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In Vietnam, cashless payments are increasingly becoming the mainstream as digital banking services expand rapidly. Alongside this growth, the State Bank of Vietnam (NHNN) has emphasized that safety and security requirements for financial transactions are becoming more urgent—particularly for high-value payments, which carry higher fraud risk if safeguards are not properly applied.
To address these concerns, NHNN issued Circular 40/2024/TT-NHNN regulating the provision of intermediary payment services. The circular strengthens controls for transactions valued at 500 million dong or more, including biometric information verification, as part of efforts to improve system safety amid rapid growth in digital payments.
In practice, Vietnam’s payment system operates through two streams: low-value payments and high-value payments. Under the regulation, transactions of 500 million dong or more are classified as high-value and must be processed through the interbank electronic payment system operated by NHNN. This approach is intended to support risk control and liquidity management across the system.
By contrast, transactions below the threshold can be processed more quickly through instant payment systems.
Despite the framework, some customers have reportedly split a large amount into multiple smaller transfers—each under 500 million dong—to take advantage of faster 24/7 processing. While this can be convenient, the NHNN Payment Department warns that the practice may create compliance and fraud risks if the transactions are not fully authenticated in line with regulations.
NHNN’s Payment Department states that splitting a payment of 500 million dong or more into smaller transactions while only cross-checking biometric information once does not ensure compliance and may be exploited by bad actors for fraud.
Mr. Nguyen Quang Huy, CEO of the Finance–Banking Faculty at Nguyen Trai University, said the 500 million dong threshold is not only a technical figure but a trigger for the system’s risk-control measures. He noted that modern risk management cannot treat each transaction in isolation; it requires monitoring overall cash flow and customer transaction behavior.
According to the expert, when a large transfer is split into multiple smaller transfers but biometric verification is performed only once, the system cannot verify the identity of the person performing each transfer. This undermines the principle that each transaction must be accompanied by one biometric verification, which he described as a fundamental principle in international risk management.
He added that fraudsters could exploit this loophole by splitting transactions to bypass controls, increasing the risk of asset loss. From a management perspective, NHNN also highlights that if controls are not strict, a fraudster may only need to pass the initial verification once to carry out subsequent transfers without re-checking, potentially enabling the removal of all funds from a customer’s account.
To mitigate these risks, requiring biometric verification for each transaction—even when the instruction is split—is presented as a key solution to ensure safety. Mr. Nguyen Quang Huy said this helps close loopholes that could be exploited and enables the system to monitor and detect unusual signs more effectively, rather than relying only on transaction thresholds.
He further argued that verifying biometric data on every transfer allows the system to track and identify unusual indicators promptly, instead of controlling solely by limits.
NHNN’s policy does not ban splitting a large transaction. Customers may still split large payments into multiple transfers below 500 million dong to achieve faster processing through real-time payment systems. However, the condition is that each transfer must cross-check biometric information in accordance with regulations.
The article also notes that banks may use technology to help customers split orders conveniently, but they must ensure each transaction is authenticated and that customer consent is obtained.
In the long term, tightening rules on transaction authentication—especially for high-value transactions under Circular 40/2024/TT-NHNN—is expected to help prevent fraud and strengthen citizens’ trust in the digital banking system. NHNN also reiterated its commitment to working with credit institutions and customers to improve transaction experience while ensuring safety and smooth payment-system operation.
Given the increasing sophistication of fraud, experts cited NHNN’s approach to managing transactions of 500 million dong or more—particularly provisions related to splitting orders and biometric verification—as a necessary and correct step to protect customers’ rights and support a safe, sustainable digital financial ecosystem.
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