Just after the Davos Forum concluded, BlackRock's CEO declared that "the financial system should migrate to Ethereum," and the NYSE announced the development of a tokenized securities platform.
Article author and source: Yuanshan Insight
In late January, the Ministry of Finance officially launched a pilot program for licensing cryptocurrency trading platforms.
- A 10 trillion Vietnamese dong (nearly 300 million RMB) entry threshold directly eliminates small and medium-sized players, allowing local financial giants to enter the market.
- Establishing a new geopolitical division of labor of "Dubai compliance, Vietnam development" aims to become the "core contract manufacturer" of the Web3 world.
Just after the Davos Forum concluded, BlackRock's CEO declared that "the financial system should migrate to Ethereum," and the NYSE announced the development of a tokenized securities platform.
Meanwhile, Vietnam's Ministry of Finance launched a pilot program for cryptocurrency licenses, with an entry threshold of 10 trillion Vietnamese dong (nearly 300 million RMB), effectively excluding small exchanges.
Traditional finance is embracing Web3, while emerging markets in Southeast Asia are raising compliance barriers. Does it want to become the next Hong Kong, or the next Singapore?
【01 | What happened?】
In late January, Vietnam's Ministry of Finance officially launched a pilot program for licensing cryptocurrency trading platforms. This marks a significant step in Vietnam's shift from a "gray area" to clear regulation.
There are three key points:
Entry threshold: Paid-in capital must reach 10 trillion Vietnamese dong (nearly 300 million RMB). In comparison, this figure is more than 16 times the Philippine threshold of 100 million pesos (approximately 1.8 million USD).
Applicant restrictions: Must be a Vietnamese company. This means that companies like Binance and Coinbase cannot obtain a license directly and must enter the market through local joint ventures or acquisitions.
The first batch of institutions to express their participation included SSI Securities (a leading securities firm in Vietnam) and MB Bank (a commercial banking giant), both of which are traditional financial institutions.
Timing: This action occurred less than a week after this year's Davos Forum.
During the forum, signals of a global regulatory race were already being released – Japan announced the legalization of Crypto ETFs by 2028, the UK Financial Conduct Authority (FCA) is close to completing its cryptocurrency regulatory consultation, and the US Congress is advancing legislation on “crypto market structure.”
Vietnam's actions are a response to this global competition. This is also a publicly known fact.
【02 | From Gray Market Profits to Large-Scale Operations in the Sunlight】
Vietnam's cryptocurrency market previously existed in a "gray area"—neither explicitly legal nor completely prohibited. In this ambiguous state, numerous small exchanges proliferated unregulated and unlicensed. User funds lacked protection, and scams involving exchanges running away with users' money were frequent.
The significance of the licensing system lies in its shift of the crypto market from a "gray market with huge profits" to one of "scaled operation under the sunlight." The nearly 300 million RMB threshold has blocked smaller exchanges with insufficient funds, but it has created space for well-established domestic financial institutions.
The entry of traditional institutions like SSI Securities and MB Bank means that user asset custody, compliance, and anti-money laundering will all be carried out in accordance with traditional financial standards.
The Philippines offers a comparable example: From the end of 2025 to the beginning of 2026, the Philippine National Telecommunications Commission (NTC), acting on instructions from the central bank, blocked nearly 50 unauthorized platforms, including Coinbase and Gemini. However, the trading volume of the locally licensed exchange PDAX experienced explosive growth. Compliance did not end the market; rather, it redistributed the market share.
Vietnam is not the first to take action. Looking across Southeast Asia, Thailand, Malaysia, and the Philippines all completed upgrades to their regulatory frameworks between 2025 and 2026.
--Thailand issued formal guidelines in early 2026 supporting the establishment of spot Bitcoin and Ethereum ETFs and incorporating crypto assets into the Derivatives Act framework. To attract institutional investors, the Thai Ministry of Finance approved a capital gains tax exemption policy that will continue until December 2029.
--Malaysia employs a "dual management" model: the Securities and Exchange Commission (SC) is responsible for classifying cryptocurrencies with investment properties as "securities," while Bank Negara Malaysia (BNM) is responsible for monitoring and anti-money laundering. Currently, six licensed exchanges are permitted to operate, and the SC adopts a "zero-tolerance" policy towards unlicensed platforms.
--The Philippines has raised the bar for entry: According to the Crypto Asset Servicer Rule issued by the SEC in 2025, all platforms operating in the Philippines must be registered as local companies with paid-up capital of no less than 100 million pesos (approximately US$1.8 million).
Vietnam's actions are part of a regional trend, following up in this Southeast Asian regulatory race. If Vietnam continues to operate in a gray area while its neighbors are establishing compliance frameworks, it risks losing opportunities to attract legitimate institutions.
An easily overlooked background is that Web3 companies are forming a new geographical division of labor in their global expansion: Dubai (compliance center) + Vietnam/Malaysia/Thailand (development center) + global markets (operations coverage).
Dubai, by establishing VARA, the world's first dedicated regulatory body, has become the preferred location for Web3 startups to register and comply with regulations. However, Dubai faces high talent costs and significant cost pressures in technology development and ecosystem building.
Southeast Asian countries such as Vietnam, Malaysia, and Thailand, with their low labor costs and supportive local policies, are becoming "development hubs." Vietnam's launch of a licensing system signifies a shift from "grey development" to "compliant development"—companies can legally establish technical teams in Vietnam to develop DApps and infrastructure without worrying about the risks of sudden policy changes.
This geographical division of labor is a major boon for the Web3 industry. Companies can handle compliance in Dubai, development in Vietnam, and market coverage globally. This "trading traffic for resources" logic is more sustainable than simply "being non-compliant everywhere."
【03 | Why might it also bring risks】
- Entry barriers may increase industry concentration.
Nearly 300 million RMB in paid-in capital may not seem like a high amount to traditional financial institutions, but it represents a significant hurdle for local crypto companies. This could lead to a monopoly of the Vietnamese crypto market by traditional financial institutions, hindering innovation.
Singapore's experience offers a point of comparison: the Monetary Authority of Singapore (MAS) has an extremely long review period for crypto exchage licenses, focusing on money laundering prevention and technical risk management. As a result, many innovative startups are unable to obtain licenses and ultimately choose to leave Singapore. Singapore has a mature regulatory framework, but this has also led to the loss of some innovative companies.
Will Vietnam repeat the same mistakes? If traditional institutions like SSI Securities and MB Bank dominate, will they have sufficient incentive to drive emerging businesses? Or will they treat crypto trading as "just another financial product," lacking an understanding of the native Web3 culture?
- Compliance costs may be passed on to users.
The licensing system introduces compliance costs—KYC processes, custody fees, and regulatory reporting—which may ultimately be passed on to users. If trading fees at licensed exchanges in Vietnam are significantly higher than those on international platforms, users may turn to underground markets or use VPNs to continue accessing overseas exchanges.
The goal of compliance is to protect users, but excessive compliance costs may push users to less secure channels.
-Mismatch between regulatory capacity and market innovation
Vietnam's crypto market is still in its early stages. Do regulators have sufficient technical capabilities and talent to oversee complex DeFi protocols, cross-chain transactions, and stablecoin issuance?
The real problem is that while SSI Securities and MB Bank may excel in traditional financial services, they may lack experience in Web3-native businesses such as on-chain governance, smart contract security, and liquidity mining. If regulators also lack expertise in these areas, the licensing system may become merely a formality—regulation in name only, without actually identifying the real risks.
Another point is geopolitical uncertainty.
Vietnam's cryptocurrency market primarily covers Southeast Asia, but the region's geopolitical situation is complex. Factors such as US influence in Southeast Asia, China-ASEAN relations, and regulatory coordination between Vietnam and its neighbors could all impact policy stability.
If Vietnam's licensing system is incompatible with the regulatory frameworks of neighboring countries (Thailand and Malaysia), it could increase the difficulty of cross-border business compliance. Will products developed by Web3 companies in Vietnam be able to 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 policy of prioritizing local institutions have sent a signal: it does not want to become the next Philippines (low threshold, high activity), but rather chooses between Hong Kong and Singapore.
Hong Kong's approach is "retail-friendly + financial product innovation": allowing retail trading, approving spot ETFs, and establishing a stablecoin sandbox. This openness has attracted significant Asian capital, but it also means higher regulatory costs and risks.
Singapore's approach is "institution-friendly + strict retail control": The Monetary Authority of Singapore (MAS) discourages speculative trading by retail investors but strongly promotes the application of blockchain in wholesale settlements and asset securitization (such as Project Guardian). The entry barriers are extremely high, but the ecosystem is more stable.
Vietnam's nearly 300 million threshold and policy of prioritizing local institutions seem to be following Singapore's path. However, the question remains: can Vietnam's financial infrastructure and talent pool support such high-standard institutional regulatory requirements?
If Vietnam wants to become the "Singapore of Southeast Asia," it needs more than just a licensing system; it also needs a sound legal framework, a professional regulatory team, and deep alignment with international standards. All of these require time and resources.
For Vietnam, following Hong Kong's path means rapidly accumulating liquidity, attracting retail investors, and establishing itself as a Southeast Asian cryptocurrency trading hub. However, the question remains: do Vietnamese regulators possess sufficient expertise to handle the complexities of the retail market? And if retail funds are at risk, can Vietnam provide a robust appeal mechanism similar to Hong Kong's?
The third path: "Development Center + Remote Compliance"
Perhaps Vietnam doesn't need to become Hong Kong or Singapore. It could take a third path: become a Web3 enterprise development hub, while leaving compliance in Dubai, Hong Kong, or Singapore.
This geographical division of labor is taking shape: Dubai (compliance center) + Vietnam/Malaysia/Thailand (development center) + global markets (operations coverage).
This path is more realistic. Vietnam doesn't need to compete with Hong Kong and Singapore for the status of a compliance center, but it can leverage its advantages in talent cost and policy support to become a recognized "hotbed for development" in the industry.
【05 | Impact on Retail Investors: Compliance is Not the End】
The licensing system will most directly impact ordinary cryptocurrency users in Vietnam. Previously, they were free to choose between international exchanges or smaller local platforms, which offered low fees and low barriers to entry, but also required them to bear the risks themselves.
Currently, if Vietnam strictly enforces the licensing system, unlicensed platforms may be blocked (as is the case in the Philippines). Users will only be able to choose licensed exchanges operated by SSI Securities or MB Bank.
Benefits: User funds are protected by escrow, the KYC process is standardized, and there are appeal channels in case of problems.
Costs: Transaction fees may increase, the number of available currencies may decrease (regulators typically only approve mainstream currencies), and the pace of product innovation may slow down.
This shift could be disorienting for Vietnam's younger generation of retail investors—who may be accustomed to platforms like Binance. If local licensed exchanges cannot provide a comparable 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 could push users to 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 approach attracts retail investors and liquidity, but requires extremely strong regulatory capabilities. The Singapore approach is robust but has very high barriers to entry, requiring mature financial infrastructure. Vietnam possesses neither of these.
But the third path is more realistic: become a Web3 development center, leveraging talent cost advantages while keeping compliance in Dubai or Hong Kong. The significance of the nearly 300 million threshold lies in pushing the market from the "gray area" to "compliant development"—companies can legally establish teams and develop products without worrying about sudden policy changes.
This is the first time Vietnam has regulated "crypto asset trading platforms" as a formal financial business.
