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In the context of growing calls for market transparency, anti-money-laundering (AML) efforts have become a central focus, especially in real estate, where large transaction values and diverse payment methods pose notable risks.
The Ministry of Construction recently chaired a conference, in collaboration with the Anti-Money Laundering Department (State Bank of Vietnam) and the Internal Security Department (Ministry of Public Security), to guide reporting subjects in the real estate business sector on the results of the national risk assessment, sector risk assessment, and obligations to prevent money laundering and terrorist financing.
Experts at the conference announced the results of the National Risk Assessment (NRA) for 2018–2022. The brokerage and real estate trading sector was ranked at a medium-high risk level for money laundering.
According to the Anti-Money Laundering Department, while the legal framework is rated as high, the effectiveness of inspection, supervision, and enforcement of administrative sanctions in the real estate sector remains low.
On internal gaps, the NRA data indicate that AML knowledge among employees of real estate enterprises is medium-low. The assessment also points to common loopholes being exploited, including unauthorized proxy transactions, customers not concerned about price, or transaction prices not aligned with market prices.
Deputy Director Hoang Thu Hang of the Real Estate Management and Market Department said anti-money laundering, terrorist financing, and financing of weapons of mass destruction are mandatory legal requirements and a central task, with particular importance for national financial security, market transparency, and Vietnam’s international standing.
She noted that, as integration deepens, compliance with international standards in this area is increasingly important and requires coordinated and decisive action from state authorities, businesses, and relevant stakeholders.
Ms. Nguyen Thi Minh Tho, Deputy Director of the AML Department, said the Law on AML has broadened its scope to cover organizations and individuals engaged in non-financial activities related to the field. Real estate businesses, she said, cannot remain outside supervision and must fulfill legal obligations including customer due diligence, risk assessment, reporting large-value transactions, reporting suspicious transactions, and maintaining records as required.
She emphasized that enterprises must conduct customer identification when providing real estate services, including verifying customer information, identifying the beneficial owner, and monitoring transactions to detect abnormal signs—described as a core mechanism to prevent the real estate market from being used to launder illicit money.
Representatives also warned that many enterprises still treat AML as a “ritual” responsibility. With supervisory standards tightening, non-compliance can create significant risks, ranging from administrative penalties to reputational damage.
Enterprises were advised to pay particular attention to monitoring large-value unusual transactions, transactions involving high-risk countries or territories, and cases showing signs of concealing the beneficial owner. Early detection and timely reporting, the AML Department said, can help prevent violations and reduce the risk of being exploited.
Deputy Director Hoang Thu Hang reiterated that the real estate sector is among the high-risk sectors if not tightly controlled. She said it is therefore essential for real estate enterprises, exchanges, and related organizations and individuals to understand and comply with the law and meet reporting obligations to support market transparency.
Ms. Hang proposed several key tasks. State agencies and businesses should disseminate AML regulations to every officer and employee to prevent violations caused by insufficient understanding. Enterprises should also review and strengthen internal controls over transactions, including suspicious transactions and large-value transactions of 400 million dong and above.
She further called for intensified coordination between state agencies and businesses to share information for early detection of violations. In parallel, applying information technology to manage real estate transactions was highlighted as a way to enhance transparency, with public disclosure on the information system intended to support self-monitoring by individuals and organizations.
“State agencies, local departments, and the business community must collaborate more cohesively and decisively to bring AML into substantive practice, contributing to a healthy business environment and upholding the rule of law,”
Deputy Director Hang said.
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