Author: Yuanshan Insight
- In late January, the Ministry of Finance officially launched the pilot program for crypto asset trading platform licenses
- A 10 trillion VND (nearly 300 million RMB) entry threshold directly cleans out small and medium players, with local financial giants entering the market
- Establishes a new geopolitical division of labor: "Dubai compliance, Vietnam development," aiming to become the "core foundry" of the Web3 world.
Just after the Davos Forum, BlackRock's CEO declared "the financial system should migrate to Ethereum," and the New York Stock Exchange announced the development of a tokenized securities platform.
Meanwhile, Vietnam's Ministry of Finance launched the crypto license pilot, with a 10 trillion VND (nearly 300 million RMB) entry threshold, directly blocking small exchanges.
Traditional finance embraces Web3, while Southeast Asian emerging markets erect compliance barriers. Does it want to become the next Hong Kong, or the next Singapore?
【 01 | What Happened 】
In late January, Vietnam's Ministry of Finance officially launched the pilot program for crypto asset trading platform licenses. This is a landmark event marking Vietnam's shift from a "gray area" to explicit regulation.
There are three key points:
Entry Threshold: Paid-in capital must reach 10 trillion VND (nearly 300 million RMB). For comparison, this figure is over 16 times the 100 million PHP (approx. $1.8 million USD) threshold in the Philippines.
Applicant Restrictions: Must be a local Vietnamese enterprise. This means Binance, Coinbase, etc., cannot obtain licenses directly and must enter through local joint ventures or acquisitions.
The first institutions to express participation include SSI Securities (a top Vietnamese securities company) and MB Bank (a major commercial bank), both traditional financial institutions.
Timing: This move occurred less than a week after this year's Davos Forum.
During the forum, signals of a global regulatory race were released—Japan announced the legalization of Crypto ETFs by 2028, the UK's Financial Conduct Authority (FCA) is nearing completion of crypto regulatory consultations, and the US Congress is advancing "crypto market structure legislation."
Vietnam's move is a response to this global race. This is the publicly known fact.
【 02 | From Gray Profits to Scalability in the Sunlight 】
Vietnam's previous crypto market was in a "gray area"—neither explicitly legal nor completely banned. In this ambiguous state, numerous small exchanges grew wildly in an unlicensed, unregulated environment. User funds lacked protection, and exit scams occurred frequently.
The significance of the licensing system is that it pushes the crypto market from "gray profits" to "scalability in the sunlight." The nearly 300 million RMB threshold blocks underfunded small exchanges but clears space for capable local financial institutions.
The entry of traditional institutions like SSI Securities and MB Bank means user asset custody, compliance, and anti-money laundering will be executed according to traditional financial standards.
The Philippine experience offers a comparison: From late 2025 to early 2026, the Philippine National Telecommunications Commission (NTC), following central bank instructions, blocked nearly 50 unauthorized platforms, including Coinbase and Gemini. However, the trading volume of the locally licensed exchange PDAX saw explosive growth. Compliance did not end the market but rather redistributed the cake.
Vietnam is not the first to act. Looking across Southeast Asia, Thailand, Malaysia, and the Philippines all upgraded their regulatory frameworks between 2025 and 2026.
-- Thailand issued formal guidance in early 2026, supporting the establishment of spot Bitcoin and Ethereum ETFs and incorporating crypto assets into the Derivatives Act framework. To attract institutional investors, the capital gains tax exemption policy approved by the Thai Ministry of Finance will last until December 2029.
-- Malaysia adopted a "dual management" model: The Securities Commission (SC) is responsible for qualifying investment-type cryptocurrencies as "securities," and the National Bank (BNM) monitors anti-money laundering. Currently, 6 licensed exchanges are approved to operate, and the SC has a "zero-tolerance" attitude towards unlicensed platforms.
-- The Philippines raised the entry threshold: According to the "Crypto Asset Service Provider Rules" issued by the SEC in 2025, all platforms operating in the Philippines must register as local companies, with paid-in capital not less than 100 million PHP (approx. $1.8 million USD).
Vietnam's move is a follow-up in this Southeast Asian regulatory race, part of a regional trend. When neighboring countries are establishing compliance frameworks, if Vietnam continues to maintain a gray area, it will instead lose the opportunity to attract正规 institutions.
An easily overlooked background is that the global layout of Web3 enterprises is forming a new geopolitical division of labor: Dubai (Compliance Center) + Vietnam/Malaysia/Thailand (Development Center) + Global Market (Operational Coverage).
Dubai, by establishing the world's first dedicated regulatory agency VARA, has become the preferred location for Web3 startup registration and compliance. But Dubai has high talent costs and significant cost pressures for technology development and ecosystem building.
Southeast Asian countries like Vietnam, Malaysia, and Thailand, with low talent costs and local policy support, are becoming "development centers." Vietnam's launch of the licensing system means it is shifting from "gray development" to "compliant development"—enterprises can legally establish technical teams in Vietnam to develop DApps and infrastructure without worrying about the risks of sudden policy changes.
The formation of this geopolitical division of labor is a major boon for the Web3 industry. Enterprises can place compliance in Dubai, development in Vietnam, and market coverage globally. This logic of "trading流量 for resources" is more sustainable than simply "being non-compliant everywhere."
【 03 | Why It Might Also Bring Risks 】
- Entry threshold may increase industry concentration
Nearly 300 million RMB in paid-in capital is not high for traditional financial institutions, but it is a difficult threshold for local crypto-native enterprises to cross. This may lead to the Vietnamese crypto market being monopolized by traditional financial institutions, lacking innovative vitality.
Singapore's experience offers a comparison: The Monetary Authority of Singapore (MAS) has extremely long review periods for crypto exchange licenses, focusing on money laundering prevention and technical risk management. The result is that many innovative startups cannot obtain licenses and ultimately choose to leave Singapore. Singapore's regulatory framework is mature, but it has也因此 lost some innovative enterprises.
Will Vietnam follow suit? If traditional institutions like SSI Securities and MB Bank dominate, will they have sufficient motivation to promote emerging businesses? Or will they operate crypto trading as "just another financial product," lacking understanding of Web3 native culture?
- Compliance costs may be passed on to users
The licensing system brings compliance costs—KYC processes, custody fees, regulatory reporting—which may ultimately be passed on to users. If the transaction fees of licensed Vietnamese exchanges are significantly higher than those of international platforms, users might turn to underground markets or use VPNs to continue accessing overseas exchanges.
The goal of compliance is to protect users, but excessively high compliance costs may push users towards less secure channels.
- Mismatch between regulatory capacity and market innovation
Vietnam's crypto market is still in its early stages. Do the regulatory authorities have sufficient technical capabilities and talent pool to regulate complex DeFi protocols, cross-chain transactions, stablecoin issuance?
The practical problem is that SSI Securities and MB Bank may be proficient in traditional financial business but lack experience in Web3-native businesses like on-chain governance, smart contract security, liquidity mining. If regulatory authorities also lack expertise in these areas, the licensing system might become "formal compliance"—superficially regulated, yet unable to identify the real risk points.
Another point: Geopolitical uncertainty
Vietnam's crypto market coverage is mainly in Southeast Asia, but the geopolitical situation in this region is complex. US influence in Southeast Asia, China-ASEAN relations, regulatory coordination between Vietnam and its neighbors—these factors may all affect policy stability.
If Vietnam's licensing system is incompatible with the regulatory frameworks of neighboring countries (Thailand, Malaysia), it may increase the compliance difficulty of cross-border business. Can products developed by Web3 enterprises in Vietnam operate smoothly in Thailand and the Philippines? If not, Vietnam's role as a "development center" would be significantly diminished.
【 04 | Hong Kong vs. Singapore: Vietnam's Choice 】
Vietnam's nearly 300 million RMB threshold and priority policy for local institutions have already sent a signal: It does not want to become the next Philippines (low threshold, high activity) but is choosing between Hong Kong and Singapore.
The Hong Kong path is "retail-friendly + financial product innovation": Allows retail trading, approves spot ETFs, establishes stablecoin sandboxes. This open attitude attracts大量 Asian-background capital but also意味着 higher regulatory costs and risk exposure.
The Singapore path is "institution-friendly + strict retail control": The MAS discourages retail speculative trading but strongly promotes blockchain applications in wholesale settlement and asset securitization (e.g., Project Guardian). The entry threshold is extremely high, but the ecosystem is more stable.
Vietnam's nearly 300 million RMB threshold and priority for local institutions更像是在走 the Singapore path. But the question is, can Vietnam's financial infrastructure and talent pool support "institutional-grade high-standard" regulatory requirements?
If Vietnam wants to become the "Singapore of Southeast Asia," it needs not only a licensing system but also a完善 legal framework, professional regulatory teams, and deep integration with international standards. These all require time and resource investment.
For Vietnam, taking the Hong Kong path means quickly aggregating liquidity, attracting retail funds, and building a Southeast Asian crypto trading center. But the question is, do Vietnamese regulatory authorities have sufficient professional capability to handle the complexity of the retail market? If retail funds are at risk, can Vietnam provide a完善申诉 mechanism like Hong Kong?
A Third Way: "Development Center + Remote Compliance"
Perhaps Vietnam does not need to become Hong Kong or Singapore. It can take a third way: become a Web3 enterprise development center, while placing compliance in Dubai, Hong Kong, or Singapore.
This geopolitical division of labor is taking shape: Dubai (Compliance Center) + Vietnam/Malaysia/Thailand (Development Center) + Global Market (Operational Coverage).
This path is more realistic. Vietnam does not need to compete with Hong Kong and Singapore for the compliance center position but can leverage its talent cost advantages and policy support to become an industry-recognized "development hotbed."
【 05 | Impact on Retail Investors: Compliance is Not the End 】
The most directly affected by the licensing system are ordinary Vietnamese crypto users. In the past, they could freely choose international exchanges or local small platforms, with low fees, low thresholds, but self-borne risks.
Now, if Vietnam strictly enforces the licensing system, unlicensed platforms may be blocked (the Philippine approach). Users can only choose licensed exchanges operated by SSI Securities or MB Bank.
Benefits: User funds have custody guarantees, KYC processes are standardized, and there are channels for complaints if problems arise.
Costs: Transaction fees may increase, the variety of selectable coins may decrease (regulators usually only approve mainstream coins), and the pace of product innovation may slow down.
For Vietnam's younger generation of retail investors—who may be accustomed to using platforms like Binance—this transition may cause不适应. If local licensed exchanges cannot provide a comparable user experience, some users might turn to VPNs or P2P over-the-counter trading, creating new regulatory blind spots.
The regulatory goal is to protect users, but overly rigid execution may push users towards less secure channels. Vietnam needs to find a balance between "protecting users" and "maintaining market vitality."
【 06 | Perhaps the Third Way is More Realistic 】
The Hong Kong path attracts retail investors and liquidity but requires extremely strong regulatory capabilities. The Singapore path is stable but has an extremely high threshold, requiring mature financial infrastructure. Vietnam possesses neither.
But the third way is more realistic: Become a Web3 development center, leverage talent cost advantages, and place compliance in Dubai or Hong Kong. The significance of the nearly 300 million RMB threshold is that it pushes the market from a "gray area" to "compliant development"—enterprises can legally establish teams and develop products without worrying about sudden policy changes.
This is the first time Vietnam has regulated "crypto asset trading platforms" as a formal financial sector.
