This week (East 8 Time), the Ministry of Finance and the State Securities Commission of Vietnam jointly launched a pilot licensing system for cryptocurrency trading platforms, attracting significant attention from the regional market. Unlike the previous long-standing regulatory gray area, this time it is officially documented with clear thresholds, bringing cryptocurrency trading platforms into the regulatory spotlight. The two most striking figures in the pilot are the minimum paid-in capital requirement of at least 100 trillion Vietnamese dong (approximately 3.8 billion USD) and reports from multiple media outlets indicating that about 10 local securities firms and banks are interested in applying for licenses. It seems to be a transition from "no regulation" to a compliance process of "having regulation," but the extremely high capital threshold is bound to reshape the local cryptocurrency landscape: who can truly enter the licensing system and who will be kept out has become the core contradiction and focal point of a new round of competition in the Vietnamese market.
Gray Trading at a Crossroads: From Ambiguous Tolerance to Formal Regulation
● Causes of the gray market: In recent years, Vietnam has adopted a "neither prohibited nor managed" attitude towards cryptocurrency assets—neither issuing a systematic regulatory framework nor clearly recognizing them as legitimate payment or investment targets. This ambiguous stance has provided space for gray activities such as over-the-counter trading, overseas registration, and social group matchmaking, allowing retail investors and small to medium-sized funds to participate in high-volatility assets without protection, fully bearing the risks, while regulatory governance and information disclosure regarding trading platforms have been almost nonexistent.
● Shift in regulatory attitude: The pilot launched this week, co-led by the Ministry of Finance and the State Securities Commission, marks a shift in regulatory logic from past tacit tolerance to a management approach centered on a licensing system. Especially with the securities regulatory agency taking the lead, it means that cryptocurrency trading platforms are increasingly viewed as "financial infrastructure" and "quasi-securities markets," needing to meet multiple requirements regarding capital, compliance, and risk control, which is fundamentally different from the previous positioning of "technology companies" or "internet platforms."
● Milestone signal: According to local analysts quoted by the Planet Daily, this pilot is referred to as a "milestone in the normalization of Vietnam's digital asset market," focusing on reshaping risk expectations and participation thresholds. On one hand, players will realize that the regulatory risks of non-compliant platforms are rapidly accumulating; on the other hand, platforms entering the licensing system may enjoy compliance premiums and trust from funds. Gray trading is at a crossroads, and the future dominant force will gradually shift from wild platforms to officially endorsed "regular troops."
The 100 Trillion Dong High Wall: Who is Blocked from Compliance
● Extremely high paid-in threshold: The pilot plan sets a minimum paid-in capital of 100 trillion Vietnamese dong (approximately 3.8 billion USD), which is an extremely aggressive requirement among emerging markets. Considering the scale of Vietnam's domestic capital market and the asset sizes of local financial institutions, this threshold far exceeds the capital levels that ordinary tech startups and small to medium platforms can bear, being closer to the standards for establishing subsidiaries of large banks or leading brokerages, signaling a preference for "quality over quantity, prioritizing large institutions."
● Survival pressure on small and medium platforms: Market commentary points out that this threshold "may squeeze the survival space of small and medium platforms." For local small trading platforms that rely on technological innovation and light asset operations, it is almost impossible to meet the capital requirements in the short term; continuing to operate without a license poses regulatory risks of being cleaned up in the future. They may be forced to choose to transform into technology service providers, collaborate with licensed institutions, or exit the market altogether, leading to an accelerated elimination of Vietnam's previously diverse platform ecosystem.
● Favorable for capital-rich "giants": In contrast, capital-rich banks and large securities firms naturally adapt to this high threshold. Once the licensing system is established, these institutions, with ample capital, risk control capabilities, and brand reputation, will easily gain advantages in user trust and institutional fund inflow. The high capital requirements objectively raise the industry's concentration, creating conditions for a few leading licensed platforms to rapidly expand and compete for market pricing power and discourse.
Southeast Asia Licensing Competition: How Vietnam Balances Openness and Risk Control
● Regional regulatory competition landscape: In Southeast Asia, countries like Singapore and Thailand have already established relatively mature cryptocurrency regulatory and licensing systems. Singapore filters participants through payment licenses and capital requirements, while Thailand implements tiered regulation and investor protection rules for exchanges. Vietnam's pilot is widely seen as a compensatory action—both an internal rectification of the gray market and an external response to the pressure of regional "compliance competition," avoiding long-term outflow of domestic capital and projects.
● Pilot and securitization management approach: Compared to neighboring countries, Vietnam has chosen a "pilot + securities regulatory framework" as a starting point, testing within limited subjects and business scopes before expanding as needed. This path is more conservative in terms of openness but leans towards strict prudence in risk control: the leadership of the securities commission means treating cryptocurrency trading as comparable to securities market activities, emphasizing information disclosure, investor suitability, and anti-money laundering, rather than simply viewing it as ordinary technology or payment business.
● Attractiveness to startup platforms and overseas projects: The high capital threshold combined with strong regulation significantly reduces Vietnam's friendliness towards lightweight startup platforms. For overseas project parties, if they want to operate compliantly in Vietnam, they can almost only enter indirectly through partnerships with licensed financial institutions, making it unlikely to apply for a license independently. While this enhances system security, it also weakens Vietnam's appeal as a "low-threshold innovation testing ground," leading some startup teams to continue choosing to establish themselves in more mature jurisdictions like Singapore with clearer paths.
Banks and Brokerages Making Inroads: Entering Through Subsidiaries and Technical Cooperation
● Regular troops' reserve team: According to reports from multiple industry media, including panews and the Planet Daily, about 10 securities firms and banks are planning to apply for pilot licenses, becoming candidates for the first batch of "regular troops." These institutions have long been deeply involved in capital markets and payment systems, are more familiar with regulatory communication and compliance review processes, and have first-mover advantages in submitting application materials, building facilities, and internal approvals, likely occupying most seats in the first round of the pilot.
● Integration of securities regulatory experience: The pilot plan clearly draws on regulatory experiences from the securities industry, which aligns well with the existing systems of banks and brokerages. They already have comprehensive customer due diligence, anti-money laundering, risk control models, and compliance teams, and extending these systems to cryptocurrency trading only requires adaptation at the technical and product levels. Regulation can build on their existing reporting and auditing mechanisms, reducing the difficulty of completely "building from scratch" a regulatory framework for new business models.
● Pathways through subsidiaries and technical cooperation: Research briefs indicate that relevant institutions are largely laying out cryptocurrency-related businesses through establishing subsidiaries, equity partnerships, or technical outsourcing. Traditional finance provides funding and compliance guarantees, while local or overseas technical teams handle matchmaking engines, risk control models, and on-chain connections, achieving resource complementarity. This model, after the licensing pilot is implemented, will significantly compress the discourse space of existing cryptocurrency platforms: pure cryptocurrency platforms that originally relied on first-mover advantages and user bases may be overtaken by large institutions in terms of brand, credibility, and banking channels.
Licensing Dividends and Competition: What New Order Awaits Investors
● Expectations for enhanced investor protection and risk control: From the regulatory intent, the licensing system primarily targets user protection and systemic risk control. Once under regulation, platforms will be required to implement stricter customer identity verification, fund segregation, asset custody, and information disclosure, with anti-money laundering and anti-terrorist financing reviews becoming more systematic. For Vietnamese retail and institutional funds, the future expectations for fund safety and legal remedies when trading on licensed platforms are likely to be significantly better than the previous unprotected state in gray channels.
● Regulatory premium from limited licenses: The limited number of licenses, combined with high capital thresholds, gives the licensed qualifications themselves a clear "regulatory premium." Leading licensed platforms will have significant advantages in valuation, financing capabilities, and liquidity acquisition, making it easier to attract large institutions for market-making, compliant funds, and international partners. In the secondary market, stocks or equity projects related to licensed platforms may also enjoy valuation premiums due to regulatory endorsement, further consolidating their market dominance.
● The dilemma of compliance costs and user experience: High-intensity compliance means significantly increased operational costs, making it difficult for platforms to achieve growth through extremely low fees or unrestricted listing strategies. In the future, increased trading fees, stricter listing reviews, and restrictions on leverage and derivatives may become the norm. For medium to long-term funds pursuing safety and compliance, this is a favorable adjustment; however, for old players accustomed to high leverage, high volatility, and "long-tail assets," the experience may become noticeably "tightened," with some traffic potentially flowing to unregulated overseas platforms and on-chain protocols, leading to a more detailed stratification of market flows.
Unwritten Details and Uncertain Future Gambles
The approval timeline, specific processes, and supporting tax policy details have not yet been announced, creating significant uncertainty for the market between short-term trading and long-term expectations. How regulatory guidelines are implemented, when the first batch of licenses will truly be issued, and how tax burdens will affect platform and user costs will directly determine the pace and intensity of Vietnam's regulatory shift. What is certain is that Vietnam is moving from a long-standing regulatory gray area to a high-threshold, highly prudent licensing system, a choice that will not only rewrite the country's cryptocurrency trading ecology but also impact the overall regulatory landscape and capital flow patterns in Southeast Asia.
Moving forward, the most noteworthy aspects to observe will be three dimensions: the composition of the first batch of licensed institutions, whether they are dominated by banks and brokerages or if there is space reserved for some tech platforms; the permitted business scope, covering spot trading, custody, or further touching on derivatives and lending; and their market share evolution after implementation, whether it forms an oligopoly or maintains a certain diversity. These real-world feedbacks will determine whether this pilot is a concentrated opportunity to deliver dividends to traditional finance or a "squeezed reform" that forces innovative platforms to upgrade and transform.
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