Legal and Regulatory Landscape in Vietnam
Vietnam’s current legal framework treats Bitcoin and other cryptocurrencies as non-legal tender and even prohibits their use as a means of payment. The State Bank of Vietnam (SBV) has explicitly banned the issuance, supply, and use of Bitcoin or similar virtual currencies for payment purposes, and violations can incur heavy fines (VNĐ 150–200 million) or even criminal liability . In other words, companies cannot legally invoice or settle domestic transactions in crypto – all business payments must be in Vietnamese đồng or other lawful currency. Owning, buying, or selling cryptocurrency is not outright banned for individuals and companies, but it operates in a gray area with no clear legal protections for participants . Vietnamese courts have even ruled that crypto is not recognized as a lawful asset or property under existing law, underscoring the lack of legal status (and making it hard for authorities to regulate or tax) .
Recent Developments: Recognizing the need to catch up with innovation, Vietnam is in the midst of establishing a legal framework for digital assets. On June 14, 2025, the National Assembly passed the Digital Technology Industry Law, a landmark legislation that officially defines and recognizes digital assets (including crypto assets) . This law (set to take effect Jan. 1, 2026) categorizes digital assets into “virtual assets” and “crypto assets,” with the latter defined by the use of cryptographic encryption in their creation and transfer . While cryptocurrencies are still not recognized as fiat money or legal payment instruments, they will be recognized as a form of property/asset under the new law, providing a legal foundation for ownership and transactions .
Alongside defining crypto assets, the new law empowers regulators to issue detailed conditions on anti-money-laundering (AML) controls, cybersecurity, and consumer protection for crypto activities . Notably, the law also introduces incentives for blockchain and digital asset firms – such as tax breaks, R&D subsidies, and even visa facilitation – to foster innovation . This reflects Vietnam’s intent to promote blockchain technology and attract crypto-related investment, while improving compliance with international standards (Vietnam has been on the FATF “grey list” for AML deficiencies, partly due to unregulated crypto activity) .
Pilot Programs and Upcoming Regulations: In parallel, the government is launching pilot schemes to safely integrate crypto into the financial system. A draft “Crypto Asset Market Pilot” has been proposed, outlining a sandbox program running until end of 2027 . Under this pilot, licensed enterprises will be allowed to provide certain crypto-related services – including operating digital asset trading platforms, custody services, proprietary trading, and token issuance platforms – all under the oversight of the Ministry of Finance and in coordination with the SBV and other agencies . This means that in the near future, companies in Vietnam could apply for licenses to run regulated crypto exchanges or custodial services on a trial basis. The goal is to establish a controlled environment where crypto markets can function with government monitoring, thereby shaping permanent regulations based on the pilot’s outcomes .
Bottom Line: As of 2025, Vietnam’s legal stance is still restrictive – crypto cannot be used as money – but outright holding and investment are tolerated (if not yet explicitly protected). Companies venturing into Bitcoin should be prepared for regulatory evolution. By 2026, crypto assets will have legal recognition as property in Vietnam , and a more comprehensive regulatory regime (covering licensing, AML/KYC, and consumer protection) is expected to follow. Staying abreast of new decrees and implementing compliance measures early will be crucial for any Bitcoin treasury business to operate legally and securely in Vietnam’s emerging crypto landscape.
Tax Implications and Reporting Requirements
Current Tax Treatment – Uncertainty Prevails: Vietnam currently lacks any crypto-specific tax law, leading to significant ambiguity in how Bitcoin holdings or gains are taxed. In fact, recent legal cases have highlighted this uncertainty. In one instance, a Vietnamese court ruled that cryptocurrencies do not meet the legal definition of goods, assets, or currency, and therefore the tax authorities could not enforce taxes on crypto trading profits . Similarly, Verdict No. 224/2024/HSST reaffirmed that under today’s laws, crypto is not recognized as property or a taxable commodity . As a result, attempts by tax authorities to impose income tax or value-added tax on crypto transactions have so far been unsuccessful . In short, until crypto is legally defined, there is no formal tax category for it – leaving individuals and businesses in a gray zone. The government generally taxes investment income, but because of crypto’s cross-border, pseudonymous nature, enforcement has been very challenging .
Corporate Income Tax (CIT): In the absence of explicit guidance, the prudent approach is to treat Bitcoin profits like any other investment income for a company. Vietnam’s standard corporate income tax rate is 20%. Thus, if a company sells Bitcoin at a profit (i.e. the sale price in VND exceeds the original cost basis of the Bitcoin), that profit would logically be added to its taxable income and subject to the 20% CIT . Conversely, realized losses from selling Bitcoin could potentially be treated as deductible losses to offset other income, subject to normal tax rules on loss carry-forwards . It’s important to note that unrealized gains (market value increase of Bitcoin holdings that haven’t been sold) are not taxed in Vietnam – taxation is triggered only upon a realization event (e.g. selling crypto for fiat or possibly trading it for another asset) . This aligns with general tax principles that mark-to-market gains are not taxed for assets not officially recognized under current law. However, companies should be aware that once crypto is legally classified (as expected by 2025–2026), new rules might specifically impose a **capital gains tax on crypto transactions (a 20% rate has been discussed to mirror corporate tax rates)】 .
Value-Added Tax (VAT): Vietnam levies a 10% VAT on most goods and services, but Bitcoin itself is not considered a good or service, so trading Bitcoin per se is not currently a VAT-taxable activity . For example, simply buying BTC or selling BTC for VND does not incur VAT, since crypto is not recognized as a product. However, if a company provides crypto-related services (for instance, running a crypto exchange, brokerage, or advisory service), the fees or commissions earned would likely attract VAT (at 10%), just as any service revenue . Draft proposals have indeed suggested imposing a 10% VAT on service fees of crypto exchanges, while not taxing the value of the crypto asset transfer itself . For a pure treasury holding company that does not provide services to others, there would be no VAT unless it sells some service. One caveat: if the company uses overseas service providers (say, a foreign crypto exchange or custodian that charges fees), those fees aren’t subject to Vietnamese VAT directly – though in theory, import of services can trigger a “reverse charge” VAT obligation. In practice, until crypto is fully regulated, this is not enforced, but it’s something to keep in mind for future compliance .
Accounting and Reporting: Accounting for Bitcoin under Vietnamese Accounting Standards (VAS) is currently unaddressed, so companies often look to international standards (IFRS) as a reference. Under IFRS, Bitcoin is usually classified as an intangible asset (IAS 38) – unless it’s held for sale in the ordinary course of business (which would be more like inventory for a crypto dealer) . As an intangible asset, Bitcoin would be initially recorded at cost, not amortized (since it has an indefinite life), but subject to impairment testing. That means if the market price falls below the carrying value at a reporting date, the company must write down the value (record an impairment loss) on the balance sheet . If the price increases, no upward revaluation is recorded in most cases – gains are only recognized upon sale . This conservative accounting can understate the asset’s value on books if Bitcoin’s price rises significantly, but those unrealized gains simply won’t appear in income until realized. Vietnamese auditors have no official crypto guidelines yet, but they are likely to follow a similar approach (intangible or “other investment” classification) by analogy . Companies should work closely with their auditors and possibly the tax office to ensure they disclose crypto holdings properly – for example, listing Bitcoin under “other long-term investments” or “intangible assets” in financial statements, and providing notes on fair value, cost, and impairments .
Record-Keeping and Compliance: Even in this gray period, a company holding or transacting Bitcoin is wise to keep meticulous records and be transparent in its tax filings. This includes maintaining detailed logs of every crypto transaction (dates, amounts, VND value at time of transaction) and ensuring any realized gains or losses are included in the annual tax finalization reports . Although today Vietnamese authorities might not explicitly ask for crypto reporting, once the new legal framework kicks in, they may scrutinize past activities. Voluntarily reporting under general tax principles now (e.g. treating crypto gains as other income in tax filings) can reduce the risk of penalties later when regulations tighten . As one expert noted, until clear regulations are issued, “investors and businesses… don’t know how or to whom they should pay taxes” on crypto . But this is expected to change soon. Anticipating that change, companies should be ready to comply with likely requirements: this could include declaring crypto holdings as part of financial statements, computing taxable gains on any crypto disposals, and possibly filing supplementary reports on digital assets. The takeaway is that the tax landscape is in flux – for now, no crypto-specific taxes are enforced , but standard taxes (20% corporate tax on profits) likely apply by default, and Vietnam’s forthcoming rules will aim to bring digital assets into the tax net. Engaging a professional tax advisor who stays updated on the latest decrees will be invaluable to navigate reporting duties for a Bitcoin treasury.
Banking and Financial Services: Availability and Limitations
Establishing a Bitcoin-focused company in Vietnam will encounter significant banking and financial infrastructure challenges. Vietnamese banks are, at present, very cautious (if not outright restrictive) about any crypto-related transactions. The SBV has directed all banks and payment service providers to monitor and prevent cryptocurrency transactions, especially to enforce the ban on using crypto for payments . In practice, if a company tries to, say, wire a large sum to a known cryptocurrency exchange or if it receives incoming funds flagged as crypto-related, the bank’s compliance department will likely freeze or scrutinize the transaction heavily . There have been anecdotal reports of banks calling in customers for questioning if they suspect crypto trading activity, and some banks have blocked credit card payments or outbound transfers to foreign crypto exchanges entirely . This means that a straightforward approach to convert VND to BTC (or vice versa) via the banking system is often not possible for a company in Vietnam.
No Native Crypto Banking Services: Unlike some jurisdictions where banks have begun offering crypto custody or trading desks, in Vietnam no bank currently offers crypto custody, deposit accounts in crypto, or direct exchange services . Crypto businesses cannot simply open a corporate bank account labeled for crypto transactions; they typically must operate under the radar of conventional banking. Until the law changes, all banks are under SBV’s uniform guidance, so none can officially endorse or facilitate crypto dealings . This lack of support forces crypto-focused companies to get creative in accessing on/off ramps:
- Peer-to-Peer (P2P) and OTC Trades: Most Vietnamese crypto users rely on peer-to-peer marketplaces or over-the-counter trades to exchange between VND and crypto. A company may need to do the same. For instance, converting a portion of corporate VND funds into Bitcoin might involve buying USDT (Tether) or USDC stablecoins from a local broker or P2P market (since stablecoins are commonly traded for VND), then swapping those stablecoins for Bitcoin on an international exchange or decentralized exchange . This indirect route avoids the company sending money directly to a crypto exchange (which the bank might block), but it comes with counterparty risk and can be slower due to trade size limits (a local OTC trader might only handle limited volume per trade) . Similarly, when the company needs to liquidate Bitcoin to pay for expenses in VND, it would likely have to sell BTC to a buyer who pays VND into the company’s bank account (essentially a reverse P2P trade) . Such incoming funds might require an explanation to the bank (e.g. labeling it as proceeds from sale of an “asset”) because large unexplained deposits can raise money-laundering red flags .
- Offshore Banking and Entities: Some companies set up an offshore subsidiary or use an overseas bank account in a crypto-friendly jurisdiction (for example Singapore or Hong Kong) to handle the conversion. The offshore entity could conduct crypto trades on international exchanges, then transfer funds (fiat or crypto) to the Vietnam entity as needed . This effectively moves the sensitive conversion step outside Vietnam’s banking system. However, this approach adds complexity – it may require proper inter-company agreements, and Vietnamese foreign exchange laws require justification for cross-border transfers. Without an official legal framework, routing funds this way exists in a legal grey zone and must be carefully structured to avoid violating currency controls or tax rules . Companies considering this will need legal counsel to ensure any offshore-onshore transfers (whether labeled as investments, loans, or revenue) are compliant with Vietnam’s foreign investment regulations.
Impact on Operations: The inability to freely move between crypto and fiat on demand means a Bitcoin treasury company must plan liquidity carefully. It should maintain enough VND cash on hand for operations, since converting BTC to VND in a hurry can be cumbersome (and potentially delayed by banking scrutiny) . It also means normal financial services we take for granted – like using payment gateways, merchant accounts, or even accounting software integrated with banks – won’t accommodate crypto transactions. The company must effectively operate a dual system: one leg in the traditional banking world (for fiat needs like salaries, rent, vendors) and one leg in the crypto world for its treasury holdings, with a barrier between them enforced by banking restrictions.
Future Outlook: There is optimism that these banking barriers will ease once regulations are in place. The government’s pilot plan includes establishing licensed digital asset exchanges by ~2026 as part of a regulated financial center . If a regulated local crypto exchange emerges (under state oversight), companies might eventually have a compliant domestic avenue to convert between VND and crypto . Likewise, if Vietnamese banks are allowed to partner with fintechs or run their own crypto custody services under license, a company could potentially hold Bitcoin with a local bank or use banking channels for crypto in the future . For now, though, Vietnam’s banking system poses significant friction for crypto operations . Any business dealing with Bitcoin in Vietnam must factor in extra time, costs, and workarounds for moving money. Best practices include maintaining open communication with your banks (to the extent prudent) – for example, inform them that your company might engage in “digital investments” or overseas investments so that occasional large transfers don’t come as a total surprise . It’s also wise to diversify banking relationships (have accounts with multiple banks) in case one institution is particularly strict or closes your account due to crypto-related activity . Until local financial institutions fully embrace crypto, success in Vietnam will require being resourceful with on/off ramps – leveraging P2P networks, trusted OTC brokers, or foreign partners – and rigorously adhering to AML documentation (keeping records of sources and destinations of funds) to satisfy any bank inquiries . In summary, expect banking to be one of the hardest parts of operating a Bitcoin treasury company in Vietnam, and plan accordingly with contingency plans for liquidity.
Business Models for a Bitcoin Treasury Company
A “Bitcoin treasury company” can take on various business models or service offerings. Broadly, such a company could simply manage its own crypto treasury as a principal (much like a corporate holding Bitcoin as a reserve asset), or it could offer services to others looking to hold or invest in Bitcoin. Key business models and activities in this space include custody services, investment advisory, trading/OTC services, and asset management. Each comes with its own operational focus and regulatory considerations:
- Custody Services: A custody-focused model means the company securely holds Bitcoin (and potentially other digital assets) on behalf of clients. The value proposition is to provide institutional-grade security (cold storage, multi-signature controls, insurance coverage, etc.) so that other companies or high-net-worth individuals don’t have to worry about safeguarding their own private keys. Custodians generate revenue via custody fees (often a percentage of assets under custody or a flat fee for storage). In many jurisdictions, offering custody might require a trust or custody license. In Vietnam, crypto custody is not yet a regulated service – but the draft crypto pilot resolution explicitly envisions licensed crypto custodians (enterprises will need a license from the MOF to provide “custody of crypto assets”) . This suggests that in the near future, a Bitcoin treasury company could apply to become an authorized custodian, storing assets for clients under government oversight. Regionally, we already see examples of this model: for instance, Hex Trust (based in Hong Kong/Singapore) and OSL (Hong Kong) are dedicated digital asset custodians serving institutional clients. A Vietnam-based custodian would need to implement robust security infrastructure – likely employing hardware security modules, multi-signature wallets, tiered access controls for internal staff, and regular audits. The company could also offer ancillary services like custody reporting (statements of holdings), facilitating insurance on custodied assets, and perhaps integration with banks or exchanges for quick transfers.
- Investment Advisory: In an advisory model, the company acts as a consultant or financial advisor for clients (e.g. businesses or family offices) interested in Bitcoin. This could involve advising on treasury allocation strategies (how much of a corporate treasury to allocate to BTC), timing and execution of purchases, and guidance on regulatory compliance for holding crypto. The company might also educate clients on Bitcoin’s risk profile, how to integrate it into their balance sheet, and design internal policies for governance of digital assets. Revenue can come from consulting fees or retainers. In Vietnam, traditional financial advisory and management of client funds is regulated (e.g. investment management licenses), but since Bitcoin is not a security, pure advice on buying Bitcoin falls in a grey zone. Nevertheless, an advisory-focused crypto firm should uphold high standards of diligence – for example, ensuring any advice given aligns with the client’s risk tolerance and that proper disclosures (volatility, legal risks) are made. In practice, Big Four consulting firms and boutique crypto advisors are already offering such services in crypto-friendly hubs (Singapore’s consultants, for instance, help companies navigate setting up crypto treasuries). A Bitcoin treasury company in Vietnam could similarly carve a niche as the go-to expert advisor for corporates that want to dip their toes into crypto once regulations permit. Over time, this could evolve into a licensed “digital asset manager” role if Vietnam creates a framework for crypto investment funds.
- Trading and Brokerage (OTC Desk): Another model is operating a trading desk or brokerage that helps clients buy and sell Bitcoin. In this capacity, the company might function like an OTC (over-the-counter) broker, matching buyers and sellers off-exchange and earning a spread or commission. It could also involve proprietary trading – using the company’s own capital to trade crypto and profit from market movements or arbitrage. This model demands deep liquidity access and risk management expertise. In Vietnam, running a crypto exchange or trading platform currently has no legal basis (and unlicensed exchanges are illegal), but the upcoming sandbox could allow licensed exchanges or trading platforms as a pilot . For now, any trading operations would need to be done carefully to not violate laws (e.g. not publicly offering an exchange service domestically). If a company limits itself to proprietary trading (trading its own Bitcoin to grow its treasury) that is generally legal in the sense that buying/selling crypto as an investment isn’t prohibited – it just faces the aforementioned banking hurdles. A full-fledged trading service for others would likely require partnering with or setting up abroad until Vietnamese licenses are available. Business-wise, an OTC or trading desk can earn good margins in markets where liquidity is fragmented (Vietnam’s market is largely P2P, so a trustworthy broker could attract significant volume). However, this also carries higher regulatory risk – such a company must implement strict AML/KYC checks for any clients (to avoid facilitating illicit transactions) and will need to monitor global and local rules to ensure it isn’t deemed an illegal money service. Examples regionally include companies like Matrixport or Amber Group, which provide OTC trading along with custody and yield services, though these tend to operate out of Singapore/Hong Kong where regulation is clearer.
- Asset Management and Funds: An asset management model would involve managing a portfolio of Bitcoin or other crypto assets on behalf of investors, either through a fund structure or separately managed accounts. For instance, the company could launch a crypto investment fund or trust that pools money from investors to buy and hold Bitcoin (similar to how Grayscale Bitcoin Trust operates in the U.S., or how some Singapore-based funds are offering Bitcoin funds to accredited investors). It could also mean treasury management for other companies – e.g. Company A outsources the management of its Bitcoin holdings to your firm, which then handles custody, executes trades at advantageous times, perhaps even employs yield strategies like lending or staking to generate a return on the Bitcoin. Asset management typically charges fees as a percentage of assets under management (AUM) and possibly performance fees. This model would clearly intersect with financial regulations: running a fund likely requires a fund management license from regulators (in Vietnam, fund management is overseen by the State Securities Commission). As of 2025, since crypto is not yet recognized as a security or commodity, a pure crypto fund might not neatly fit existing categories – but any solicitation of investors has to be done carefully under private placement rules or via an offshore fund vehicle. That said, the direction of regulation in Vietnam and regionally is to integrate crypto into the legal investment sphere. The new legal framework is expected to “unlock investment opportunities” and create regulated channels for digital assets . A Bitcoin treasury company could position itself to launch one of Vietnam’s first regulated crypto funds once allowed. In the meantime, examples elsewhere set precedents: DigiAsia – a fintech firm with operations in Indonesia/Singapore – announced plans in 2025 to raise $100M to establish a Bitcoin treasury reserve, effectively acting like a quasi-fund (allocating up to 50% of its corporate profits into Bitcoin and even exploring yield generation through lending/staking) . Even though DigiAsia is an operating company, its strategy resembles asset management, since it’s managing a large pool of capital into BTC with a strategic mandate. Similarly, MicroStrategy in the U.S. became famous for converting its corporate cash into Bitcoin; while not a fund, its business model became akin to a Bitcoin holding company, and its stock gave investors indirect exposure to Bitcoin’s performance. In Southeast Asia, we are likely to see hybrid models – for example, a tech company or a family office that creates an internal unit to manage a crypto portfolio, potentially offering those services to affiliates or clients once regulations permit.
In practice, a single Bitcoin treasury company might combine several of these models. For instance, it could hold its own Bitcoin (treasury reserve), advise other corporates, and offer custody and OTC trading as services. Many crypto firms globally have evolved to offer a “full stack” of services (trading, custody, advisory, asset management) to diversify revenue. However, each added business line increases regulatory requirements. Vietnam’s upcoming rules will likely require specific licenses for each function (as seen in the draft pilot, where exchange operation, custody, and proprietary trading are distinct licensed activities) . Therefore, a prudent strategy is to start with one or two core competencies and expand as the legal environment allows.
Summary of Models: Below is a high-level comparison of these business models, highlighting their focus and viability under Vietnam’s conditions:
| Model | Description & Revenue | Current Legal Feasibility (Vietnam) |
| Self-Treasury (Principal Investing) | Company holds Bitcoin on its own balance sheet as a reserve or investment; profits from asset appreciation (and potentially from ancillary yield strategies). | Allowed (grey area) for holding since owning crypto is not banned. Must not use for payments. No special license needed just to invest own funds , but no explicit legal protection until 2026. Subject to unclear tax treatment of gains. |
| Custody Service | Securely hold Bitcoin for clients; charge storage/management fees. Emphasizes security (cold storage, insurance). | Not yet legal to operate publicly. Draft framework will license crypto custody as a regulated service . Until then, can only offer informally or via offshore setup. High compliance and security standards required. |
| Advisory Service | Act as a consultant on crypto investment (e.g. advising companies on how to acquire/manage Bitcoin, compliance, and strategy). Revenue via consulting fees. | Partially feasible. General business consulting is legal; advising on crypto is not prohibited, but there’s no specific certification. Must avoid acting as an unlicensed investment broker. Essentially operates as a financial consultancy; likely low regulatory scrutiny if no client funds are handled directly. |
| Trading/OTC | Facilitate buying/selling of Bitcoin for clients (brokerage) or trade on company’s own account for profit. Earn spreads or trading gains. | Restricted. Operating an exchange or brokerage in Vietnam is not permitted without a license (none exists yet). Prop trading own crypto is tolerated (many individuals and some companies do it quietly). Any client-facing trading likely needs to be via an offshore entity or wait for the sandbox exchange license by 2026 . Strict AML/KYC would be essential to avoid legal issues. |
| Asset Management | Manage a portfolio or fund of Bitcoin/crypto for investors; could be a fund product or discretionary accounts. Earn management fees and performance fees. | Not currently regulated (crypto not recognized as security, so no legal fund structure for it in Vietnam). Would likely require working with regulators or setting up fund in a crypto-friendly jurisdiction. Prospective area once laws recognize crypto as an investment asset; until then, limited to private, closed-end arrangements among knowledgeable investors. |
(Table: Business model options for a Bitcoin treasury company, and their viability under present Vietnamese regulations.)
Examples of Bitcoin/Crypto Treasury Companies in Southeast Asia
While the concept of holding Bitcoin as a corporate treasury asset is still emerging, there are a growing number of companies in Asia (and globally) that have embarked on this strategy. Below we highlight several case studies and examples relevant to Vietnam and the region:
- Genius Group (Singapore) – A Singapore-based education technology (edtech) company that is publicly listed. Genius Group adopted a Bitcoin reserve strategy, explicitly holding Bitcoin to safeguard its balance sheet and align with a forward-looking, tech-driven vision . This move is part of its broader pivot towards blockchain and decentralized finance; by holding BTC, the company signals innovation to investors while hedging against potential fiat currency risks. Structurally, as a public company, Genius Group had to announce this strategy to shareholders and will account for Bitcoin under Singapore’s regulatory framework (which, compared to Vietnam, already recognizes crypto under certain conditions).
- Moon Inc. (Hong Kong) – A private digital media firm headquartered in Hong Kong that has started incorporating Bitcoin into its capital strategy. Moon Inc. is using Bitcoin to enhance its financial resilience . Although details on its operations are private, this suggests the company allocates a portion of its treasury into Bitcoin as a hedge or growth asset. Hong Kong’s regulatory environment (post-2023) has become more accommodating, allowing licensed trading platforms – so Moon Inc. can likely acquire and custody Bitcoin through local regulated channels, something not yet available in Vietnam.
- Metaplanet (Japan) – A Tokyo-listed company in the hospitality and advisory services sector, Metaplanet made headlines by transitioning to a Bitcoin-focused treasury strategy. It shifted a substantial part of its corporate strategy to acquiring and managing Bitcoin as a core holding . Metaplanet’s long-term accumulation plan has even positioned it among the world’s largest corporate Bitcoin holders . This example is notable because Japan has clear rules for crypto (legal as property and certain accounting guidance); Metaplanet likely benefited from Japan’s more favorable tax treatment for holding crypto via public equities (as noted in some reports, capital gains from equity holdings can be taxed more consistently than direct crypto gains in Japan) . The company’s operations now revolve around managing its BTC treasury, and it has had to be transparent with shareholders about this strategy, essentially transforming into a hybrid operating-and-investment entity.
- DDC Enterprise (US-Asia) – DDC is a U.S.-listed company with strong ties to Asia (its operations or management have an Asian focus). DDC embraced Bitcoin as a long-term reserve asset, making it a key part of its capital allocation . Notably, DDC partnered with Hex Trust for custody and execution, meaning it leveraged a professional custodian to secure its Bitcoin holdings . This underscores that even when a company decides to hold BTC, they often rely on specialized crypto infrastructure for safekeeping and liquidity. DDC’s example shows how a public company can strategically reallocate capital into Bitcoin to potentially improve returns or protect value, while outsourcing technical aspects to experts. Such partnerships could be a model for Vietnamese firms in the future (e.g. a Vietnam company could hold BTC but store it with a licensed custodian in Singapore for safety until local options exist).
- DigiAsia (Indonesia/Singapore) – DigiAsia is a Southeast Asian fintech firm (listed on NASDAQ, ticker FAAS) that announced plans in 2025 to raise $100 million specifically to build a Bitcoin treasury reserve . Its board approved allocating up to 50% of future net profits into Bitcoin and it’s even exploring yield-generating strategies (like lending or staking its Bitcoin via regulated partners) to make the treasury an active part of its finance strategy . This example is particularly relevant as it’s one of the largest publicly announced Bitcoin treasury initiatives in the region. The structure here is a fintech operating company turning a portion of itself into a Bitcoin holding vehicle. They have to manage the dual objectives of running their core business (payment and financial services) and acting somewhat like a crypto fund on the side. After the announcement of the Bitcoin plan, DigiAsia’s stock price surged, indicating investor interest in this pivot . This case shows that even in Southeast Asia, public markets are reacting to companies embracing Bitcoin, and it could encourage similar moves by others. For Vietnam, it’s a sign that once regulations allow, there may be appetite among tech companies or even conglomerates to publicly leverage Bitcoin as part of their financial strategy.
- Global Benchmarks (for context) – It’s worth noting globally known examples even if they’re not Southeast Asian, as they influence regional sentiment. MicroStrategy (USA) is the classic example: a software company that since 2020 has accumulated over 150,000 BTC as of 2025, effectively using corporate debt and cash flows to buy Bitcoin and turning its treasury into a Bitcoin vault. Tesla (USA) also bought $1.5 billion of BTC in 2021 (though later sold a portion) . In Asia, before Metaplanet and others, Meitu (China), a Hong Kong-listed app maker, bought around $100 million of BTC and ETH in 2021 as a treasury investment. These pioneers showed that corporate Bitcoin holdings can be done, but also highlighted challenges (e.g. accounting writedowns in MicroStrategy’s case when Bitcoin price fell, or scrutiny from regulators/shareholders). Vietnamese companies and regulators have been observing such cases closely . So far, no Vietnamese public company has officially announced Bitcoin holdings, and any that have bought crypto are doing so quietly . However, as the legal framework matures, we may see Vietnam’s “first movers” – likely tech companies or those with international exposure – follow in these footsteps to diversify their treasury with digital assets .
Vietnam Local Scene: Within Vietnam, aside from individuals, a few startups in the crypto space exist (exchanges like VNDC or blockchain projects like Axie Infinity’s Sky Mavis or Kyber Network team), but these are more operating businesses rather than pure treasury holders. They hold crypto as inventory or working capital (especially the exchanges), not as a passive treasury reserve. Some Vietnamese family offices and private companies are rumored to have allocated part of their wealth to Bitcoin as a hedge against future inflation or dong depreciation, but none have publicized it . This reticence is due to the uncertain legal environment; companies are waiting for clear legality before disclosing such holdings. Once Vietnam’s laws are in place and perhaps a regulatory sandbox is active, we might see local firms openly partnering with established players (for custody or exchange) to implement a treasury strategy.
In summary, the case studies in Southeast Asia demonstrate a variety of approaches: from publicly listed tech firms repurposing their cash into Bitcoin, to fintech upstarts raising capital specifically for crypto investment, to companies leveraging third-party custodians to manage their reserves. These examples provide a playbook of potential structures (e.g. using a portion of profits to regularly buy Bitcoin, using custody providers, integrating Bitcoin strategy with corporate narrative) that a Saigon-based Bitcoin treasury company could emulate. They also illustrate the importance of aligning such a strategy with shareholder/stakeholder communication and choosing jurisdictions wisely for different aspects of the operation (some functions might be kept offshore until Vietnam’s own regulations catch up).
Risk Management, Storage & Custody Solutions, and Compliance Practices
Implementing a Bitcoin treasury strategy in Vietnam comes with a unique risk profile. Proper risk management, secure custody solutions, and rigorous compliance practices are essential to ensure the company’s longevity and credibility. Below, we outline the key risks and recommended strategies to mitigate them:
- Regulatory and Compliance Risk: The legal framework for crypto in Vietnam is in flux, and changes can be sudden. A major risk is that new regulations could impose restrictions – for example, authorities might require companies to register crypto holdings or could even temporarily disallow corporate crypto activities if they perceive systemic risk. To manage this, the company should closely monitor policy developments (Ministry of Finance circulars, SBV directives, draft laws) and be ready to adapt. This could mean being prepared to obtain new licenses (if a law mandates that “crypto custody providers” or “crypto dealers” must get licensed, the company should swiftly comply) . It also means maintaining an open dialogue with regulators if possible – participating in the sandbox programs or industry associations (like the Vietnam Blockchain Association) to stay informed. From a compliance practice standpoint, even if not yet required by law, the company should internally enforce strong KYC/AML procedures for any crypto transactions it undertakes (especially if dealing with counterparties). This includes performing due diligence on OTC trading partners, keeping records of all trades, and even using blockchain analysis tools to ensure incoming funds aren’t tainted by illicit activity. By voluntarily adhering to global best practices (e.g. FATF’s travel rule threshold considerations, OFAC sanctions screening on crypto addresses), the company builds a compliance culture that will serve it well once Vietnamese regulations catch up.
- Market Volatility Risk: Bitcoin’s price is notoriously volatile – swings of 20–30% in a single month are not uncommon . This poses a financial risk: a sharp downturn in BTC value could impair the company’s balance sheet and even threaten its solvency if the position is large relative to the company’s equity . To mitigate volatility risk, treasury allocation should be conservative. The company should only convert to Bitcoin an amount of capital that it can afford to leave invested for the long term (multiple years) without jeopardizing operational liquidity . Many companies treat Bitcoin like a non-current asset or a reserve, meaning they don’t rely on it for short-term obligations. Additionally, the company can explore hedging strategies: for instance, using futures or options on offshore exchanges to hedge downside risk. However, accessing derivatives might be challenging from Vietnam due to legal restrictions (it would have to be via foreign platforms) and it introduces complexity and counterparty risk. Another approach is diversification – not putting 100% of the treasury in Bitcoin, but perhaps a fraction (while holding the rest in cash or stable instruments). This balances potential upside with protection. Regular stress testing of the treasury’s value against extreme price scenarios is a good practice, so management knows how a price crash might impact financial ratios or loan covenants, and plans can be made for such scenarios (e.g. have a credit line or emergency fund in fiat).
- Security and Custody Risk: Custody of Bitcoin is a critical risk area – losses can be irretrievable. A Bitcoin treasury company must implement ironclad security protocols to prevent theft, hacking, or loss of private keys. Multi-signature (“multi-sig”) wallets are a foundational tool: require multiple approvals (e.g. 2-of-3 or 3-of-5 keys) to move funds, so no single person can drain the wallet . Keys should be stored on hardware devices (hardware wallets) kept offline (cold storage) in secure physical vaults. Splitting key holders among trusted executives or board members (and possibly an independent custodian) provides checks and balances. The company should have strict policies for key management: e.g. no one travels with all key devices together, regular key audits are conducted, and emergency procedures are in place if a key is lost (one reason to use multi-sig with a redundant key). Insider risk is also a concern – background check and vet any personnel with access to crypto systems, and use role-based access controls so that, for example, an accounting staff might view wallet balances but cannot initiate transfers. Many firms even establish a “key ceremony” process for generating and distributing keys at inception, with legal observers or auditors present to record the process.
If the company chooses to use a third-party custodian (like a bank’s custody service or a specialist custodian), it should vet that provider’s security certifications, insurance policy (does it cover theft of client assets), and regulatory status. Third-party custody can reduce internal technical burden and adds a layer of insurance/recourse, but it introduces counterparty risk – the custodian could itself be hacked or could freeze assets due to regulatory issues . Diversifying storage (e.g. some portion in self-custody, some with a reputable custodian) could be a balanced approach. It’s also advisable to insure the crypto assets if possible. Some insurers offer policies for digital asset theft or loss (often under specialty lines at a high premium). While insurance might not cover every scenario (and may exclude things like government seizure or insider theft), it can provide some financial hedge and reassure stakeholders that risks are being responsibly managed.
- Liquidity and Cash-Flow Management: We touched on this in banking, but from a risk perspective, the company must manage the risk that it cannot convert Bitcoin to cash when needed. Given the on-ramp/off-ramp frictions, a plan should be in place for how to raise liquidity in an emergency. Strategies include maintaining a fiat buffer (e.g. always keep X months of operating expenses in cash, separate from the Bitcoin reserve) . Also, setting thresholds for liquidation: for instance, if Bitcoin’s price rises dramatically and the position becomes, say, more than 50% of the company’s total assets, the company might rebalance by selling a portion to lock in gains and reduce exposure – this is more of a financial policy decision. On the flip side, if Bitcoin’s price is crashing and the company urgently needs funds, having pre-identified OTC partners or liquid exchanges is important (possibly even accounts on multiple exchanges ready to use). The worst time to scramble for liquidity is during a market panic, so establishing relationships with liquidity providers in advance is wise. The company could also arrange for credit facilities secured by Bitcoin – in some jurisdictions, firms borrow against their Bitcoin (using it as collateral to get a cash loan) to avoid selling at a bad time. This might not be available in Vietnam yet, but some crypto lending desks abroad might extend such services to a foreign entity. The risk here is margin calls if Bitcoin falls further. In summary, treat Bitcoin as relatively illiquid for planning purposes – ensure the business can run even if the Bitcoin can’t be quickly cashed out .
- Financial Reporting and Audit Risk: Being an early mover in holding Bitcoin means auditors and authorities might apply extra scrutiny. There is a risk that auditors in Vietnam (who tend to be conservative) might issue a qualified opinion or raise concerns if they feel there’s uncertainty in how the crypto is treated in financial statements . To mitigate this, the company should engage with its auditors early and often. Agree on an accounting policy for the Bitcoin (likely the intangible asset approach as discussed), and disclose everything transparently in notes. It may help to obtain a valuation from an independent source at year-end (to back up any impairment or disclosure of fair value). Compliance with any emerging accounting guidance is crucial; even if not mandatory, following IFRS or guidance from jurisdictions like the US (where the FASB in late 2023 proposed fair value accounting for crypto) could show that the company is using reasonable standards. The finance team should also prepare to do additional reporting – for instance, if regulators require a periodic report of digital asset holdings, the company can adapt its internal reports accordingly. Being proactive in reporting Bitcoin holdings to tax authorities (within the annual tax return notes or separate letter) could also avoid surprises later. Essentially, treat the crypto holding with the same rigor as any other significant financial asset: reconcile transactions, document custody statements, and be ready to justify the treatment to any inquisitive official or stakeholder.
- Reputational and Stakeholder Management: In Vietnam, crypto carries a mix of excitement and skepticism. There are reputational risks: Some traditional partners (banks, large customers, government bodies) might view a company that holds a lot of Bitcoin as engaging in risky or speculative behavior . If not communicated properly, this could affect business relationships or investor confidence. To handle this, the company should craft a clear narrative for why it is holding Bitcoin. For example, it can publicly position the Bitcoin reserve as a hedge against future inflation or currency risk, or as a way to be part of the digital transformation in finance (i.e. “digital gold” thesis) . By emphasizing that this is a long-term, strategic reserve and not a short-term gamble, the company can mitigate the perception of recklessness. It should also reassure stakeholders that robust risk management (as we are detailing) is in place. Regular updates in annual reports or shareholder meetings about the status of the Bitcoin investment – how it’s safeguarded, how it fits into the overall financial strategy – will help maintain trust. Communication is key: the company might consider holding educational sessions for its board and major investors about crypto, to ensure alignment. Also, have a plan for media inquiries – if word gets out that “Company X holds Bitcoin,” be ready to answer questions on how you manage the risks. If the Bitcoin investment were to perform poorly (say there’s a large loss in value one year), having already framed it as a long-term play will help contextualize the temporary hit, whereas if people think the company was speculating, they may react more negatively.
- Legal and Enforcement Risk: The fact that Bitcoin is not yet fully recognized in law means if something goes wrong, the company may have limited legal recourse. For example, if the company is defrauded by a rogue OTC counterparty, or an employee steals some BTC, recovering those assets through legal action is very uncertain. Vietnamese courts might not know how to treat a case involving crypto assets (can they order the return of an asset that isn’t officially recognized property?) . Similarly, insurance claims might be tricky if insurers argue about the legal status of the asset. The company should therefore assume that preventive measures are the primary protection – once a loss happens, it might not be recoverable. This means double-down on vendor due diligence (only trade with reputable firms, possibly use escrow arrangements for large trades), and enforce strict internal controls to prevent misconduct. It may also consider legal structuring such that some aspects of crypto dealings fall under jurisdictions with clearer laws – e.g. using an arbitration clause that if a dispute with a foreign exchange arises, it’s handled in Singapore courts (which are more familiar with crypto cases). Until Vietnamese law enforcement and courts gain expertise in digital assets, a Bitcoin treasury company must tread carefully knowing that it operates in a semi-official space.
- Strategic Risk: Finally, there is the high-level risk that the core rationale for holding Bitcoin might not pan out as expected. The company might be betting on Bitcoin’s long-term appreciation or its hedge properties. However, there’s no guarantee that Bitcoin’s price will rise on the needed timeline, or that it will indeed act as a hedge against local currency issues. If, for example, global interest rates rise and make bonds more attractive, capital could shift away from crypto. Or a superior technology could emerge that diminishes Bitcoin’s dominance. The strategy needs review if macro conditions change. Mitigating strategic risk involves staying informed about the crypto industry and macroeconomics, and being willing to pivot. The company should periodically reassess: Is Bitcoin still the best use of our capital? If circumstances shift (say regulatory costs become too high or volatility too damaging), the company might reduce its crypto holdings. Having an exit strategy or adjustment strategy is prudent – even if the plan is to hold “indefinitely,” define conditions that would trigger re-evaluation (e.g. if Bitcoin falls by X% or if a law requires onerous capital charges on crypto holdings, etc.).
In conclusion, adopting Bitcoin in a treasury requires a sober, robust risk management approach. The rewards – potential high returns, diversification, being at the forefront of innovation – come with equally high risks in Vietnam’s context . A successful Bitcoin treasury company will treat risk management as a first-class priority: not as an afterthought but as part of its core operations. This means diversifying its assets (not “all eggs in one basket”), implementing strong internal controls and security measures, obtaining professional advice for legal and tax compliance, and perhaps even securing insurance or backup arrangements for worst-case scenarios . By doing so, the company can confidently navigate the volatility and uncertainties, turning a bold vision (embracing a new asset class) into a sustainable, compliant, and well-governed reality in Vietnam.