From November 1, 2025, Circular 27/2025/TT-NHNN guiding the Law on Prevention and Control of Money Laundering will be officially applied. This document provides many detailed regulations, requiring organizations and businesses to quickly update internal processes to comply. Here are the 5 most important new points.
1. Transactions of 400 million VND without an account still need to be recognized
This is one of the most notable changes. According to the new regulation, organizations must carry out the customer recognition process for those who do not have an account but carry out transactions to deposit, withdraw or transfer money with a total value of 400 million VND or more in one day. This regulation helps to bridge loopholes in controlling large-value futures transactions.
2. There must be a senior manager responsible
Circular 27 requires organizations to assign a senior manager (or authorized person) with primary responsibility for organizing, directing and inspecting compliance with regulations on preventing and combating money laundering. Depending on the scale, the enterprise must establish a specialized department or appoint a specific responsible person, instead of just a general responsibility as before.
3. Compulsory regulations on personnel training
Training is no longer an incentive but has become a mandatory requirement. Specifically, new employees must be trained in basic knowledge of money laundering prevention and control within 6 months from the date of recruitment. At the same time, related leaders and employees must be trained and fostered professionally every year to update new methods and tricks of money laundering.
4. Internal audit must have separate content on money laundering prevention and control
The work of preventing and combating money laundering must become a separate content in the annual internal audit report. This report must independently inspect and evaluate the control system and the level of compliance of enterprises. The report must then be sent to the Department of Money Laundering Prevention and Control or relevant ministries and branches within 60 days from the end of the fiscal year.
5. Continuously monitoring and updating customer records according to risks
The new Circular emphasizes the need to continuously monitor business relations. Organizations must ensure that customers' transactions are consistent with the collected information about their business activities and the origin of their assets. In particular, the records of high-risk customers must be reviewed and updated regularly to ensure information is always accurate and updated.
