Will Advertising or Holding Crypto on International Exchanges Bring Fines?

Vietnamese crypto holders do not need to sell their Bitcoin or Ethereum immediately, but future trading rules will depend on when the country licenses its first crypto-asset service provider.

Lawyer Nguyen Huu Tuan of the Hanoi Bar Association said Decree 284, effective September 1, 2026, establishes administrative penalties for transactions conducted outside organizations licensed by the Finance Ministry. Individuals could face fines of 15 million to 25 million dong, while organizations could be fined 30 million to 50 million dong. If crypto assets are offered to foreign investors, the individual penalty could reach 35 million to 50 million dong.

Tuan said the penalties for trading through an unlicensed exchange will apply only six months after the first crypto-asset service provider receives an official license. As a result, continuing to hold Bitcoin or Ethereum on an international exchange from September 1 does not itself trigger a penalty, and investors are not required to sell their assets in panic.

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Under Resolution 5, penalties for trading outside a licensed exchange will only begin to apply six months after the first crypto-asset service provider is officially licensed.

The important distinction is between continuing to hold an asset and carrying out a new transaction. Once the six-month transition period is activated, new buying and selling through platforms that lack Finance Ministry approval could be treated as violations.

Tuan advised investors to preserve documents proving the origin of their assets and avoid new purchases or sales through unlicensed organizations and platforms until they meet the conditions set out in the government’s Resolution 5. The Finance Ministry has so far announced no licensed crypto-asset market service provider. It has previously found five company applications complete and valid enough to enter the licensing review process under a pilot scheme capped at five providers.

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Investors should preserve records proving the origin of their assets and avoid new buying or selling through unlicensed organizations or platforms until they meet the conditions under the government’s Resolution 5.