Vietnam — Country Risk Report

Vietnam (Asia Pacific • Southeast Asia). Risk report as of the 19 Jun 2026 FATF plenary.

High country risk, with governance and transparency concerns. Vietnam's country risk score is 6.0/10, placing it in the high-risk band. The principal driver is weak voice and accountability, alongside corruption risk. Vietnam is subject to FATF increased monitoring. Vietnam is not subject to comprehensive country-wide sanctions. Firms should apply additional scrutiny where exposure involves state-linked entities, restricted sectors, sensitive technology, dual-use goods or politically exposed counterparties.

Recommended treatment

Enhanced due diligence.

At a glance

  • FATF status: Grey list (one indicator only; it does not set the overall country risk rating by itself)
  • Comprehensive country sanctions: none identified. Targeted sanctions exposure: possible, screen applicable persons, entities and sectors
  • Government effectiveness and rule of law: 5.0/10
  • Corruption (CPI 2025): 41/100, rank #81 of 182
  • Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 6.0/10 (High)

Higher score means higher country risk (global average 4.6). Full information available. Strong data coverage. Enforcement activity and CPI are shown for context but do not change the score.

All three parts of the score are available.

How this score was calculated

  • Financial crime controls: 7.4/10 — 50% of this score
  • Government effectiveness and rule of law: 5.0/10 — 30% of this score
  • International sanctions: 0.0/10 — 20% of this score
  • FATF grey-list status means the score cannot be lower than 6.0. This minimum set the final score.

International sanctions contributes 0.0 because the complete UN, UK, EU and US review found no direct country-level sanctions programme. People or organisations connected to the country may still appear on sanctions lists.

Show the exact calculation

aml 7.4 × 50% + governance 5 × 30% + sanctions 0 × 20% = 5.2; fatf-grey floor 6 applied; final 6

Principal risk drivers

  • FATF increased-monitoring status
  • Voice & accountability — 6.2/10
  • Corruption (WGI) — 5.7/10

Mitigating factors

  • No comprehensive country-wide sanctions programme.
  • Comparatively stronger political stability (3.4/10).
  • Risk is concentrated in specific counterparties, sectors and transactions rather than applying uniformly.

Business impact

  • Customer onboarding (High): Additional ownership and control verification may be required.
  • Payments and transactions (High): Review transaction purpose, counterparties and geographic routing.
  • Trade and export activity (High): Screen goods, end users and potential dual-use exposure.
  • Corporate clients (High): Assess state ownership, government links and political exposure.
  • Ongoing monitoring (High): Apply alerts for ownership changes, sanctions and geopolitical developments.

Recommended controls

  • Verify ultimate beneficial ownership using more than one reliable source.
  • Identify state ownership, government influence and politically exposed persons.
  • Screen entities, directors and beneficial owners against applicable sanctions lists.
  • Apply enhanced review to technology, defence, telecommunications, financial services and dual-use activity.
  • Document transaction purpose and source of funds where cross-border structures are complex.
  • Escalate unresolved ownership opacity or adverse information to Compliance.

Enhanced due diligence triggers

  • State ownership / control
  • PEP involvement
  • Sensitive / restricted sectors
  • Opaque ownership
  • Adverse media
  • Dual-use goods & technology
  • High-risk intermediary routing

FATF status: Grey list

Jurisdiction Under Increased Monitoring. Last reviewed 19 Jun 2026; next FATF plenary Oct 2026.

Source details

International sanctions by issuing body

  • UN: No
  • EU: No
  • UK: No
  • US: No

No means the complete UN, UK, EU and US review found no direct country-level programme. People or organisations may still appear on sanctions lists.

Government effectiveness and rule of law (World Bank 2024, percentile)

  • Government Effectiveness: 50/100
  • Regulatory Quality: 51/100
  • Rule of Law: 52/100

Regulators and legal framework

FATF network

FATF network via APG.

Last mutual evaluation: 2022 · report

National regulators

Regulator profiles not yet available on RegActions.

FIU: Not an Egmont Group member

Framework signals

  • FATF listing: Grey list
  • International sanctions: no listed programme identified
  • EU tax list: Listed (Annex I)
  • Corruption (CPI 2025): 41/100, rank #81 of 182
  • Rule of law (WGI): 4.9/10 risk

Sector exposure

  • Banking & payments (Elevated): FATF grey-list status elevates correspondent-banking risk
  • Trade & export controls (Low): No sanctions programme or FATF black-list constraint identified
  • Crypto & virtual assets (Elevated): FATF grey-list VASP supervision gaps raise virtual-asset risk
  • Real estate & luxury assets (Low): Corruption indicators within normal range for high-value assets
  • State-linked & procurement (Low): Political-stability and corruption governance within normal range

Derived from sanctions tier, FATF listing, World Bank WGI governance and CPI; no per-sector dataset is asserted.

Vietnam: analysis

Vietnam combines a governance picture marked by corruption and accountability weaknesses with current FATF grey listing. Governance is driven by voice and accountability and corruption, with rule of law and institutions and political stability providing partial mitigation. The FATF grey-list status, reviewed as recently as June 2026, is the most significant near-term risk factor and will require enhanced due diligence from regulated firms. No sanctions apply. Vietnam sits just below the global median on the World Bank governance indicators.

Outlook

Vietnam's risk profile will be heavily influenced by its progress in addressing the FATF-identified deficiencies. Successful completion of the FATF action plan could lead to removal from the grey list, easing the FATF overlay, though the underlying governance weaknesses would remain. The October 2026 plenary is a critical milestone. Firms should apply enhanced due diligence to Vietnamese counterparties until the listing is resolved.

Key watchpoints

  • Track Vietnam's progress against its FATF action plan ahead of the October 2026 plenary.
  • Monitor for any FATF decision to remove or retain the grey-list designation.
  • Watch corruption and accountability domain scores for any structural deterioration.
  • Review AML/CFT legislative and supervisory reforms as indicators of compliance trajectory.

Assessment currency

  • FATF status: Increased monitoring (as of 19 Jun 2026)
  • Sanctions exposure: None identified (as of Jul 2026)
  • Governance (WGI): Latest dataset incorporated (as of 2024)
  • Corruption (CPI): 41/100 (as of 2025)
  • RegActions assessment: Reviewed (as of 19 Jun 2026)

Public evidence layer

FATF action: increased monitoring. FATF identifies the jurisdiction as under increased monitoring; apply the firm's risk-based controls and monitor remediation progress.

Contextual signals (not scored)

  • FATF network membership: FATF regional network: APG (present, as of 2026-07)
  • EU non-cooperative tax jurisdictions: Listed in Annex I (present, as of 2026-02-17)
  • Egmont Group FIU: No Egmont member FIU identified (absent, as of 2026-07-17)
  • Beneficial-ownership register: No live register identified in the source (unavailable, as of 2026-07-17)
  • Transparency International CPI: 41/100, rank 81 (present, as of 2025)

Evidence freshness

  • FATF monitored-jurisdiction status: current; data 2026-06-19
  • FATF mutual evaluation and follow-up ratings: current; data 2026-07-31; follow-up 2025-02; base assessment 2022-02
  • World Bank governance indicators: current; data 2024
  • UN, UK, EU and US sanctions regimes: current; data 2026-08-16

Contextual signals are public evidence only and do not change the immutable v2 score.

Download evidence PDF · CSV · JSON

Regional peer scores

FAQ

Is Vietnam on the FATF grey list?

Yes. As of the 19 Jun 2026 FATF plenary, Vietnam is on the FATF grey list (Jurisdictions Under Increased Monitoring). This is one AML indicator and does not by itself set Vietnam's overall country risk rating. The next FATF plenary review is scheduled for Oct 2026.

Is Vietnam subject to sanctions?

No country-level programme was identified. In the approved RegActions snapshot, no comprehensive or targeted country-wide sanctions programme was found for Vietnam, but individual listed persons may still exist, so firms should continue to screen counterparties against the applicable lists.

What is Vietnam's country risk rating?

RegActions rates Vietnam at 6.0/10 (High risk), where a higher score means higher country risk. The score combines financial crime controls, government effectiveness and rule of law, and international sanctions. Transparency International's 2025 Corruption Perceptions Index scores Vietnam 41/100 (rank #81 of 182).

What due diligence applies to Vietnam?

Enhanced due diligence. This is decision-support based on Vietnam's FATF grey list status, governance and sanctions signals, and is not a substitute for a firm's own risk assessment.

Source: FATF black & grey lists · World Bank WGI (CC BY 4.0 — World Bank WGI) · TI CPI (CC BY-ND 4.0 — Transparency International, display only)