What liability can bank-account owners face after lending accounts used in a scam?

Allowing another person to use a bank account does not automatically make the account holder criminally responsible for an online fraud scheme, lawyer Phan Nhi of the Ho Chi Minh City Bar Association says. The key question is whether the owner knew about the purpose of the account and intentionally helped the fraud.

Under Article 17 of Vietnam’s 2015 Penal Code, accomplices are people who intentionally act together to commit an offense. Investigators may therefore examine whether the account holder knew how the account would be used, participated in receiving, transferring or withdrawing money, provided one-time passwords or authentication details, benefited from the transactions, or otherwise assisted the crime.

If the owner did not know the account’s purpose, was unaware that the money came from criminal activity, did not take part in the transactions and received no benefit, those facts may be important in determining whether there is evidence of intentional fault or complicity. But knowing assistance can create criminal exposure even if the account holder did not directly deceive victims. Organizers, instigators and helpers can also face liability, depending on their role.

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The most important issue in this situation is determining whether the person who lent the account knew about and intentionally supported the fraudulent conduct.

The lawyer advises the registered owner to immediately stop allowing further use of the account, change the password and authentication method, and preserve messages, transaction records, explanations for lending the account and evidence showing who actually conducted the transfers. The owner should give investigators a truthful and consistent account based on verifiable documents.

The case described involved transactions totaling about 500 million dong, with some money allegedly linked to an online fraud network. Phan Nhi recommends obtaining a lawyer early to review the evidence and protect the account holder’s lawful rights and interests. The article also notes that lending payment accounts may create separate administrative liability under Vietnam’s Decree 340/2025/NĐ-CP, although the supplied text ends before stating the specific penalty.

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The use of a bank account to receive or transfer money originating from fraud does not mean that the account holder is automatically criminally liable.