1 Define the mission, scope & capital stack
Clarify whether you’ll (a) hold Bitcoin on your own balance sheet only, (b) manage it for third‑party corporates, or (c) do both. Draft a high‑level treasury allocation plan (how many BTC, investment horizon, risk appetite). This anchors every later decision.
2 Master Vietnam’s crypto rulebook
- Payment use is prohibited—Bitcoin can’t be used to settle invoices domestically .
- Holding & trading are allowed but taxed as investment assets .
- The Law on Digital Technology Industry (DTI Law)—passed 14 Jun 2025, in force 1 Jan 2026—creates formal licensing and a regulatory sandbox for crypto businesses .
Read the law, track draft decrees and prepare to file under the sandbox if you want exchange or custody permissions.
3 Choose the right legal entity
For an operational treasury business, a 100 % foreign‑owned Limited Liability Company (LLC) is simplest. Vietnam permits full foreign ownership in most sectors .
4 Secure investment approval (IRC)
Foreign founders must first obtain an Investment Registration Certificate (IRC) from the Ho Chi Minh City Department of Planning & Investment.
Key documents: investment project outline, proof of funds, draft charter .
5 Incorporate & get an Enterprise Registration Certificate (ERC)
Submit the charter, member list and legalised IDs to receive the ERC—your company’s “birth certificate.” Expect 3 – 4 months total for IRC + ERC .
6 Open a Vietnamese bank account & inject charter capital
You’ll need a local dong account for capital injection and tax payments. Some banks are crypto‑averse—shop for one familiar with fintech clients.
7 Apply (or prepare) for a
Crypto‑Asset Business Licence
Under the DTI Law the Ministry of Finance will issue sub‑licenses for:
| Licence | What it covers | Lead agency |
| Custody / cold‑storage services | Safekeeping client BTC | MOF + SBV |
| Brokerage / OTC | Match buyers & sellers | MOF sandbox |
| Proprietary holding only | No third‑party funds | Lightest touch |
Stay alert for MOF circulars setting exact forms & fees.
8 Design your compliance stack
- AML/KYC: mirror FATF Travel‑Rule controls; verify counterparties on‑chain.
- Book‑keeping: adopt IFRS or Vietnam VAS plus FASB fair‑value guidance so you can mark BTC up & down .
- Tax: register for corporate income tax (20 %) and quarterly crypto‑gain reporting .
9 Draft & adopt a written treasury policy
Falcon Rappaport’s checklist is gold :
- Board‑approved allocation & rebalancing triggers.
- Legal / regulatory review.
- Risk‑mitigation tools (DCA, options hedges, insurance).
- Audit & on‑chain proof procedures.
10 Select institutional‑grade custody
Never park treasury coins in a hot wallet! Industry best practice offers three tiers :
- Multi‑sig wallets (2‑of‑3, 3‑of‑5)
- MPC (multi‑party computation)—flexible quorum without on‑chain fingerprint
- Offline HSM‑backed cold storage (Ledger Enterprise, IBM Cold‑as‑a‑Service)
Choose one, document key‑holder roles, back‑ups and disaster‑recovery drills.
11 Acquire your Bitcoin
- Use regulated OTC desks or exchanges operating in Vietnam’s upcoming sandbox.
- Sweep proceeds straight to cold storage; log TxIDs for auditors.
- Dollar‑cost‑average to smooth price swings.
12 Operate, monitor, grow
- Monthly: reconcile wallets, file VAT & WHT if you offer services.
- Quarterly: tax returns on realised crypto gains/losses.
- Annually: audited financials, renewal of any licences, board review of treasury policy.
- Scale‑up options: Lightning Network settlement, collateralised lending, or white‑label treasury services for regional SMEs once regulation matures.
🚀 Your launch checklist
| Stage | Status box |
| Mission & BTC allocation defined | ☐ |
| Legal memo on DTI Law & payments ban | ☐ |
| IRC obtained | ☐ |
| ERC obtained | ☐ |
| Bank account funded | ☐ |
| Licence / sandbox application filed | ☐ |
| AML, tax, audit frameworks live | ☐ |
| Custody solution operational | ☐ |
| First BTC acquired & cold‑stored | ☐ |
| Policy review & stakeholder report | ☐ |
Feel the energy!
Vietnam’s crypto adoption already tops 20 % of adults and is climbing . With regulation turning from “gray area” to clear runway, you’re stepping in right before lift‑off. Nail each step above, stay agile, and you’ll lead the charge as Saigon’s premier Bitcoin‑treasury powerhouse.
Onward—build, stack sats, and shine!