Vietnam – CM PB – Update 2021

Jun 2, 2021

Country Manuals Private Banking


We would like to inform you that BRP has updated its COUNTRY MANUAL PRIVATE BANKING for the following jurisdiction:

VIETNAM OUT OF BANK’S COUNTRY OF ESTABLISHMENT (Def, RS, BT & RT)

Regulatory Summary and Regulatory Template


Material changes
This Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up-to-date. The changes and clarifications made following consultations with our local counsel concern:
– We have clarified that this Country Manual only applies to foreign, unlicensed banks established in WTO member countries.
– Vietnamese laws generally also apply to activities undertaken via remote means of communication into Vietnam. However, due to Vietnam’s WTO commitments, financial activities undertaken via remote means of communication into Vietnam without a license generally seem to be permitted based on an unofficial tolerated practice (no official position). This approach has been streamlined throughout the documents. Still, public advertising in Vietnam remains restricted for a foreign bank.
– The RS has been amended to reflect that a foreign bank’s representative may undertake marketing activities on the Bank’s financial services in Vietnam without a local license, provided that:
(i) Activities are undertaken on a one-to-one basis (not to the general public);
(ii) The Bank’s representative does not provide services on-site but, whilst in Vietnam, is only engaged in onshore marketing;
(iii) The Bank’s representative acts on an occasional basis only;
(iv) No remuneration is received from a source located within Vietnam.
– We have clarified that reverse solicitation is not regulated in Vietnam but (…)

Non-material changes
The documents have been reformatted onto the latest templates. Some comments have been reworded, additional references to applicable law/regulation have been made in order to provide more clarity and to reflect the current regulatory situation more accurately. Further non-material changes have been made throughout the document.

Behaviour Template
BT conditions have been aligned to RS and RT.

BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “VIETNAM” in the Target Country Field.

The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared

Best regards,