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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.

Legal source library

20 sources. Primary texts first. No invented sections.

Last checked 29 Oct 2026. Where a section is unverified we say so. Corporate and companion items are labelled as such.

20 / 20

A01AIFC / AFSA

AFSA — List of Regulated Activities

Sections
Official index page of AFSA regulated activities.
Why it matters
Each neobank product must map to one or more distinct AIFC regulated activities; one licence does not cover all.
Implementation question
Which activity combination would each product require if benchmarked to AIFC?
BankingCustodyCreditInvestment management
A02AIFC / AFSA

AFSA — Accepting Deposits

Sections
Specific sections not yet verified — read the full text.
Why it matters
Benchmark for treating deposit-taking as a distinct banking activity requiring bank authorisation.
Implementation question
Does the VIFC member-bank licence mirror this activity boundary and its prudential conditions?
BankingDeposits
A03AIFC / AFSA

AFSA — Providing Credit

Sections
Specific sections not yet verified — read the full text.
Why it matters
Fiat lending against crypto collateral is a credit activity first; collateral type does not change that.
Implementation question
Which VIFC entity may provide credit, to whom, and against which collateral classes?
Credit
A04AIFC / AFSA

AFSA — Providing Custody

Sections
Specific sections not yet verified — read the full text.
Why it matters
Crypto Vault is a custody service, not a deposit; segregation and client-asset rules apply.
Implementation question
Is digital-asset custody an explicitly permitted activity in VIFC, and under which instrument?
CustodyDigital assets
A05AIFC / AFSA

AFSA — Managing Investments

Sections
Specific sections not yet verified — read the full text.
Why it matters
Earn products that deploy client assets at discretion may resemble investment management.
Implementation question
Would a discretionary yield strategy be classified as portfolio management or a collective scheme?
Investment managementDigital assets
A06AIFC / AFSAVerify URL / index only

AFSA Rulebook portal (Orderly) — Banking Prudential module index

Sections
Portal root only. Navigate to the Banking Prudential module manually; no deep link is asserted here.
Why it matters
Capital, liquidity and large-exposure benchmarks for crypto-collateralised exposures.
Implementation question
What risk weight or deduction would a VIFC bank apply to crypto-collateralised loans?
Capital & prudentialBanking
A07AIFC / AFSA

AIFC Financial Services Framework Regulations (FSFR)

Sections
Specific sections not yet verified — read the full text.
Why it matters
Framework for licensing, the general prohibition and AFSA powers; basis for benchmarking.
Implementation question
Which FSFR concepts does the VIFC regime adopt, and which differ?
BankingConsumer protectionAML / CFT
A08AIFC / AFSA

AFSA Digital Asset Activities rules — 2.13.3 Lending and Staking

Sections
Rule 2.13.3 (as titled on source).
Why it matters
A digital asset trading facility may not offer member lending facilities unless reasonably satisfied the user is a Professional Client; an exception concerns collateral provided to the Authorised Firm. Route-dependent — not a blanket ban on all crypto loans.
Implementation question
Would any VIFC Earn or lending product be restricted to professional clients by analogy?
Digital assetsCreditConsumer protection
A09AIFC / AFSA

AIFC Rules on Digital Asset Activities (module)

Sections
Specific sections not yet verified — read the full text.
Why it matters
A digital asset trading facility permission does not by itself authorise deposit-taking, yield or crypto lending.
Implementation question
Which digital-asset activities would a VIFC CASP need beyond trading?
Digital assetsCustody
A10AIFC / AFSA

AFSA FinTech Lab

Sections
Programme page.
Why it matters
Sandbox model for testing under restrictions; any published participant example is not a blanket licence.
Implementation question
Does VIFC offer an equivalent controlled-testing route with client caps?
Sandbox / FinTech
A11AIFC / AFSA

AFSA FinTech — Authorisation process

Sections
Specific sections not yet verified — read the full text.
Why it matters
Illustrates staged application, restricted licence and exit criteria.
Implementation question
What evidence pack would a VIFC sandbox application require?
Sandbox / FinTech
V01Viet Nam

Resolution 222/2025/QH15 on the International Financial Centre in Viet Nam

Sections
Specific sections not yet verified — read the full text.
Why it matters
National Assembly foundation for VIFC: special mechanisms, members, supervision and dispute resolution.
Implementation question
Which provisions govern banking, FX, digital assets, sandbox and disputes for VIFC members?
BankingFX & cross-borderDigital assetsSandbox / FinTechDisputesAML / CFT
V02Viet Nam

Decree 329/2025/ND-CP (official English PDF via VIFC Da Nang)

Sections
Art. 3 (definitions incl. deposit taking in money); Art. 5 (VIFC member banks do not participate in Viet Nam deposit insurance). Other articles: verify.
Why it matters
The existing VIFC banking enabling regime — the neobank is not a blank slate.
Implementation question
What licence, capital, client and currency limits apply to a VIFC member bank?
BankingDepositsCapital & prudentialConsumer protectionFX & cross-border
V03Viet Nam

Resolution 05/2025/NQ-CP on piloting the crypto-asset market (official gazette entry)

Sections
Art. 6 (primary offering only to foreign investors); Art. 13 (foreign investors' specialised VND account). Scope excludes securities and fiat-backed assets.
Why it matters
Pilot covers crypto assets issued by Vietnamese enterprises, backed by non-securities real assets, traded via MoF-licensed venues. Interaction with bank deposits must be assessed product-by-product.
Implementation question
Does the pilot apply inside VIFC, or does VIFC have a separate digital-asset perimeter?
Digital assetsFX & cross-borderCustody
V04Viet Nam

Resolution 05/2025/NQ-CP — full text (Government policy portal)

Sections
Full text; see Art. 6 and Art. 13 as above.
Why it matters
Readable full text for article-level checks.
Implementation question
Do tokenised commodity records fall within the pilot's crypto-asset definition?
Digital assetsCommodities
V05Viet Nam

VIFC Da Nang — official legislation index

Sections
Index page; use to locate current decrees and English versions.
Why it matters
Authoritative entry point for the VIFC legal stack.
Implementation question
Which implementing decrees and circulars have been issued since the last check?
BankingFX & cross-borderAML / CFTDisputesSandbox / FinTech
V06Viet Nam

Decree 323/2025/ND-CP

Sections
Subject matter and sections to be verified against the official text.
Why it matters
Part of the VIFC implementing package; scope must be read before relying on it.
Implementation question
Which governance, member or operator rules in this decree affect the neobank?
BankingAML / CFT
V07Viet Nam

Decree 330/2025/ND-CP — commodity exchange

Sections
Specific sections not yet verified — read the full text.
Why it matters
Relevant if tokenised commodity records or warehouse receipts interact with a VIFC commodity exchange.
Implementation question
Can warehouse documents be listed, pledged or settled via the exchange?
CommoditiesCredit
C01Corporate proposalCorporate proposal · not law · no approval implied

HDBank — draft GMS resolution on establishing a subsidiary bank in VIFC (26 Mar 2026)

Sections
Corporate shareholder draft — not law.
Why it matters
Shows a proposed 100%-owned VIFC subsidiary; current corporate and authorisation status awaits verification.
Implementation question
Has the resolution been adopted, and has any licence application been filed or granted?
BankingCapital & prudential
C02CompanionWorking companion · not official

AIFC → VIFC Tokenisation Launchpad (independent research companion)

Sections
Working research companion — not an official source.
Why it matters
Deeper tokenisation analysis that complements this workspace.
Implementation question
Are its conclusions consistent with the latest official texts?
Digital assetsCommodities

A12 (FSFR duplicate of A07) was merged into A07 to avoid listing the same document twice.