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Concept & legal working tool as of 29 Oct 2026 — not an operating bank, exchange or financial advice. Proposed roles are not agreed or approved.

Decisions & risks

Fifteen questions for the authorities

Risks are conditional: each states what we do if the answer is unfavourable or unknown. No resolution here is approved.

Questions

  1. Q1Is digital-asset custody a permitted activity for VIFC members, and under which instrument?
  2. Q2May a VIFC member bank accept BTC/ETH as collateral, and how is the pledge perfected?
  3. Q3Does Resolution 05/2025/NQ-CP apply within VIFC, or does VIFC have a separate perimeter?
  4. Q4Which clients (residents, non-residents, retail) may a VIFC member bank serve?
  5. Q5What are the VND settlement and convertibility rules for VIFC member banks?
  6. Q6What mandatory disclosure wording implements Decree 329 Art. 5 on deposit insurance?
  7. Q7Is any form of crypto yield (Earn/staking) permissible, and for which client classes?
  8. Q8Are stablecoins recognised in VIFC, and may they be lent or used for settlement?
  9. Q9What capital treatment applies to crypto-collateralised exposures?
  10. Q10Is there a VIFC sandbox route, and what client caps and exit criteria apply?
  11. Q11Does a token recording warehouse goods have any legal effect on title or pledge?
  12. Q12Which authority receives AML/STR reports from VIFC members holding crypto?
  13. Q13What forum resolves retail client disputes with VIFC members?
  14. Q14Are AIFC-licensed firms given any recognition, or must they apply afresh?
  15. Q15What cybersecurity and data-localisation requirements apply to VIFC members?

Red lines

  • ✕ No live launch without written regulatory approvals.
  • ✕ No crypto presented as a deposit or legal tender.
  • ✕ No guaranteed yield; any yield transparent and risk-rated.
  • ✕ No reuse of client assets without explicit consent and legal basis.
  • ✕ No partner role presented as agreed until signed.

Risk register (conditional)

AreaRiskConditional responseSeverity
Product classificationEarn mis-classified as savings.If no written perimeter view, exclude Earn.Critical
VND settlementBreach of FX controls.If rules unclear, foreign-currency only.Critical
Retail suitabilityUnsuitable crypto credit sold to retail.If no suitability regime, professional clients only.High
RehypothecationClient assets reused, creating loss on failure.If reuse proposed, require explicit consent and opinion.Critical
Custody bankruptcy remotenessClient assets enter insolvency estate.If no opinion, no Vault launch.Critical
Collateral enforceabilityPledge over crypto unenforceable.If unconfirmed, no crypto-secured credit.Critical
FX & cross-border remittanceCorridor limits and reporting breaches.If limits unknown, pilot with caps.High
CASP licensingOperating crypto services without licence.If no licence route, partner with licensed provider or defer.Critical
Deposit insurance disclaimerClients assume state protection.Disclaimer mandatory at every touchpoint.High
LiquidationsCascading liquidations in market crash.If stress test fails, lower max LTV.High
Trust / SPV structuresTrust or SPV not recognised locally.If unrecognised, use contractual segregation with opinion.Medium
Vietjet / cargo logisticsPartner role assumed but not agreed.If no consent, run lane with other carriers.Medium
Sanctions / AMLExposure to sanctioned parties or illicit flows.If screening fails, block transaction.Critical
CybersecurityKey compromise or platform breach.If audit open findings, no launch.Critical
Token legal effectClients believe token equals title.If no legal effect, label token as record only.High
Questions are drafts for legal counsel to refine before any submission.