Author: Yuanshan洞见

• In late January, the Ministry of Finance officially launched the pilot work for cryptocurrency trading platform licenses.

• The entry threshold of 10 trillion Vietnamese Dong (nearly 300 million RMB) directly eliminates small players, allowing local financial giants to enter.

• Establishing a new geopolitical division of labor of "Dubai compliance, Vietnam development," aiming to become the "core manufacturing hub" of the Web3 world.

The Davos Forum has just concluded, and BlackRock's CEO claims that "the financial system should migrate to Ethereum," while the New York Stock Exchange announces the development of a tokenized securities platform.

Meanwhile, the Vietnamese Ministry of Finance has initiated the cryptocurrency license pilot, with a 10 trillion Vietnamese Dong (nearly 300 million RMB) entry threshold, effectively keeping small exchanges out.

Traditional finance embraces Web3, while emerging markets in Southeast Asia erect compliance barriers. Does it want to become the next Hong Kong or the next Singapore?

【 01 ｜ What Happened 】

In late January, the Vietnamese Ministry of Finance officially launched the pilot work for cryptocurrency trading platform licenses. This marks a significant shift for Vietnam from a "gray area" to clear regulation.

There are three core points:

Entry threshold: The paid-in capital must reach 10 trillion Vietnamese Dong (nearly 300 million RMB). In comparison, this figure is more than 16 times the 100 million pesos (about 1.8 million USD) threshold in the Philippines.

Application subject restrictions: Must be a local Vietnamese enterprise. This means that Binance, Coinbase, and others cannot directly obtain licenses and must enter through local joint ventures or acquisitions.

The first institutions to express participation include SSI Securities (a leading securities company in Vietnam) and MB Bank (a commercial banking giant), both of which are traditional financial institutions.

Timeline: This action occurred less than a week after this year's Davos Forum.

During the forum, signals of a global regulatory race were already released—Japan announced the legalization of Crypto ETFs by 2028, the UK's Financial Conduct Authority (FCA) is nearing completion of cryptocurrency regulatory consultations, and the U.S. Congress is advancing "cryptocurrency market structure legislation."

Vietnam's actions are a response to this global competition. This is also a publicly acknowledged fact.

【 02 ｜ From Gray Profits to Scalable Sunshine 】

Vietnam's previous cryptocurrency market was in a "gray area"—neither clearly legal nor completely prohibited. In this ambiguous state, a large number of small exchanges grew wildly in an environment without licenses or regulation. User funds lacked protection, and incidents of running away occurred from time to time.

The significance of the licensing system is that it pushes the cryptocurrency market from "gray profits" to "scalable sunshine." The nearly 300 million RMB threshold blocks underfunded small exchanges but frees up space for capable local financial institutions.

The entry of traditional institutions like SSI Securities and MB Bank means that user asset custody, compliance, and anti-money laundering will be executed according to traditional financial standards.

The experience of the Philippines can be compared: from the end of 2025 to early 2026, the National Telecommunications Commission (NTC) of the Philippines, following the central bank's instructions, blocked nearly 50 unauthorized platforms, including Coinbase and Gemini. However, the local licensed exchange PDAX saw explosive growth in trading volume. Compliance did not end the market; instead, it redistributed the cake.

Vietnam is not the first to take action. Looking across Southeast Asia, Thailand, Malaysia, and the Philippines have all completed regulatory framework upgrades between 2025 and 2026.

-- Thailand issued formal guidelines in early 2026, supporting the establishment of spot Bitcoin and Ethereum ETFs and incorporating cryptocurrency assets into the "Derivatives Act" framework. To attract institutional investors, the capital gains tax exemption policy approved by the Thai Ministry of Finance will last until December 2029.

-- Malaysia adopts a "dual management" model: the Securities Commission (SC) is responsible for classifying cryptocurrencies with investment attributes as "securities," while the central bank (BNM) monitors anti-money laundering. Currently, six licensed exchanges are permitted to operate, and the SC takes a "zero tolerance" attitude towards unlicensed platforms.

-- The Philippines has raised the entry threshold: according to the "Cryptocurrency Service Provider Rules" issued by the SEC in 2025, all platforms operating in the Philippines must register as local companies, and the paid-in capital must not be less than 100 million pesos (about $180,000).

Vietnam's actions are a follow-up in this regulatory race in Southeast Asia, part of a regional trend. When neighboring countries are establishing compliance frameworks, if Vietnam continues to maintain a gray area, it will lose the opportunity to attract legitimate institutions.

An easily overlooked background is that the global layout of Web3 enterprises is forming a new geopolitical division of labor: Dubai (compliance center) + Vietnam/Malaysia/Thailand (development center) + global market (operational coverage).

Dubai has become the preferred location for Web3 startups to register and comply by establishing the world's first dedicated regulatory agency, VARA. However, Dubai has high talent costs and significant pressure on technology development and ecosystem construction costs.

Southeast Asian countries like Vietnam, Malaysia, and Thailand have low talent costs and local policy support, and are becoming "development centers." Vietnam's initiation of the licensing system means it is shifting from "gray development" to "compliance development"—enterprises can legally establish technical teams in Vietnam to develop DApps and infrastructure without worrying about the risks of sudden policy changes.

This geopolitical division of labor is a significant boon for the Web3 industry. Enterprises can place compliance in Dubai, development in Vietnam, and cover the global market. This "exchanging traffic for resources" logic is more sustainable than simply being "non-compliant everywhere."

【 03 ｜ Why It May Also Bring Risks 】

• The entry threshold may raise industry concentration.

The nearly 300 million RMB paid-in capital is not high for traditional financial institutions, but it is a difficult threshold for local crypto-native enterprises to cross. This may lead to the Vietnamese crypto market being monopolized by traditional financial institutions, lacking innovative vitality.

The experience of Singapore can be compared: the Monetary Authority of Singapore has a very long review period for cryptocurrency exchange licenses, focusing on anti-money laundering protection and technology risk management. As a result, many innovative startups cannot obtain licenses and ultimately choose to leave Singapore. Singapore's regulatory framework is mature, but it has also lost some innovative enterprises.

Will Vietnam repeat this mistake? If traditional institutions like SSI Securities and MB Bank dominate, do they have enough motivation to promote emerging businesses? Or will they treat cryptocurrency trading as "just another financial product," lacking an understanding of the Web3 native culture?

• Compliance costs may be passed on to users.

The licensing system brings compliance costs—KYC processes, custody fees, regulatory reports—that may ultimately be passed on to users. If trading fees on licensed exchanges in Vietnam are significantly higher than those on international platforms, users may turn to underground markets or continue to access foreign exchanges using VPNs.

The goal of compliance is to protect users, but if compliance costs are too high, it may push users toward less secure channels.

• Mismatch between regulatory capacity and market innovation.

Vietnam's crypto market is still in its early stages; do regulatory authorities have enough technical capacity and talent reserves to regulate complex DeFi protocols, cross-chain transactions, and stablecoin issuance?

The reality is that SSI Securities and MB Bank may excel in traditional financial business but may lack experience in on-chain governance, smart contract security, liquidity mining, and other Web3 native businesses. If regulatory authorities also lack expertise in these areas, the licensing system may become "formal compliance"—appearing to have regulation but failing to identify real risk points.

Another point is geopolitical uncertainty.

Vietnam's crypto market mainly covers Southeast Asia, but the geopolitical situation in this region is complex. The influence of the U.S. in Southeast Asia, the relationship between China and ASEAN, and Vietnam's regulatory coordination with neighboring countries—these factors may all affect policy stability.

If Vietnam's licensing system is incompatible with the regulatory frameworks of neighboring countries (Thailand, Malaysia), it may increase the difficulty of compliance for cross-border business. Can products developed by Web3 enterprises in Vietnam operate smoothly in Thailand and the Philippines? If not, Vietnam's role as a "development center" will be significantly diminished.

【 04 ｜ Hong Kong vs. Singapore: Vietnam's Choice 】

Vietnam's nearly 300 million threshold and local institution priority policy have already sent a signal: it does not want to become the next Philippines (low threshold, high activity) but is choosing between Hong Kong and Singapore.

The Hong Kong path is "retail-friendly + financial product innovation": allowing retail trading, approving spot ETFs, and establishing stablecoin sandboxes. This open stance has attracted a large amount of capital with Asian backgrounds, but it also means higher regulatory costs and risks.

The Singapore path is "institution-friendly + strict control of retail": the Monetary Authority does not encourage retail investors to engage in speculative trading but actively promotes the application of blockchain in wholesale settlement and asset securitization (such as Project Guardian). The entry threshold is extremely high, but the ecosystem is more stable.

Vietnam's nearly 300 million threshold and local institution priority policy resemble the Singapore path. But the question is whether Vietnam's financial infrastructure and talent reserves can support "institution-level high-standard" regulatory requirements?

If Vietnam wants to become the "Singapore of Southeast Asia," it needs not only a licensing system but also a complete legal framework, a professional regulatory team, and deep integration with international standards. All of these require time and resource investment.

For Vietnam, taking the Hong Kong path means quickly gathering liquidity, attracting retail funds, and building a Southeast Asian crypto trading center. But the question is whether Vietnam's regulatory authorities have enough professional capacity to handle the complexities of the retail market? If retail funds encounter risks, can Vietnam provide a complete complaint mechanism like Hong Kong?

The third path: "Development Center + Remote Compliance."

Perhaps Vietnam does not need to become Hong Kong or Singapore. It can take a third path: become a development center for Web3 enterprises while placing compliance in Dubai, Hong Kong, or Singapore.

This geopolitical division of labor is taking shape: Dubai (compliance center) + Vietnam/Malaysia/Thailand (development center) + global market (operational coverage).

This path is more realistic. Vietnam does not need to compete with Hong Kong and Singapore for compliance center status but can leverage its talent cost advantage and policy support to become an industry-recognized "development hotbed."

【 05 ｜ Retail Impact: Compliance Is Not the End 】

The most direct impact of the licensing system is on ordinary crypto users in Vietnam. In the past, they could freely choose international exchanges or local small platforms, with low fees and low thresholds, but at their own risk.

Now, if Vietnam strictly enforces the licensing system, unlicensed platforms may be blocked (as in the Philippines). Users can only choose licensed exchanges operated by SSI Securities or MB Bank.

Benefits: User funds have custody protection, KYC processes are standardized, and there are complaint channels in case of issues.

Costs: Trading fees may rise, the variety of available cryptocurrencies may decrease (regulatory authorities usually only approve mainstream coins), and the speed of product innovation may slow down.

For the younger generation of retail investors in Vietnam—who may be accustomed to using platforms like Binance—this transition may bring discomfort. If local licensed exchanges cannot provide the same user experience, some users may turn to VPNs or P2P over-the-counter trading, creating new regulatory blind spots.

The regulatory goal is to protect users, but overly rigid enforcement may push users toward less secure channels. Vietnam needs to find a balance between "protecting users" and "maintaining market vitality."

【 06 ｜ Perhaps the Third Path Is More Realistic 】

The Hong Kong path attracts retail investors and liquidity but requires extremely strong regulatory capacity. The Singapore path is stable but has an extremely high threshold, requiring mature financial infrastructure. Vietnam has neither.

But the third path is more realistic: becoming a Web3 development center, leveraging talent cost advantages, and placing compliance in Dubai or Hong Kong. The nearly 300 million threshold signifies that it pushes the market from "gray areas" to "compliance development"—enterprises can legally establish teams and develop products without worrying about sudden policy changes.

This is the first time Vietnam has regulated "cryptocurrency trading platforms" as a formal financial entity.

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