Strategic & regulatory workspace · 29 Oct 2026
One neobank experience.
Four legally distinct entities.
A proposed concept for digital banking and crypto-backed finance in VIFC Da Nang — for discussion among Sovico Group, HDBank, the Galaxy ecosystem, AIFC and Commodity Chain. Nothing here is agreed, licensed or live.
Existing regime, not a blank slate
Resolution 222/2025/QH15 and Decree 329/2025/ND-CP already enable VIFC member banks.
No passporting
AIFC licences do not carry over to Viet Nam; every permission must be obtained locally.
Outside deposit insurance
Decree 329 Art. 5: VIFC member banks do not participate in Viet Nam deposit insurance.
Executive summary
Share-ready brief
VIFC NEOBANK — EXECUTIVE SUMMARY (concept, as of 29 Oct 2026) Status: independent working draft. Not an operating bank, exchange or advice. No partner role, licence or product is agreed or approved. 1. One neobank experience, four legally distinct entities: proposed VIFC member bank; separately licensed crypto custody/asset service provider; licensed credit provider (if separate); commodity/RWA infrastructure with independent verifiers. 2. Viet Nam already has a VIFC banking enabling regime (Resolution 222/2025/QH15; Decree 329/2025/ND-CP). Decree 329 Art. 5: VIFC member banks do not participate in Viet Nam deposit insurance — mandatory disclosure. 3. AIFC licences do not passport to Viet Nam. An AFSA trading-facility permission does not authorise deposit-taking, yield or crypto lending; AFSA DAA 2.13.3 is route-dependent, not a blanket ban. 4. HDBank published a draft GMS resolution (26 Mar 2026) proposing a 100%-owned VIFC subsidiary bank — a corporate proposal; authorisation status unverified. 5. Resolution 05/2025/NQ-CP crypto pilot (excludes securities/fiat-backed assets; Art. 6 primary offering to foreign investors; Art. 13 specialised VND account) must be mapped product-by-product, not applied to deposits automatically. 6. Red lines: no launch without written approvals; crypto is not a deposit; no guaranteed yield; no client-asset reuse without consent and legal basis. 7. Next: submit 15 questions to authorities; complete phase 0–1 planning gates.
Phased roadmap (planning gates)
Eight phases to a regulator-ready launch
- PHASE 0
Stakeholder mandate & legal perimeter
Gate: Signed non-binding mandate; perimeter memo accepted.
- PHASE 1
Product legal taxonomy & disclosures
Gate: Each product classified; disclosures drafted.
- PHASE 2
Licensed entity, ownership & capital
Gate: Entity map and licence applications ready.
- PHASE 3
Custody, asset segregation & Earn
Gate: Segregation opinion; Earn perimeter confirmed or excluded.
- PHASE 4
Collateral lending & credit policies
Gate: Credit policy approved; enforceability opinion.
- PHASE 5
Payments, FX, AML & risk
Gate: FX and AML frameworks confirmed.
- PHASE 6
Trade finance pilot & logistics
Gate: Pilot lane documents and partner consents in writing.
- PHASE 7
Sandbox, regulator approvals & launch readiness
Gate: Written approvals received — no live launch without them.
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.
Priority decisions
- Q1Is digital-asset custody a permitted activity for VIFC members, and under which instrument?
- Q2May a VIFC member bank accept BTC/ETH as collateral, and how is the pledge perfected?
- Q3Does Resolution 05/2025/NQ-CP apply within VIFC, or does VIFC have a separate perimeter?
- Q4Which clients (residents, non-residents, retail) may a VIFC member bank serve?
- Q5What are the VND settlement and convertibility rules for VIFC member banks?
Proposed product set