Starting a Bitcoin treasury company in Vietnam requires careful navigation of legal frameworks, market conditions, and operational best practices. Below is a comprehensive guide organized into clear steps and sections, covering regulatory requirements, market landscape, infrastructure, entity setup, treasury management, risks/opportunities, and local support resources.
1. Understand Vietnam’s Legal & Regulatory Framework for Crypto
Legal Status of Crypto: As of 2025, Vietnam has officially recognized digital assets (including cryptocurrencies) under a new Law on Digital Technology Industry . Cryptocurrencies are defined as a type of asset and are legally protected as property, meaning citizens and companies can own, transfer, trade, donate, or inherit them with legal recognition . However, they are not legal tender – using Bitcoin or other crypto as payment for goods and services in Vietnam remains prohibited by law . In practice, this means crypto is treated as an investment or commodity, not as currency.
Licensing Requirements: The new law (effective Jan 1, 2026) establishes a framework for licensing and compliance. Any organization dealing in crypto assets – such as exchanges, wallet providers, custodians, or token issuers – will need to register and obtain licenses from Vietnamese authorities . A regulatory sandbox program is being introduced to pilot crypto services in a controlled environment. Under a draft resolution, Vietnam will allow licensed pilots for: (i) crypto trading platforms, (ii) proprietary trading (investing the company’s own funds in crypto), (iii) crypto custody services, and (iv) token issuance platforms . Notably, foreign ownership in such crypto ventures is capped at 49% during the pilot , so if you are a foreign founder you’ll need a Vietnamese partner for majority ownership in regulated crypto services. The government is imposing strict conditions for crypto business licenses to ensure only well-capitalized, qualified players operate. For example, a draft requirement for crypto exchanges is a minimum ₫10 trillion (≈US$385 million) paid-in capital, with at least 35% owned by at least two regulated financial or tech institutions . These high thresholds show the intent to prevent under-capitalized or non-compliant operators from entering the market.
Regulatory Restrictions: Aside from the ban on using crypto for payments, Vietnam’s regulators (such as the State Bank of Vietnam) have historically warned about crypto-related risks. Until the new law takes full effect, no official domestic crypto exchange or brokerage licenses exist, and activities have operated in a legal “gray area” . Companies must therefore avoid acting as unlicensed exchanges or payment services. All crypto-related businesses will be subject to anti-money-laundering (AML) and counter-terrorism financing rules aligned with FATF standards . This includes implementing strict Know-Your-Customer (KYC) procedures and cybersecurity measures. Non-compliance can lead to penalties once enforcement begins in 2026 (Q1–Q3 2026 is when licensing audits and compliance checks start) . Bottom line: plan to fully comply with licensing, KYC/AML, reporting, and minimum capital rules if your treasury company will offer services to others. If your company only manages its own Bitcoin treasury (proprietary investment) and does not service clients, you may not need a special license, but you should still register a legal business entity and adhere to general financial regulations.
Tax Implications: Up to now, Vietnam has lacked specific tax guidance on crypto, meaning many crypto gains went untaxed under the “gray area”. General tax principles do apply, however, since crypto is considered an asset. Profits from selling cryptocurrency (realizing gains in VND) are likely subject to capital gains tax – roughly 20% on corporate profits or on personal investment gains, aligning with standard corporate income tax rates . If the Bitcoin treasury company earns income (e.g. from mining, staking, or advisory fees), those earnings would fall under normal corporate income tax (20% for companies) or personal income tax for individuals, according to existing brackets . Value-added tax (VAT) of 10% may apply to any service fees the company charges (for example, if you provide custody or brokerage services) . It’s important to maintain detailed records of all crypto transactions (dates, values in VND at time of transaction, etc.) for tax reporting . As the legal framework solidifies, Vietnam’s tax authorities are expected to issue clearer rules. There are indications that new regulations will formalize a 20% capital gains tax on crypto trading profits, apply VAT to exchange services, and require annual tax filings for crypto income by March 31 (for individuals) and quarterly for businesses . On the positive side, the Digital Technology Industry law includes major tax incentives for qualified tech and crypto companies: for example, eligible digital tech enterprises can enjoy a reduced corporate tax rate of 10% for up to 15 years, exemptions on import duties for equipment, and even personal income tax exemptions for certain skilled employees . High-quality digital technology professionals (including foreign experts) working on qualified projects are exempt from personal income tax for 5 years in Vietnam . Your Bitcoin treasury company, if registered as a digital tech enterprise (e.g. focusing on blockchain tech development or infrastructure), could potentially avail these incentives. Always consult a tax advisor or local tax office for the latest rules – by 2025 the Ministry of Finance is expected to clarify crypto tax obligations .
Regulatory Timeline (Summary): To put it in context, Vietnam’s stance is rapidly evolving from restrictive to proactive:
- 2017-2021: Crypto not recognized; the State Bank banned crypto as payment, and no licensing framework existed (crypto businesses operated unofficially).
- 2022: Government began studying crypto regulation; Prime Minister directed ministries to develop a legal framework and even explore a pilot Central Bank Digital Currency.
- 2023: Vietnam was flagged by FATF (gray list) partly due to crypto AML concerns, spurring urgency for regulation .
- 2024: Draft Law on Digital Technology Industry introduced, and the National Blockchain Strategy announced (to make Vietnam a regional blockchain leader by 2030) .
- June 2025: National Assembly passed the Digital Technology Industry Law, legally defining crypto assets and mandating government oversight . Also in mid-2025, the Prime Minister approved a pilot crypto market plan (sandbox) and listed blockchain/crypto as strategic technologies .
- Late 2025: Detailed sub-decrees and the Crypto Sandbox program will launch (with licenses from the Ministry of Finance for exchanges, custodians, etc.) . Ho Chi Minh City (Saigon) is slated to host an International Financial Center (IFC) pilot with special policies for digital asset companies .
- Jan 1, 2026: The new law comes into full effect – crypto assets officially gain status as property under civil law . Companies are expected to begin licensing and compliance procedures in early 2026, aiming for full FATF-compliant regulation by end of 2026 .
Action Items for Compliance:
- Engage a legal advisor early to determine what license your specific business model requires (if any). For instance, managing only your own treasury might just require standard business registration, while offering custody or trading services means preparing a license application.
- Stay updated via official channels: Follow the Ministry of Finance announcements, State Bank of Vietnam regulations, and the Vietnam Blockchain Association for news on licensing rules and deadlines .
- Implement AML/KYC now: Even before formal licenses are issued, set up internal KYC procedures and transaction monitoring to meet global standards . This will both mitigate risks and position you favorably when authorities start issuing licenses.
- Plan for audits and reporting: In anticipation of 2026 enforcement, document all crypto transactions and security controls. Regulators will likely require periodic reports or even audits of crypto holdings and compliance practices . Being organized from the start will smooth your path to full legitimacy.
2. Research Vietnam’s Crypto Landscape and Market Sentiment
Understanding the local crypto environment is crucial for strategic positioning. Vietnam’s crypto market is characterized by enthusiastic public adoption amid historically cautious government oversight, though the latter is changing fast.
High Adoption Rates: Vietnam consistently ranks among the top countries globally for cryptocurrency adoption. In 2024, Vietnam was ranked #5 in the Global Crypto Adoption Index by Chainalysis . An estimated 10 to 21 million Vietnamese (approximately 10–20% of the population) own cryptocurrency, placing Vietnam in the very top tier worldwide for crypto ownership . Between July 2022 and June 2023 alone, over US$120 billion in crypto value flowed in and out of Vietnam, with Vietnamese users reaping about $1.18 billion in profits during that period . These figures underscore that the Vietnamese public is highly active in crypto trading and investment. Interest is driven by factors like seeking investment gains, hedging against inflation, and the country’s young, tech-savvy population . However, much of this activity has been retail-level and speculative – many individuals chase short-term profits (the “FOMO” mentality) rather than employing long-term strategies .
Public Sentiment: Among the general public, sentiment toward crypto is quite positive or at least curious. Millions have participated in crypto, often via global exchanges (despite the legal gray area) . The demographic skew is young, with many retail traders and a growing community of blockchain developers and entrepreneurs. That said, because of scams and Ponzi schemes that have occurred, there is also some wariness. High-profile frauds and exchange collapses (like the FTX crash or local scam projects) have made headlines and reinforced the need for caution . Educating your potential clients or stakeholders on security and having a credible, compliant image will be important to gain trust in Vietnam.
Government and Regulatory Sentiment: Historically, Vietnam’s government was very cautious on crypto – it banned crypto as a payment method in 2018 and issued warnings about illegal fundraising and fraud in crypto. Until 2025, the sector was unregulated, which officials saw as a risk to financial security and consumer protection . However, the government’s stance has evolved to active engagement and support (with regulation) rather than outright suppression. The fact that Vietnam passed a comprehensive digital assets law in 2025 with near-unanimous support shows a strong institutional commitment to embracing blockchain innovation while controlling risks. Regulators cite reasons such as protecting investors from scams (nearly 90% of crypto-related complaints involved fraud) and capturing lost tax revenue as motivation for the new framework . At the same time, there’s recognition that Vietnam could benefit enormously from blockchain tech and even potentially launch a CBDC (central bank digital currency) in the future to modernize payments . The overall government sentiment now is cautious optimism – crypto is seen as having economic potential if properly managed. This means your venture will be operating in a climate where authorities are willing to support genuine, compliant crypto businesses (through incentives and sandboxes) but will crack down hard on illegal or risky behavior. Staying in good standing with regulators and aligning your goals with Vietnam’s digital transformation agenda will be key to your long-term success.
Major Players and Ecosystem: Even under past restrictions, Vietnam has produced notable crypto projects and a thriving community:
- Global Exchanges: Since domestic exchanges were not legal, Vietnamese users heavily use international platforms like Binance, OKX, Huobi, and Bybit. In fact, Vietnam was the fourth-largest user base on Binance by trading volume in 2023 . Most trading is done via P2P (peer-to-peer) markets on these platforms, converting VND to stablecoins (like USDT) to trade – a practice common but until now unregulated . Your company should be aware that these platforms dominate liquidity; any local trading service you offer would need to compete with their presence or perhaps collaborate with them.
- Local Exchanges and Startups: A few local crypto exchanges/startups have operated in a limited capacity. For example, Remitano (a P2P exchange) has been used in Vietnam, and startups like VNDC (a Vietnam dong-pegged stablecoin and trading app) gained users, though they operated without official sanction. Additionally, Coin98 (a Vietnamese-founded DeFi platform and wallet) and Kyber Network (founded by Vietnamese developers, now a global DeFi project) are success stories showing local talent in blockchain. Vietnam is also home to Sky Mavis, the company behind Axie Infinity, a world-famous NFT game – this showcases local blockchain innovation (though the company is registered offshore). These examples indicate a strong developer community in Ho Chi Minh City and Hanoi for blockchain. Engaging with such existing players can provide partnerships or talent for your venture.
- Blockchain Associations: The Vietnam Blockchain Association, established in 2022 under the Ministry of Home Affairs, has been a bridge between the crypto industry and the government. In July 2025, it rebranded as the Vietnam Blockchain and Digital Assets Association (VBA) to reflect an expanded focus on digital assets in general . The VBA works closely with regulators in shaping policy and also provides networking for companies. Joining this association would be highly beneficial – it keeps you informed of legal updates and connects you with key industry stakeholders .
- Public Awareness and Education: Vietnamese media (like Vietnam News, Thanh Nien, VNExpress, etc.) have increased coverage of crypto – both highlighting opportunities and warning of risks. There’s also an emerging startup scene around blockchain – hackathons, meetups (e.g., Fintech meetups in HCMC), and university clubs (RMIT University in Vietnam even has a FinTech-Crypto hub for students ). This means talent is growing, and public understanding is improving. Still, given many users lack deep technical knowledge , a company that positions itself as a transparent and educational resource (in addition to doing business) can build goodwill.
Government Initiatives: The government has launched initiatives like the National Blockchain Strategy (Decision 1236/QD-TTg) aiming to make Vietnam a regional blockchain leader by 2030 . Ho Chi Minh City and Da Nang have been earmarked to host International Financial Centers (IFCs) which will allow pilot trading of digital assets and other fintech innovations in special zones . This indicates potential geographic hubs for crypto business. Saigon (HCMC) in particular is expected to be Vietnam’s crypto-finance hub, so being based there (as you plan) is strategic. Keep an eye on any “sandbox zones” or tech parks in Saigon that focus on blockchain – setting up in such zones might grant you easier regulatory clearance or tax breaks.
Takeaway: Vietnam’s crypto landscape is vibrant and rapidly maturing. There is a huge user base and interest in crypto, but also a history of risky trading practices due to lack of regulation. Now, with law catching up, the environment is poised for more stable growth. Your treasury company can tap into a large market of crypto-aware individuals and businesses. By understanding local attitudes – embracing innovation but wary of scams – you can tailor your approach (for example, emphasize security and compliance as your differentiator). Also, leverage the local ecosystem: attend Vietnam’s blockchain conferences (e.g., Vietnam Blockchain Week, Techfest Vietnam’s Fintech Summit ), connect with domestic crypto communities, and perhaps collaborate with established Vietnamese blockchain firms for mutual benefit. A thorough grasp of the market sentiment and key players will inform everything from your marketing to partnership strategy.
3. Plan Secure Infrastructure and Custody for Digital Assets
Managing a Bitcoin treasury means safeguarding potentially significant sums of digital assets. In Vietnam (as anywhere), infrastructure and security are paramount. You will need robust solutions for cold storage, custody, and cybersecurity to protect assets from theft or loss. Below are best practices and options:
Cold Storage & Self-Custody: For a treasury-focused company, cold storage (offline wallets) is considered a gold standard for security. Cold storage means keeping your Bitcoin private keys offline – e.g. on hardware devices or air-gapped computers – to minimize hacking risk. Popular hardware wallets include Ledger, Trezor, or Coldcard, which store keys securely offline. You should implement multi-signature (multi-sig) wallets for corporate funds: this requires multiple designated approvals (e.g. 2-of-3 or 3-of-5 keys must sign) for any transaction. Multi-sig greatly reduces the risk of one person misusing or losing a key. For example, the company could distribute keys among trusted executives or even store one with a third-party escrow agent, so no single point of failure exists. Plan for secure physical storage of backup seed phrases (splitting the secret and storing in bank vaults or secure locations in different cities). Vietnam’s climate (humid, risk of fire/flood in some areas) means you should use waterproof, fireproof storage devices for any written backups.
Third-Party Custody Solutions: If managing large assets or if you prefer professional custody, consider using reputable custodial services. Globally, firms like BitGo, Coinbase Custody, Fireblocks, or regional banks in crypto-friendly jurisdictions (Singapore’s DBS, Switzerland’s Sygnum, etc.) offer institutional-grade custody. These custodians often provide insurance coverage for digital assets and have rigorous security (multi-sig, HSMs, etc.). Using a custodian can also ease audit and reporting, since they can provide third-party attestation of balances. The downside is cost and reliance on an external party. In Vietnam, local banks currently do not yet offer crypto custody (as of 2025), but this could change as regulations roll out – Vietnam’s Bank for Investment and Development (BIDV) and others are custodians for traditional assets , and they might extend services to digital assets in the future. For now, you might use a custody provider in a jurisdiction like Singapore or Switzerland that is accustomed to servicing Southeast Asian clients, if you want assets held outside Vietnam. Ensure any custodian you use complies with Vietnam’s upcoming VASP (virtual asset service provider) rules or is willing to help you with compliance reporting.
Security Measures: Whether you self-custody or use a third party, implement comprehensive security policies:
- Access Controls: Limit the number of people with access to private keys. Use hardware wallets for any hot wallets (online wallets) and enforce multi-factor authentication for all systems. Maintain an authorization protocol for asset transfers (e.g., any transfer above a threshold requires multiple sign-offs).
- Cybersecurity: Invest in high-quality firewalls, anti-malware, and network monitoring. Any system that interacts with crypto (even for monitoring balances) should be kept isolated and secure. Consider hiring a cybersecurity firm to do penetration testing on your infrastructure. Vietnam has skilled cybersecurity professionals; you can find local firms to audit your setup. Given the government’s focus on cybersecurity for digital asset companies, having strong measures will also help in license approval and trust .
- Custody Procedures and Audits: Develop clear custody procedures (document how keys are generated, stored, backed up, rotated if needed, and destroyed if necessary). Perform regular audits of your asset balances and reconcile them with your records. This will help in internal control and any regulatory inspections. It’s wise to have an external auditor (possibly one of the accounting firms familiar with crypto) verify your holdings periodically.
- Insurance: Look into insurance policies for crypto holdings. Some global insurers offer coverage for digital asset theft or loss (usually if assets are held with an approved custodian or if certain security standards are met). While insurance adds cost, it can protect your treasury against catastrophic loss and give confidence to any clients or partners.
- Compliance & Monitoring: Use blockchain analytics tools to monitor your Bitcoin addresses for any suspicious activity. Since Vietnam will enforce AML, you should screen any incoming or outgoing transactions (e.g., if you ever accept BTC from others or send out) against sanction or illicit activity lists. There are tools (Chainalysis, Elliptic, etc.) that can integrate into your system for compliance monitoring.
To summarize the storage and custody options, here’s a comparison:
| Storage Option | Description | Pros | Cons |
| Self-Custody (Cold Storage) | Hold private keys yourself on hardware wallets or offline devices. Use multi-sig for added safety. | Complete control of assets; not reliant on third parties. No internet exposure (hack-resistant). | Requires deep expertise in security; risk of human error (lost keys if not backed up properly). No insurance by default; all responsibility on you. |
| Third-Party Custodian | Use a professional custodian (bank or crypto firm) to hold assets on your behalf. They manage keys and security. | Expert security protocols, insurance coverage often available, easier compliance reporting (they provide statements). | Custody fees can be high. You must trust the custodian’s solvency and honesty. Limited immediate access to coins (formal withdrawal process). |
| Exchange or Hot Wallet (not recommended for treasury) | Keeping funds on a crypto exchange or online wallet for liquidity. | Convenient for trading or quick access to funds; user-friendly. | High risk of exchange hacks or collapse (e.g. FTX). You don’t control keys (“not your keys, not your coins”). Typically not insured for losses. |
For a treasury company, you will likely use a combination: bulk of Bitcoin in cold storage (self-managed or via custodian) for long-term holding, and a small portion in hot wallets or exchanges for liquidity (to manage conversions to VND or other assets as needed). Always follow the principle of least exposure – only keep online what you’re willing to lose, and secure the rest offline.
Local Infrastructure Considerations: Setting up infrastructure in Saigon means also considering physical security and reliability. Ensure you have:
- Secure Office and Vault: If you hold hardware wallets on-site, use a quality safe. Consider safety deposit boxes at secure banks in HCMC for backups.
- Reliable Power and Internet: Frequent power outages or internet issues can disrupt operations. Invest in backup power (UPS, generator) and redundant internet connections for any online systems.
- Disaster Recovery Plan: Vietnam can face extreme weather (typhoons, flooding). Keep offsite backups of key data (in encrypted form). For example, one backup in HCMC, another in a different city (or country) to hedge against local disasters.
- Compliance with Local Cyber Laws: Vietnam has a Cybersecurity Law and data protection regulations. Storing customer data (if you have any) may require localization. Ensure any servers or cloud services you use comply with Vietnamese law (or get legal advice on cross-border data, if say you use cloud platforms outside Vietnam).
By establishing strong infrastructure and security from the outset, you not only protect your Bitcoin treasury but also build a credible reputation. Both clients and regulators in Vietnam will scrutinize your security posture. Demonstrating that you follow global best practices (cold storage, multi-sig, AML tools, etc.) can become a selling point and ease your path in licensing reviews .
4. Set Up Your Business Entity and Banking in Saigon
With legal groundwork and infrastructure in mind, the next step is forming the company and integrating with the traditional financial system. In Vietnam, establishing a business and obtaining banking services can be a complex process, especially for a crypto-related venture. Below is a step-by-step plan:
4.1 Choose a Legal Entity Type: In Vietnam, common entity types are Limited Liability Company (LLC) or Joint-Stock Company (JSC). An LLC (Vietnamese: Công ty TNHH) is simpler for a small number of investors (it can have single or multiple members), whereas a JSC (Công ty Cổ phần) is required if you plan to have many shareholders or eventually raise capital from the public. If you are a foreign investor, you’ll likely set up a Foreign-Invested Company under one of these forms. For a Bitcoin treasury company, an LLC is often sufficient unless you plan to invite many outside investors. Work with a local corporate lawyer or incorporation service to draft the needed documents (charter, investment registration if foreign, etc.).
4.2 Define Business Lines: When registering, you must specify business activities using Vietnam’s system of industry codes. Currently, there may not be a specific code for “cryptocurrency investment” as it’s new. Companies in the crypto space have used codes like Software Development, IT Services, Financial Consulting, or Investment Consulting. For example, you might register as a “Software consultancy and supply and software management” company, or “Other information technology and computer service activities”, which are broad enough to cover blockchain tech services. The new Digital Technology Industry law signals that blockchain and digital asset businesses are encouraged, so consult your lawyer if any specific new category is available. Avoid describing your business as a “currency trading” or “payment” service, as that could trigger denial (since non-fiat payment services require special licenses from the central bank). Instead, if you’re mainly managing your own treasury, you can frame it as a consulting or investment management business that uses proprietary capital to invest in digital assets. If you do plan to manage funds for others or operate a platform, make sure to disclose that and prepare for the additional licensing as discussed in Section 1.
4.3 Register the Company: The incorporation process involves applying for an Enterprise Registration Certificate (ERC) with the Department of Planning and Investment (DPI) in Ho Chi Minh City. If foreign-owned, you also need an Investment Registration Certificate (IRC) before the ERC. Provide all required documents (charter, list of members, registered address lease, etc.). Given the novelty of crypto, having a local law firm like Viet An Law or ASL Law (both experienced in tech startups) handle the paperwork can smooth the process . It typically takes a few weeks to a couple of months for full approval. As Vietnam’s government is keen on digital tech firms, they are likely to approve a properly documented application – there is no ban on establishing a company that deals with blockchain tech or holds crypto, especially after the new law (in fact, the government wants thousands of digital tech firms to be created) . Just ensure your submitted documents emphasize legal, permitted activities (avoid the word “exchange” or “trading platform” unless you have guidance to do so under the sandbox program).
4.4 Capital Contribution: Ensure you inject the charter capital you commit. If you are using foreign funds, you’ll need to open a capital contribution bank account in Vietnam to receive the incoming funds in foreign currency and convert to VND. Note that if you mention the source of funds comes from crypto, it may raise questions – it might be easier to bring in capital via normal bank transfer (e.g. from a foreign personal or corporate account after selling some crypto abroad), because Vietnamese authorities are still unfamiliar with valuing crypto contributions. Technically, you cannot contribute capital in-kind in the form of cryptocurrency because it’s not recognized as a fiat contribution or easily valued asset in legal terms yet. So you’d typically convert your Bitcoin to USD or VND, then inject as cash capital to the company’s bank account, and then later the company can purchase Bitcoin again on its own account. This ensures your company’s charter capital is properly recorded in VND as required.
4.5 Opening Bank Accounts: After getting your ERC, you will open a corporate bank account in Vietnam (in VND, and possibly a USD account if needed). This step can be challenging – Vietnamese banks have historically been cautious about businesses linked to crypto. To improve your chances:
- Choose the Right Bank: Some banks in Vietnam known for tech-friendly approaches include TP Bank, Vietcombank, and MB Bank, among others. TP Bank, for example, has experimented with blockchain for remittances (using Ripple) in the past, indicating an openness to blockchain technology. Foreign banks in Vietnam (Standard Chartered, HSBC, etc.) are conservative and follow global compliance; they might question crypto dealings as well. Smaller or newer banks (e.g. Timo digital bank, or local private banks) might be more flexible if you have a relationship.
- Be Transparent but Focused: When discussing your business with the bank, emphasize the software/technology aspect (“we develop blockchain software” or “we invest in digital technology projects”) rather than “we trade cryptocurrency”, to avoid alarm. Provide any business plan or the new law’s context if needed to show legality. Having your legal registration and possibly a letter from the Vietnam Blockchain Association vouching for your legitimacy could help.
- Compliance Documentation: Be prepared to provide extra documentation: the bank may ask for your company charter, identities of owners, and a declaration that you will comply with Vietnamese law (some banks have clauses prohibiting using accounts for cryptocurrency trading, due to past regulations). You might need to sign an undertaking not to use the account for illegal payment transactions. This is where you clarify that funds will be used for permitted investment and operating expenses, not for facilitating customer crypto payments.
4.6 Banking Transactions and Relationships: Once you have an account, maintain a good relationship with your bank. Assign someone in your team to liaise with the bank’s manager and clearly explain any unusual transactions. For example, if you plan to receive a large wire that came from selling Bitcoin abroad, consider informing the bank compliance officer in advance. It’s possible banks will still be wary of frequent crypto-related inflows/outflows. As of now, many Vietnamese crypto entrepreneurs use peer-to-peer methods to move money (like buying USDT via a P2P market and then trading crypto offshore) precisely because banks would scrutinize or block direct crypto exchange transfers. This may change after 2026 when licensed exchanges exist. In the interim, your treasury company can utilize OTC (over-the-counter) brokers or reputable P2P traders to convert VND to Bitcoin and vice versa, thereby avoiding flagging the bank. If you do so, always ensure to follow AML best practices on your side (check who you’re transacting with).
4.7 Utilizing the International Financial Center (IFC) and Sandbox: Since you are in Saigon, keep in mind HCMC’s upcoming International Financial Center pilot. The government intends to create an IFC with special regulations where digital asset businesses might get preferential treatment, regulatory exemptions, and easier foreign exchange rules . The IFC might be located in a specific area (potentially the new Thu Thiem financial zone or another district). If this materializes, consider registering your office or a branch in that zone to benefit from any eased constraints – for example, they mentioned sandboxes in IFC could even allow certain activities normally not allowed (with temporary exemptions) . Similarly, if your business model falls under the crypto sandbox pilot program, apply for that through the Ministry of Finance when applications open. Being admitted to the sandbox can grant you legal allowance to do things like operate a trading platform or custody service with some liability protections until full regulations are in place . It’s a way to work closely with regulators and demonstrate your solution in a controlled manner.
4.8 Accounting and Reporting: Once operating, maintain proper accounting records. Work with an accounting firm that knows how to account for crypto assets. In Vietnam, accounting standards for crypto aren’t defined yet, but presumably you’d treat Bitcoin as either an intangible asset or inventory on the books (until guidance comes). Keep records of all your crypto purchases (date, cost in VND) and sales (proceeds in VND) to calculate taxable gains. Also record any fiat transactions in the normal accounting software. You will need to file quarterly tax reports for VAT and corporate income tax (if any profit) and an annual financial statement audit if you’re sizable. Transparent and accurate financial reporting will also help if you later seek investments or partnerships.
4.9 Hiring and HR: As you establish the company, hire local staff or advisors who are familiar with Vietnam’s bureaucracy. A local accountant or finance manager who has dealt with the Tax Department can ensure compliance (for instance, how to report any crypto-related income, as currently it might be declared under “other income” in tax filings). If you plan to hire foreign experts for blockchain security or so, remember they can get a 5-year personal tax exemption under the new law incentives – coordinate with the tax office to avail that, which can help attract talent. Ensure all employees’ labor contracts and work permits (for foreigners) are properly handled, as any scrutiny could be higher on a crypto company.
4.10 Bank Relationships and Alternatives: Despite best efforts, if traditional banks remain difficult (this is a known pain point for crypto firms globally), consider alternatives:
- Use payment gateways or fintech services: Some Vietnamese fintech startups (like Momo, VNPay, etc.) dominate e-wallet payments. They usually link to banks though, so they might also restrict crypto-related uses. But you might use them for everyday VND transactions (paying vendors, salaries) while keeping big funds in crypto.
- Offshore banking for crypto: Some crypto companies in Vietnam use an offshore entity in a crypto-friendly jurisdiction (like Singapore, BVI, etc.) to handle crypto asset custody and then fund the Vietnam entity for operations. For example, you could have a Singapore company that interfaces with exchanges and banks there (where crypto banking is easier), and that company invests in the Vietnam subsidiary which actually does the local business. This adds complexity but is an option if Vietnamese banks impede you.
- Engage with the Vietnam Banks Association Fintech Club: There is a Fintech Club under the Vietnam Banks Association which discusses policy for fintech and possibly crypto integration . Networking there might connect you to bankers who are forward-looking and willing to support fintech/blockchain companies as clients.
In summary, incorporating and banking in Saigon will require careful presentation of your business and compliance with standard procedures. While Vietnam is opening up to crypto, some practical frictions remain at the bank level. With patience, local guidance, and by leveraging new pro-tech policies, you can successfully establish a legal entity and maintain a bank account for your treasury operations. This foundation allows your company to operate legitimately – paying employees, renting offices, entering contracts – while holding and managing Bitcoin as an asset on the side.
5. Implement Best Practices for Bitcoin Treasury Management
Managing a Bitcoin treasury is not just about buying and holding; it requires a strategic approach to ensure the company’s financial health and capitalize on opportunities while mitigating risks. Here are best practices for treasury management of Bitcoin and other digital assets:
Develop a Treasury Policy: Start by formulating a clear investment policy or guidelines for your crypto treasury. This document (approved by founders or the board) should outline:
- Allocation Strategy: Decide what portion of the company’s total reserves will be held in Bitcoin vs fiat or other assets. Given Bitcoin’s volatility, many companies opt to allocate a modest percentage of reserves to BTC (unless your business model inherently is crypto-centric). Determine an allocation that suits your risk tolerance – for example, “Our company will hold up to 50% of its excess cash in Bitcoin as a long-term store of value, with the remainder in stable instruments for liquidity.”
- Diversification: Though your focus is Bitcoin, consider whether to include other digital assets or stablecoins. For instance, keeping some funds in USD Coin (USDC) or Tether (USDT) can provide stability and liquidity for near-term obligations (since stablecoins are pegged to USD). However, be aware of counterparty risk of stablecoins and plan how to convert them to actual USD or VND when needed. You might also decide if you will invest in Ethereum or other top assets as part of treasury – if so, set maximum percentages for each asset.
- Hedging and Risk Management: Define if you will use any hedging instruments. For instance, you could use futures or options to hedge against extreme downside in Bitcoin price. Vietnam itself doesn’t have crypto derivatives exchanges (legally), but you could use international platforms carefully. If you prefer not to deal with derivatives, your policy might simply be “buy and hold” and ride out volatility. But ensure stakeholders understand the potential drawdowns. It may be wise to set some rebalance or trigger points – e.g., if Bitcoin value doubles and becomes, say, 70% of your total capital, you might rebalance (sell some to move into fiat or other assets) to maintain a target allocation. Conversely, if it crashes beyond a point, decide if you hold or if you need stop-loss rules (generally, long-term holders avoid selling at a loss, but have a plan).
- Liquidity & Cash Management: Treasury management isn’t just about investment; it’s also ensuring the company can pay its bills. Keep an adequate fiat working capital buffer for operating expenses (rent, salaries, etc.) for at least 6-12 months, so you’re not forced to liquidate Bitcoin at a bad time. You can also keep a portion of crypto in highly liquid form (on an exchange or readily convertible) for emergency cash needs.
- Approval Process: Define who can authorize movements of funds. For example, any transfer from cold storage might require CEO + CFO approval. This should be in writing to prevent any single person from making rogue transactions.
- Accounting Treatment: Decide on how you will account for Bitcoin holdings – likely as an intangible asset recorded at cost minus impairment (per international accounting standards), unless local authorities issue different guidance. Implement internal tracking of market value versus cost basis to understand your real position.
Secure Acquisition and Storage: When acquiring Bitcoin for your treasury, do so through reputable channels. Large purchases can be done via OTC desks or through limit orders on exchanges to avoid slippage. Always withdraw coins to your controlled wallets (not your exchange account) promptly after purchase. Make sure your multi-sig and cold storage arrangements (as discussed in Section 3) are in place before accumulating significant holdings. Many treasury-focused firms use a “90/10 rule”: e.g., keep 90% in deep cold storage, 10% in hot wallets for liquidity/trading needs. Adjust these ratios based on your operational needs.
Documentation and Reporting: Keep thorough records of all treasury transactions:
- Log every purchase: date, amount of BTC, price in VND or USD, which wallet it went to, and who approved.
- Do the same for any sale or transfer. This helps with auditing and tax calculations (profit/loss).
- Periodically (e.g., monthly or quarterly), produce an internal Treasury Report showing current holdings, their market value, and any notable changes. This is useful for management or board oversight.
- If required by law in future, be prepared to declare digital asset holdings. For instance, auditors in Vietnam might ask if the company holds any “intangible assets” like crypto – full transparency with your auditors will ensure your financial statements are accurate. Under the new legal framework, companies might have to disclose crypto holdings for regulatory reasons too (especially if a listed company or large enterprise).
Risk Mitigation Strategies: Key risks to manage in a crypto treasury include price volatility, cyber threats, and regulatory changes:
- Volatility: As noted, maintain enough fiat to cover short-term needs. You can also mitigate volatility by dollar-cost averaging (DCA) your Bitcoin purchases over time instead of buying all at once, to smooth out price fluctuations. Some companies schedule monthly BTC buys with excess cash. Avoid over-leveraging or borrowing to buy crypto – that can be dangerous in downswings.
- Custody Risk: Use multi-sig and distribute keys (covered in Section 3). Additionally, consider having a disaster recovery wallet: for instance, an emergency phrase held by a trusted third party (like an escrow attorney or a corporate director abroad) that could be used to recover funds if your primary team or facility encounters a catastrophe. Test your backup recovery process periodically (e.g., do a drill to restore from seed phrase on a new device to ensure it works).
- Insurance and Reserves: If possible, set aside a reserve fund in case of unexpected events – whether that’s a reserve of fiat or even a small reserve of extra Bitcoin that isn’t counted as core treasury. This could be tapped if you faced a loss or need to respond to a new regulation cost. Also maintain liability insurance for the company’s directors/officers (D&O insurance), which might provide some coverage if there are legal actions related to crypto holdings (for example, if shareholders or clients claim mismanagement of assets).
- Compliance Monitoring: Keep an eye on regulatory changes that might affect treasury. For instance, if Vietnam issues a rule requiring businesses to register crypto holdings or implement certain security standards, be ready to comply. Given that Vietnam’s crypto rules are new, expect some evolution and possibly reporting duties by 2026 . Being proactive (voluntarily following best practices from more mature jurisdictions like the US or Singapore) will put you ahead.
Earning Yield vs. HODLing: A common question for treasury management is whether to earn yield on crypto holdings (through staking, DeFi lending, etc.) or simply hold (the “HODL” strategy). Yield opportunities exist – for example, some centralized platforms or DeFi protocols offer interest if you lend your Bitcoin or stablecoins. However, after events like platforms going bankrupt (e.g., Celsius, etc.), counterparty risk is a big concern. As a conservative treasury, you might decide not to chase yield with core assets, to avoid the risk of losing funds. If you do attempt to earn yield, do it with a small portion and only via reputable venues. Another avenue could be participating in Bitcoin’s Lightning Network or other emerging tech if it suits your business (though that’s more complex and experimental). For most treasury-focused companies, the primary strategy is long-term holding, under the belief that Bitcoin will appreciate in value and serve as a hedge. Make sure this philosophy is agreed upon by your company’s leadership and possibly communicated to any investors or stakeholders so they understand why you hold volatile assets on the balance sheet.
Example of Treasury Practices: You may draw inspiration from companies like MicroStrategy (USA) or Meitu (China), which hold significant Bitcoin in their treasuries. They follow strict custody procedures and are very transparent in financial reports about their crypto. While the scale might differ, the principles of security, long-term outlook, and transparency apply equally. In Vietnam, there may not yet be prominent examples of public companies holding Bitcoin (given regulations were not in place), so your company could be one of the pioneers in corporate Bitcoin treasury in the country. This is an opportunity to set industry standards – by implementing top-notch practices now, you position yourself as a thought leader in this niche.
Educating and Onboarding Traditional Stakeholders: If you have co-founders, employees, or investors who are not crypto-native, incorporate training and guidelines for them. For instance, if part of salaries might be paid in crypto (only do so if legally allowed and with employee consent, since officially salaries should be VND), or if bonuses will be in BTC, ensure they understand how to use wallets. More importantly, internally make sure everyone understands the rationale and risks of a Bitcoin treasury strategy. Document an internal FAQ or policy explaining why the company holds Bitcoin, what the plan is in different market conditions, and who to contact if, say, something seems amiss in the wallet (so employees know the chain of command for reporting issues). This kind of preparedness fosters a culture of responsibility around digital assets.
By adhering to these best practices, your Bitcoin treasury company can effectively manage its digital assets in a way that supports business growth and financial stability. Treasury management is an ongoing process – regularly review your strategies as market conditions and regulations change. Vietnam’s crypto market might mature quickly in coming years, offering new tools (like maybe local custodial services or crypto-based financial instruments) that you can integrate into your treasury approach. Stay agile and informed.
6. Assess Risks, Opportunities, and Strategic Positioning
Operating a Bitcoin treasury company in Vietnam carries both significant risks and promising opportunities. Below, we outline the key considerations and how to strategically position your company for growth while managing potential pitfalls:
Major Risks and Mitigations:
- Regulatory Risk: Although Vietnam is legalizing crypto, the regulatory framework is new and could change. There may be uncertainty in detailed regulations (tax codes, licensing rules) or shifts if authorities perceive problems. Mitigation: Stay closely engaged with regulators and industry associations. By actively participating in the Vietnam Blockchain & Digital Assets Association, you can get early warnings on regulatory changes and even voice industry concerns (for example, lobbying for reasonable tax rates so as not to drive business offshore ). Ensure full compliance with all known rules – being a model compliant company gives you credibility and likely leeway if rules tighten. Also, diversify regulatory risk by possibly maintaining part of the operation or assets in friendlier jurisdictions as backup (as mentioned, an offshore arm, if needed).
- Market Volatility: Bitcoin’s price can swing wildly. A sharp downturn could affect your company’s balance sheet and ability to raise further capital or meet obligations. This is intrinsic to a Bitcoin-focused business. Mitigation: As discussed in treasury practices, keep adequate fiat reserves and consider hedging critical amounts. Manage expectations of investors/employees that there will be volatility. Conduct stress tests – e.g., “What if BTC drops 50%? Are we still solvent and operational?” If not, adjust treasury allocations. On the flip side, if BTC spikes and you have outsized gains, have a plan to possibly take some profit to secure your operating budget for years ahead.
- Security and Custody Risk: The risk of hacking, theft, or internal fraud is non-negligible. A single security failure could be catastrophic (losing the treasury). Mitigation: Use the layered security approach from Section 3 (cold storage, multi-sig, audits). Additionally, enforce strict internal controls: background check any personnel who handle keys, use dual control (no one alone should be able to execute a transfer), and consider bonding or insurance for employees in sensitive roles. Regularly review logs of wallet access if any. If you ever discover a breach or anomaly, act immediately – have an incident response plan (who to call, whether to alert authorities, etc.). Vietnam has cybercrime units; in case of theft you might coordinate with them, though prevention is far better as crypto theft recovery is extremely difficult.
- Banking and Liquidity Risk: As noted, domestic banks might freeze or shut your account if they suspect violations, which could lock up your VND funds. Also, converting large amounts of crypto to fiat quickly could be challenging under current infrastructure. Mitigation: Maintain relationships with multiple financial platforms. For instance, have at least two bank accounts (maybe one local bank, one foreign bank branch) for redundancy. Build a track record with your banks by maintaining a good average balance and being transparent; this can make them more comfortable. Also line up a network of OTC partners or global exchange accounts such that if you needed to liquidate a large position, you can do so across several venues without depending on one channel. Over time, as Vietnam licenses local exchanges, form relationships with one of them for local liquidity.
- Reputation and Trust: Being a crypto company, you may face skepticism from traditional businesses or the public. Any association (even unwarranted) with scams could harm you. Also, if your company manages others’ assets at some point, trust is everything. Mitigation: Build a strong brand based on transparency and compliance. Publish information about your security practices or even voluntary audits to build trust. Engage in community education to differentiate yourself from the “get-rich-quick” schemes. For example, host seminars or webinars on safe crypto management – this positions you as a legitimate thought leader. Keep an eye on media narratives; if any negative press arises, address it openly. Align with reputable partners (tech firms, established financial institutions in Vietnam) to enhance credibility by association.
- Talent Risk: The field of blockchain is competitive globally. You might struggle to find or retain talent (developers, security experts) in Vietnam as demand grows. Mitigation: Take advantage of Vietnam’s talent initiatives – the government is funding tech workforce development . Offer attractive conditions, like the fact that foreign experts get 5-year tax exemption , to recruit internationally. Create a positive, innovative work culture to retain staff (who might otherwise jump to the next crypto startup). Additionally, continually train your team on both technical and compliance topics, so they stay up-to-date and feel invested in.
Key Opportunities:
- First-Mover Advantage: The legalization of crypto is very recent. By starting now, you position yourself among the first licensed and compliant crypto companies in Vietnam. This can give you a head start in capturing clients who need trustworthy crypto treasury services or in building relationships with authorities. As the law rolls out, many traditional companies might look for expertise to help manage digital assets – you could become a go-to advisor or service provider in that niche if you establish your brand early.
- Growing Market & Adoption: Vietnam’s large population of crypto users (17–21 million) indicates a huge domestic market if you ever offer services. Even if your core model is managing your own treasury, there might be opportunities to expand into treasury services for other companies or high-net-worth individuals. Many SMEs or even larger firms in Vietnam might start allocating to Bitcoin once it’s legally recognized – they could outsource the custody or management to specialists. By mastering this domain, you could offer treasury management as a service (with proper licensing). The sheer volume of crypto activity (over $100B inflows yearly) suggests that any value-add service has a big potential client base.
- Government Support and Incentives: The Vietnamese government is providing generous incentives to tech companies (tax breaks, R&D grants, land use benefits) . Your company can tap into these:
- Enjoy tax incentives (10% CIT, etc.) by qualifying as a digital tech enterprise.
- Apply for grants or subsidized loans for developing blockchain solutions (perhaps if you’re building proprietary security software or contributing to national infrastructure, there could be funding).
- Benefit from tech zones and incubators: HCMC has the Saigon Hi-Tech Park and various innovation programs. These often provide free/cheap office space, mentoring, or connections to investors.
- With crypto being a strategic sector, you might also get opportunities to collaborate on government pilots (for example, helping with a local e-government blockchain project or a state-owned bank’s crypto pilot). Such collaboration could raise your profile significantly.
- International Expansion via Vietnam: Vietnam aims to be a regional hub. The new law even mandates setting up Vietnamese digital tech offices abroad to help companies go global . As you grow, you could leverage Vietnam as a base with lower costs and strong developer talent, while reaching customers regionally. For instance, you might manage crypto treasuries for companies in nearby ASEAN markets that don’t yet have clear regulations, using Vietnam’s legal status as a backbone. Also, any future IFC in HCMC could attract foreign financial institutions – partnerships or services with those entrants is an opportunity.
- Innovation in Services: A “Bitcoin treasury company” can evolve into more. For example, you could develop financial products around Bitcoin: such as collateralized lending (if legal – e.g., allowing companies to borrow VND against their Bitcoin holdings), or providing consulting to traditional treasurers on how to safely get into crypto. There’s also an opportunity in education and software – you might create internal tools for managing crypto that you can license or sell to others (like a treasury management software specialized for digital assets). Being in a frontier sector means you can define new services as the market matures.
Strategic Positioning for Growth:
- Compliance as Competitive Edge: Make strict compliance and security your brand. When licensed exchanges and custodians come online by 2026, competition will increase. Companies that can demonstrate they have never had a security breach and have always complied with laws will gain trust from larger clients (like banks or funds that may enter crypto). Consider obtaining relevant certifications in the future – for example, an ISO 27001 certification for information security, or getting audited by reputable firms – to distinguish yourself.
- Networking and Alliances: Position yourself at the center of the crypto-finance network in Vietnam. Join not just the blockchain association, but also general fintech associations, chambers of commerce, etc. If any sandbox program or advisory committee is looking for private sector participants, volunteer. By being in those circles, you can influence and anticipate regulations (for instance, advocating to keep taxes moderate to prevent capital flight ). Forge alliances with established finance players: maybe partner with a local bank to help them develop crypto custody (as a tech provider), or with a big auditing firm to be their go-to crypto expert.
- Customer Focus (if applicable): If eventually you manage crypto for others, focus on customer education and transparency. Given many Vietnamese crypto users have only used overseas platforms, highlight local presence and support as a benefit. Also, maybe target institutional clients (like Vietnamese SMEs or family offices) who want exposure to Bitcoin but don’t know how – your treasury services could fill that gap, and being a domestic, legally compliant provider will be a major plus as foreign platforms might face restrictions to operate.
- Adapt and Diversify: While Bitcoin is your mainstay, be open to future trends. For example, if Vietnam legalizes or encourages tokenized assets or stablecoins, you could incorporate those into your business. The law is also looking at DeFi and NFTs under review ; if you have expertise, you could expand into managing a diversified digital asset portfolio or building products in those realms. Always align with where the government focus is – currently they even classify blockchain as a “strategic technology” like AI , meaning there will be ongoing support. If you prove a concept in Bitcoin treasury, you could be well-placed to extend into related strategic areas (maybe help enterprises tokenize some assets or implement blockchain record-keeping for treasuries, etc.).
Risks vs Opportunities Table: For a quick overview, consider the following summary:
| Risks | Mitigation/Notes | Opportunities | How to Leverage |
| Regulatory changes or restrictive rules | – Stay compliant and engage with regulators– Use sandbox and association to influence policy | Government support and clear legal status now | – Use tax incentives and grants – Be a first-mover in a regulated environment |
| Bitcoin price volatility | – Maintain fiat reserves and hedge as needed– Set clear treasury policy | Growing crypto adoption (millions of users) | – Market your services to new crypto adopters– Educate businesses entering crypto |
| Security breaches or loss | – Best-in-class security (cold storage, multi-sig, audits)– Insurance for assets | Low competition initially (few local firms) | – Capture market share early– Define industry security standards as a leader |
| Banking restrictions | – Build relationships with multiple banks– Consider offshore structures for flexibility | Emerging financial infrastructure (IFC, possible bank custody) | – Position to partner with banks on crypto solutions– Possibly join IFC projects to get benefits |
| Talent scarcity | – Offer competitive incentives (use tax breaks for experts) – Train in-house talent via courses | Strong local tech talent pool, government training support | – Hire from Vietnam’s young developer community– Engage in tech events to attract talent |
The key is to maximize opportunities while having contingency plans for risks. Vietnam’s fast evolution in this field means flexibility is important. Continually revisit your SWOT (Strengths, Weaknesses, Opportunities, Threats) analysis as you progress. For instance, if by 2027 Vietnam decides to make a very crypto-friendly move (like allowing banks to hold crypto or implementing clear crypto accounting standards), be ready to pivot and expand under those favorable conditions. Conversely, if some global crypto crisis occurs that leads Vietnam to impose stricter controls, have a plan to possibly scale down risk or diversify business lines temporarily.
In conclusion of this section, by being proactive, well-connected, and resilient, your Bitcoin treasury company can turn potential risks into managed challenges and ride on the wave of opportunities in Vietnam’s burgeoning crypto industry. The strategic positioning you establish in these early days will define your long-term trajectory – and given Vietnam’s ambition to be a leader in digital assets, positioning yourself aligned with that national vision will serve you well.
7. Leverage Local Advisors, Networks, and Support Resources
Building a successful company is not a solo endeavor – especially in a nuanced field like crypto in Vietnam. Engaging local advisors, incubators, and experts will provide invaluable guidance and credibility. Here are key resources and how they can support your journey:
- Vietnam Blockchain and Digital Assets Association (VBA): This is the official industry association recognized by the government (under the Ministry of Home Affairs) . The VBA (formerly Vietnam Blockchain Association) focuses on creating a legal framework and promoting blockchain adoption in Vietnam. They are deeply involved in policy discussions and also organize industry events. How they help: By joining the VBA, you gain a direct line to regulatory updates and a platform to voice any challenges your business faces. The association frequently liaises with ministries to provide industry feedback. They also host networking sessions with Vietnam’s top blockchain entrepreneurs and projects . For example, if you need clarification on a licensing process, VBA can assist or connect you to the right officials. Contact them via their website ( ) or attend their meetups in HCMC and Hanoi. Being an active member can also bolster your company’s legitimacy in the eyes of customers and regulators.
- Legal Advisors (Law Firms): Engage a local law firm with expertise in fintech/crypto to navigate licenses, contracts, and compliance. Notable firms include:
- Tilleke & Gibbins (Vietnam): A regional firm whose lawyers are well-versed in crypto regulation (they’ve published insights on the crypto sandbox and legal frameworks ). They can assist in licensing applications, drafting compliance policies, and even intellectual property (if you develop tech). A specific contact is Ms. Tram Nguyen, head of Tilleke’s Vietnam corporate practice, who has written on crypto regulations .
- YKVN or VILAF: Top domestic firms that have fintech experience. YKVN has published thoughts on classifying crypto in Vietnam and can provide high-level legal strategy .
- Viet An Law, ASL Law: Medium-sized firms explicitly mentioned as resources for crypto startups . They can help with company setup, work permits, and ongoing legal compliance.
- ANVI Law: Led by lawyers like Mr. Truong Thanh Duc (quoted in Vietnam Law Magazine) who understand crypto asset legal status . They could advise on civil law aspects (e.g., how to structure custody agreements or handle crypto in wills, etc., since he noted crypto can be inherited like other assets now).
How they help: These legal advisors will ensure your company’s activities and documentation are sound. They can represent you in discussions with regulators for sandbox entry or dispute resolution. Also, for any contracts (say you custodialize assets for a client, or partner with a bank), having a lawyer draft proper terms to cover crypto-specific issues (like defining ownership of private keys, liability for hacks, jurisdiction in case of disputes) is crucial.- Local Incubators and Startup Hubs: Vietnam has a growing startup ecosystem. While not all are crypto-focused, many welcome blockchain projects:
- Saigon Innovation Hub (SIHUB): A HCMC-backed startup incubator that sometimes supports emerging tech startups. They provide mentorship and can connect you to governmental startup support programs.
- National Innovation Center (NIC): A government initiative under the Ministry of Planning and Investment, set up hubs in Hanoi (and planning one in HCMC). They focus on Industry 4.0 tech including blockchain. Being in their program might give you access to mentorship and investor networks.
- Vietnam Silicon Valley (VSV) Accelerator: An older program which sometimes takes in fintech startups. While primarily seed-stage, they have a network of entrepreneurs and mentors.
- Blockchain-focused incubators: Keep an eye out for any specialized programs. For example, a program called “Vietnam Blockchain Week” or hackathon events can be a place to meet investors and advisors. In 2025, Vietnam hosted Southeast Asia’s largest blockchain gathering – events like this attract international incubators (like Binance Labs or others) who might pick Vietnam startups for investment or mentoring.
How they help: Incubators can provide early-stage advice on business model, pitch refinement, and introductions to venture capital if you seek funding. Even if you’re self-funded, having seasoned mentors pressure-test your strategy is valuable. They can highlight local business culture nuances, hiring tips, etc. Also, via incubators, you might meet your future CTO or advisor who has done a similar project.- Financial and Tax Advisors: Crypto accounting is tricky. Engaging an accounting firm or consultancy that understands both Vietnamese tax law and crypto will save headaches. Big Four firms (PwC, KPMG, etc.) in Vietnam have fintech advisories – for instance, PwC Vietnam has published materials on blockchain’s impact. There are also specialized crypto tax advisors emerging (for example, a company like Kryptos Vietnam published a crypto tax guide in 2025 noting that most crypto transactions were not yet taxed ). Consider hiring a CPA who’s personally knowledgeable in crypto or using an international tax advisor for complex cross-border issues. How they help: They’ll ensure you’re meeting any current tax obligations (e.g., if you realize trading profits, how to declare them properly given lack of explicit forms yet) and position you to benefit from tax incentives. As laws update, they’ll help adapt your tax strategy. Plus, when dealing with converting crypto to fiat, they can advise on documentation needed to satisfy the tax authority (General Department of Taxation) that proper taxes are paid .
- Banks and Finance Partners: We’ve discussed banks at length; consider also making allies inside banks. For instance, if you know someone in the fintech division of a local bank or at the State Bank, their informal advice can be gold. Vietnam’s banking sector is somewhat old-school, but many are looking at digital transformation. If you can find a champion who finds your project interesting (perhaps you offer to collaborate on research or training for their staff about blockchain), that relationship could ease future banking or even lead to partnerships (like a bank using your company as a consultant for their own crypto initiatives).
- Local Tech Communities and Talent Pipelines: Connect with Vietnam’s vibrant developer communities to recruit talent and advisors:
- Join or sponsor meetups like Saigon Bitcoin Meetup (if exists), or Fintech Vietnam Meetup .
- Universities: HCMC is home to universities like RMIT Vietnam (which has fintech programs) and Bach Khoa (HCMC University of Technology) where many blockchain developers come from. Professors or student club leaders there could become advisors or interns.
- Online forums: The crypto community in Vietnam often discusses on platforms like Facebook groups or Telegram channels. While one must filter signal from noise, being present there can give insight into retail trends and also find enthusiastic local supporters.
- Advisors with Government or Finance Background: It may be wise to have an advisory board that includes someone with a regulatory background (e.g., a retired official or a fintech policy expert) and someone from traditional finance (e.g., a former bank executive). They can guide you on how to approach compliance and gain legitimacy. For example, an advisor who previously worked at the State Securities Commission or SBV can help interpret new regulations practically. Another example: a respected entrepreneur in Vietnam’s tech scene lending their name as an advisor can boost credibility. Leverage your network or the associations to find such figures.
- Notable Local Figures: Some known proponents of blockchain in Vietnam include:
- Truong Gia Bao – Chairman of the Digital Transformation Alliance and Sustainable Blockchain Initiative (he was quoted discussing Vietnam’s crypto market being “wide but not deep” ). He’s involved in promoting blockchain education. Such individuals might advise on industry direction or help connect to policy discussions.
- Nguyen Dinh Thang – Chairman of the Vina Fintech Club (under the Bank Association) . He has spoken on legal risks in P2P trading. Engaging with the Fintech Club could provide banking sector insights.
- Phan Duc Trung – Chairman of VBA . As association head, he’s actively shaping the 5-year blockchain strategy. While he’s busy, his speeches (often public) are useful to follow; he might also connect serious projects with resources.
- Local Crypto Entrepreneurs: e.g., the founders of Kyber Network (Loi Luu, etc.) or Coin98 (Thanh Le) are Vietnamese. While they operate globally, they sometimes interact with local community or invest in local startups. Networking with them at events could open doors to mentorship or funding.
Utilizing Vietnamese Official Resources: Don’t forget to use official sources of information to guide you:
- Vietnam News & Government Portals: Keep an eye on sources like Vietnam News (vietnamnews.vn) and Vietnam Plus (vietnamplus.vn) for any announcements on crypto regulations or government initiatives. For example, Vietnam News and Vietnam+ have covered the need for legal framework and progress on laws . Official statements often appear there or on the Government Web Portal (chinhphu.vn).
- Ministry of Finance & State Bank: These bodies might issue circulars or guidelines as the law is implemented. It’s wise to have someone translate any new Vietnamese directives for you if you’re not fluent. Being proactive – for instance, if MoF calls for feedback on a draft crypto decree, submit your company’s constructive comments – positions you as a serious local player.
- General Department of Taxation: Since tax is a concern, monitor if the tax authority issues any guidance on crypto. Given FATF pressures, they might release guidance soon. Ensure your tax advisor checks the official Vietnamese text of any such guidance (as sometimes the local language version appears first).
Building Relationships with Incubators/Investors: If you foresee needing capital or scaling up, cultivate relationships with venture capital funds in Vietnam that are blockchain-friendly. Some names include VCs like VinaCapital Ventures (they’ve looked at fintech), Ascend Vietnam Ventures, and global crypto funds now eyeing Vietnam due to the legal changes. Being connected to an incubator or association often facilitates introductions to such investors when the time is right.
In sum, make full use of the local support ecosystem:
- Advisors ensure you do things right and efficiently (saving you from costly mistakes in unfamiliar bureaucracy).
- Networks and associations keep you informed and give you influence beyond your company’s size.
- Incubators and events plug you into the innovation community where you can find partners or team members.
- Official agencies and experts keep you aligned with Vietnam’s direction and help in obtaining any needed approvals.
By surrounding your venture with a strong support system, you significantly increase your chances of success. Vietnam’s business culture values relationships and community – being an active, contributing member of the tech and fintech community will not only boost your company’s profile but also likely open up opportunities that wouldn’t arise in isolation.
Conclusion:
Establishing a Bitcoin treasury company in Saigon, Vietnam is an ambitious endeavor at a historic time. Vietnam is moving from a regulatory gray area to a pioneering legal framework for crypto, offering clarity and incentives for businesses . By carefully adhering to legal requirements (licenses, compliance, tax), understanding the local crypto market dynamics, implementing robust technical infrastructure, and following sound financial management practices, you can build a solid foundation for your company. Equally important is leveraging the favorable climate – government support for digital innovation and a large, crypto-savvy population – to seize opportunities for growth and partnerships .
This guide outlined each aspect, from setting up the legal entity and bank accounts to securing your Bitcoin assets and navigating potential risks. The journey will involve engaging with a broad spectrum of stakeholders: regulators, banks, customers, and the community. As you proceed step-by-step:
- Legal/Regulatory: Obtain the necessary approvals and embed compliance into your company DNA from day one.
- Market Landscape: Stay attuned to Vietnam’s fast-evolving crypto scene – be ready to adapt as the country’s policies and market players develop.
- Infrastructure/Security: Treat security as non-negotiable, invest in best-in-class solutions to protect assets.
- Business Operations: Build a compliant company structure with good banking relations and transparent financial practices.
- Treasury Strategy: Manage your digital assets prudently, balancing growth with caution.
- Risk & Opportunity: Continuously manage risks while positioning to capitalize on Vietnam’s pro-blockchain momentum.
- Local Support: Don’t go it alone – use Vietnam’s rich pool of associations, experts, and talent to bolster your venture.
By following this roadmap, you will be well on your way to launching a successful Bitcoin treasury company in Saigon. You’ll be operating at the cutting edge of finance in Vietnam, and with that comes the responsibility to set an example in professionalism and integrity. If executed well, your company could not only achieve its business goals but also contribute to the growth of Vietnam’s nascent crypto industry – becoming a trusted custodian of digital value and a thought leader in the space.
Good luck with your endeavor, and welcome to Vietnam’s dynamic crypto future! Build carefully, and build boldly.
Sources:
- Vietnam’s Law on Digital Technology Industry – crypto defined, effective 2026
- Vietnam News (Apr 2025) – crypto adoption rank and lack of framework
- Vietnam Law Magazine (Feb 2025) – insights on new law, exchange licensing requirements
- Tilleke & Gibbins (Aug 2025) – sandbox details: crypto services, foreign ownership cap
- CCN Tech Guide (July 2025) – step-by-step launching crypto startup, incentives
- AInvest News (Apr 2025) – expected crypto tax rates (20% on gains, 10% VAT)
- Globe Newswire (July 2025) – Vietnam Blockchain Association’s role and rebranding
- Vietnam Briefing (June 2025) – summary of Digital Tech Law goals and support policies
- Vietnam Plus/VietnamNews Agency – calls for legal framework and expert opinions
- Blockchain Council News (July 2025) – Vietnam legalizes crypto, FATF compliance timeline .