Phase 0 | Vision & Groundwork (Week –6 → Week 0)
| # | Action | Why it matters | When |
| 1 | Write a one‑page “Mission & Mandate”. Define: (a) % of balance‑sheet you’ll park in BTC, (b) services you may add later (custody, OTC, advisory), (c) 3‑year success metrics. | Clarifies scope for lawyers, banks, investors. | Day 1 |
| 2 | Assemble a core team (CEO, CFO/treasurer, CTO/security lead). | Sandbox & bank applications require named, experienced managers. | Week 1 |
| 3 | Engage a Vietnam‑based fintech counsel (e.g., Tilleke & Gibbins, Viet An Law). | To map the Digital Technology Industry Law (effective 1 Jan 2026) and Decree 94/2025 sandbox rules to your model. | Week 1 |
| 4 | Do a ½‑day market deep‑dive. Use Chainalysis + Vietnam News stats to size demand (120 B USD flows; 17–21 M holders). | Week 2 | |
| 5 | Open a project‑tracker (Notion/Jira). Create columns for Legal, Banking, Security, Ops, Comms with owners & deadlines. | Keeps execution visible. | Week 2 |
Phase 1 | Entity & Compliance (Week 0 → Week 6)
| # | Action | Detail |
| 6 | Pick legal form. Usually a multi‑member LLC (Công ty TNHH) if you and Vietnamese partners will hold shares; JSC if you plan public fundraising later. | Week 0 |
| 7 | Draft charter & business lines. Register under Software / IT consulting & digital‑asset investment codes—avoid “payment intermediary” language unless joining the sandbox for that. | Week 1 |
| 8 | File for IRC → ERC with HCMC DPI. | 2–5 weeks; counsel handles Vietnamese filings & chops. |
| 9 | Inject charter capital in VND/USD. Convert any BTC to fiat first; crypto cannot be used as paid‑up capital yet. | Week 4 |
| 10 | Open corporate bank accounts. Target tech‑friendly banks (TPBank, Vietcombank, MB). Bring charter, KYC policy, and law excerpts showing crypto is property, not currency. | Week 4 |
| 11 | Register for tax codes & digital signature. Essential for e‑invoices and quarterly CIT/VAT filings. | Week 5 |
| 12 | Adopt a baseline AML/KYC manual (FATF‑style). Even if you manage only proprietary funds, Vietnam’s new law mandates AML controls. | Week 6 |
Phase 2 | Security & Treasury Architecture (Week 6 → Week 10)
| # | Action | How |
| 13 | Design the “90/10” wallet stack. • 90 % BTC → air‑gapped multi‑sig (2‑of‑3) on Coldcard/Ledger stored in two cities.• 10 % BTC → policy‑limited hot wallet for liquidity. | Week 6 |
| 14 | Draft Treasury Policy (board‑signed). Include allocation caps, re‑balance triggers, sign‑off matrix (> 1 BTC needs CEO + CFO), and emergency procedure. | Week 7 |
| 15 | Select insurance or custodian (optional). If AUM > 5 M USD, get BitGo or Fireblocks institutional cover; if self‑custody, budget annual third‑party audit. | Week 8 |
| 16 | Run a disaster‑recovery drill. Restore seeds on a blank device to prove backups work; log results for auditors. | Week 9 |
| 17 | Install compliance analytics (Chainalysis KYT or Elliptic) on all addresses to flag sanctioned coins. | Week 10 |
Phase 3 | Licensing Edge (Week 10 → Week 18)
| # | Action | Why & Source |
| 18 | Apply for the SBV/MoF Regulatory Sandbox (Decree 94). Choose the digital‑asset custody or trading‑own‑funds vertical. File: biz plan, risk matrix, capital proof. Sandbox opens 1 July 2025. | Week 10 |
| 19 | Prepare minimum‑capital dossier. Draft exchange rules suggest ≥ ₫10 T (~US$385 M) for full trading platforms; pure treasury/custody has no set floor yet but show solvency anyway. | Week 12 |
| 20 | Secure Vietnamese majority (≥ 51 %) if foreign‑owned. Sandbox caps foreign share at 49 %. | Week 12 |
| 21 | Join the Vietnam Blockchain & Digital Assets Association (VBA). Fast‑lane to regulators, peer network, and brand trust. | Week 13 |
| 22 | Schedule pre‑license audit mock. Your legal team simulates an SBV inspection: KYC logs, wallet security, tax records. Fix gaps before real visit. | Week 16 |
| 23 | Receive sandbox licence (target within 60 days of application) → authorized to operate under pilot conditions for two years. | Week 18 |
Phase 4 | Launch & Operations (Week 18 → Week 24)
| # | Action | Deliverable |
| 24 | Execute first BTC purchase via reputable OTC desk; move immediately to cold storage; log in treasury register. | Week 18 |
| 25 | Publish quarterly Treasury Transparency Report. Show BTC held (cost & fair value), security measures, and compliance statement—boosts credibility. | Week 19 |
| 26 | Roll out internal education. Run wallet‑handling workshops for staff; circulate FAQ on why company holds BTC. | Week 20 |
| 27 | Engage external accountant familiar with crypto. Align books to VAS/IFRS: BTC = intangible asset; mark impairment; track taxable gains. | Week 20 |
| 28 | File crypto tax estimates. Apply 20 % CGT on realized BTC gains; 10 % VAT on any custody fees (if you add that service). | Quarterly |
| 29 | Stake your local thought‑leadership flag. Sponsor a panel at Vietnam Blockchain Week; share best‑practice playbook—be the trusted treasury voice. | Week 22 |
| 30 | Iterate security annually (rotate keys, refresh incident‑response plan) and renew insurance. | Ongoing |
Phase 5 | Scale & Future‑Proof (Month 7 → Year 2)
- Explore IFC privileges: HCMC’s planned International Financial Center in Thủ Thiêm may grant relaxed FX rules—open a branch there once policy is live.
- Add services smartly: After sandbox graduation, consider treasury‑as‑a‑service for Vietnamese SMEs entering crypto.
- Stay policy‑sharp: Monitor sub‑decrees under the Digital Tech Law before it takes effect 1 Jan 2026; adapt treasury policy if asset‑classification or reporting forms change.
- Talent pipeline: Use the 5‑year personal‑income‑tax holiday for digital experts (in the new law) to attract world‑class security engineers.
- Global diversification: Consider a Singapore or Switzerland SPV for cross‑border custody; keep Vietnam entity focused on domestic compliance.
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90‑Day Gantt Snapshot
| Week | Legal | Banking | Security | Ops | Comms |
| 0‑2 | Entity type, counsel | – | – | Mission doc | Market research |
| 3‑6 | IRC/ERC, tax code | Open VND/USD a/c | Wallet design | AML policy | Brand story |
| 7‑10 | Sandbox file draft | Bank KYC demos | Cold‑storage drill | Treasury policy | Social channels |
| 11‑14 | Submit sandbox | – | Insurance quotes | Hire accountant | Join VBA |
| 15‑18 | – | – | Audit rehearsal | 1st BTC buy | Press release |
| 19‑24 | Sandbox licence | – | Key rotation | Q1 report | Event sponsorship |
(Adjust durations as approvals/holidays dictate.)
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Key Take‑aways
- Legally green‑lit: Crypto = property in Vietnam from 2026; sandbox licences available now.
- Massive market: $120 B flow + Vietnam #5 adoption = deep liquidity and user familiarity.
- Tax clear‑ish: 20 % CGT on realized gains; 10 % VAT on service fees—plan cash buffers accordingly.
- Compliance = moat: Early, transparent KYC/AML & audits will set you apart when regulation tightens.
Stay upbeat, stay compliant, stay ₿‑bullish—and turn Saigon into the safest vault for Satoshis in Southeast Asia! 🎉