training methods and ensure training effectiveness through regular assessments. Encourage key position employees to participate in professional certifications, such as ACAMS certification.

Improve internal controls: Ensure anti-money laundering compliance officers have sufficient independence, authority, and resources. Establish an independent internal audit mechanism to regularly assess the effectiveness of anti-money laundering measures. Implement an issue tracking system to ensure all identified problems are timely and effectively rectified.

Leverage technology: Actively explore the application of new technologies in the anti-money laundering field, such as using big data analysis to improve risk identification capabilities, using blockchain technology to enhance transaction transparency, or applying artificial intelligence to optimize decision-making processes.

Enhance information sharing: Strengthen information exchange with industry peers and regulatory authorities within the scope allowed by law. Participate in industry working groups or forums to share best practices and emerging risk information.

Establish a compliance culture: Incorporate anti-money laundering compliance into corporate culture building, starting from top management, establishing a “compliance first” concept. Include anti-money laundering performance in employee performance evaluations to incentivize full participation.

Regular self-assessment and external assessment: Establish a regular self-assessment mechanism and consider engaging external experts for independent assessments. Through continuous assessment and improvement, ensure anti-money laundering measures always maintain effectiveness.

Implementing these best practices requires long-term commitment and resource investment from enterprises. However, this is not only a regulatory compliance need but also an important measure to enhance overall risk management capabilities and protect the enterprise’s reputation. In a rapidly developing market like Vietnam, establishing a robust anti-money laundering system will become a key competitive advantage for enterprises to gain regulatory trust and win customer confidence.

Enterprises should selectively adopt these suggestions based on their size, business characteristics, and risk situations, formulating feasible improvement plans. Through continuous efforts, enterprises can not only meet regulatory requirements but also build a solid risk defense line in a complex financial environment, laying the foundation for long-term stable development.

Conclusion

With the rapid development of Vietnam’s financial market and the increasing degree of internationalization, anti-money laundering compliance has become a crucial aspect of enterprise operations. This guide has detailed the key areas, methods, and standards for assessing enterprise anti-money laundering measures, aiming to provide Vietnamese enterprises with a comprehensive and practical anti-money laundering self-assessment framework. As we conclude this guide, we need to emphasize two core points: the importance of continuity and the necessity of maintaining good communication with regulatory authorities.

Importance of Continuity:

Anti-money laundering compliance is not a one-time task, but a dynamic process that needs to be continuously carried out. Financial crime techniques are constantly evolving, regulatory requirements are continuously updating, and the risk environment faced by enterprises is constantly changing. Therefore, regular, systematic assessment of anti-money laundering measures is crucial for maintaining the effectiveness of the compliance system.

We recommend that enterprises incorporate anti-money laundering assessments into their regular management processes, conducting comprehensive self-assessments at least annually. Additionally, extra assessments should be considered in the following situations: when launching new products or services; when entering new geographic markets or customer segments; when significant organizational structure changes occur; when the external environment changes significantly, such as new regulatory requirements or the emergence of new money laundering threats.

Continuous assessment not only helps to timely detect and repair compliance vulnerabilities but also helps enterprises optimize resources and improve the efficiency and effectiveness of anti-money laundering measures. Through regular assessments, enterprises can establish an evidence-based improvement mechanism, continuously enhancing the maturity of their anti-money laundering systems.

Moreover, continuous assessment can cultivate a compliance culture within the enterprise. When employees are aware that anti-money laundering is an area of ongoing focus, they are more likely to integrate compliance concepts into their daily work. This bottom-up compliance awareness, combined with top-down management determination, can form a powerful anti-money laundering defense line.

Necessity of Maintaining Communication with Regulatory Authorities:

In anti-money laundering compliance work, maintaining good communication with regulatory authorities is another key factor. This communication should not be limited to passively responding to regulatory inspections or meeting reporting requirements, but should be a proactive, ongoing interactive process.

Maintaining good communication with regulatory authorities has several important advantages:

Timely understanding of regulatory expectations: Through regular communication with regulatory authorities, enterprises can better understand and anticipate regulatory trends, thus preparing in advance.

Clarifying regulatory interpretations: Anti-money laundering regulations may sometimes have ambiguities, and proactive communication with regulatory authorities can help enterprises accurately understand regulatory requirements and avoid compliance risks.

Sharing best practices: Regulatory authorities usually have an overview of the industry situation. Through communication, enterprises can learn about industry best practices and improve their own compliance levels.

Building trust relationships: Proactive and transparent communication helps build trust between enterprises and regulatory authorities, which is crucial when dealing with complex compliance issues.

Seeking regulatory support: When enterprises face special challenges or need to implement innovative compliance measures, good communication channels can help gain understanding and support from regulatory authorities.

To maintain effective communication, enterprises can consider the following measures:

• Designate specific personnel responsible for daily contact with regulatory authorities;
• Regularly participate in seminars, training, and other activities organized by regulatory authorities;
• Proactively report to regulatory authorities and propose solutions when significant compliance issues are discovered;
• Invite regulatory personnel to participate in internal compliance training or seminars;
• Respond to regulatory inquiries and requirements promptly and completely.

In conclusion, anti-money laundering compliance is a long-term strategic task that requires continuous engagement and attention from enterprises. By establishing a systematic assessment mechanism and maintaining good communication with regulatory authorities, enterprises can not only effectively manage compliance risks but also transform anti-money laundering work into a competitive advantage. In the rapidly developing Vietnamese market, a robust anti-money laundering system will become a key factor for enterprises to win customer trust and achieve sustainable development.

We hope this guide provides valuable guidance for Vietnamese enterprises, helping them build a strong anti-money laundering defense line in an extremely complex regulatory environment. By continuously improving anti-money laundering measures, enterprises not only meet compliance requirements but also make positive contributions to the healthy development of Vietnam’s financial system, while laying a solid foundation for their own long-term development in the international market.