Administrative Fines for Violations related to Crypto Assets
Mai Nguyen
On 16 July 2026 the Government of Vietnam issued Decree No. 284/2026/ND-CP on penalties for violations related to the crypto asset market Taking effect from 1 September 2026, Decree 284 creates compliance risks for offshore crypto asset exchanges in Vietnam that do not hold, and practically cannot obtain, a Vietnamese license, and for Vietnamese users who continue to transact on these offshore platforms. The following significant fines will be imposed under this Decree:
Vietnamese users would face direct personal liability for using offshore exchange platforms. Specifically, Vietnamese users who trade crypto assets outside of a Ministry of Finance-licensed service providers will be subject to fines of up to VND 50 million.
A fine of up to VND 100 million will be applied to Vietnamese users trading in crypto assets that are offered or issued to foreign users.
The provision of crypto asset services or advertising of crypto-related services without a license or operating of a crypto asset trading market without proper .authorization will be subject to fines of up to VND 200 million and
Violations of issuance, provision, or disclosure rules may face fines of up to VND 200 million.
Repeated violations are treated as aggravating circumstances and will be subject to penalties within statutory ranges.
In addition to monetary fines, Decree 284 empowers authorities to impose a range of supplementary and corrective measures that can cause significantly more operational harm to an offshore exchange than the headline fines alone. These including temporary suspension of activities for defined periods (more applicable to unlicensed local exchanges), disgorgement of unlawful gains derived from noncompliant activities, confiscation of assets used in or connected to violations and other measures
During the transition period calculating from Decree 284 comes into force as form 1 September 2026), all Vietnamese users must migrate their trading activities to licensed local exchanges within six months after the first local exchange is licensed or face penalties. Offshore exchange platforms should be ready to have a plan for the migration.