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The Government issued Decree 132/2026/ND-CP on April 6, 2026, effective from May 21, 2026, amending and supplementing a number of articles of Decree 41/2018/ND-CP on administrative penalties in the accounting and independent auditing sectors. A notable highlight is the addition of Article 35a, which stipulates penalties for violations related to anti-money laundering (AML), combating the financing of terrorism (CFT), and the financing of the proliferation of weapons of mass destruction within the accounting service business sector.
Note: The fine levels apply to individuals. For organizations committing the same violation, the fine will be doubled.
Details of fine levels (for individuals):
1. Violations regarding customer identification and risk assessment:
From 10,000,000 to 15,000,000 VND: Failure to identify, verify, or update customer information; failure to update the blacklist; failure to perform or report risk assessment results.
From 15,000,000 to 20,000,000 VND: Failure to establish risk management procedures or failure to classify customers by risk level.
2. Violations regarding internal regulations and information storage:
From 10,000,000 to 20,000,000 VND: Failure to properly apply internal regulations on control/audit, training, fostering, or assigning AML officers.
From 15,000,000 to 25,000,000 VND: Failure to provide information/records in a timely manner; failure to fully retain records or violate customer information confidentiality.
From 20,000,000 to 30,000,000 VND: Failure to issue internal regulations on AML and CTF.
3. Violations regarding special customers and transaction monitoring:
From 15,000,000 to 20,000,000 VND: Failure to implement regulations related to foreign politically exposed persons (PEPs).
From 20,000,000 to 30,000,000 VND: Failure to monitor special transactions as prescribed.
4. Violations regarding transaction reporting:
From 8,000,000 to 12,000,000 VND: Violating the deadline or accuracy of large-value transaction reports (from the 3rd time onwards per year); submitting suspicious transaction reports with incomplete information.
From 15,000,000 to 25,000,000 VND: Failure to report large-value transactions or suspicious transactions; failure to report when a customer is on the blacklist.
5. Violations of prohibited acts:
From 15,000,000 to 25,000,000 VND: Obstructing the provision of information for AML/CTF purposes.
From 30,000,000 to 40,000,000 VND: Illegally providing services of receiving cash, checks, or payment instruments.
From 40,000,000 to 50,000,000 VND (when not yet subject to criminal prosecution):
- Assisting in carrying out money laundering acts or establishing relationships with shell banks.
- Failure to denounce acts of terrorist financing.
- Directly or indirectly providing finance or services to terrorist organizations or individuals.
Transitional provision: Violations regarding AML in accounting services not regulated in this Decree shall be penalized in accordance with Decree No. 340/2025/ND-CP (in the monetary and banking sector).
View and download Decree 132/2026/ND-CP
Businesses must comprehensively develop and update their internal AML/CFT procedures, which include: Know Your Customer (KYC), risk classification, and transaction monitoring, along with conducting periodic personnel training to ensure compliance.
In addition, it is necessary to establish systems for record-keeping, transaction reporting, and alert mechanisms to detect and promptly report suspicious or high-value transactions in accordance with regulations.
Finally, businesses should strengthen controls over high-risk clients (such as PEPs) and proactively coordinate with competent authorities, ensuring the transparent provision of information to mitigate legal risks and penalties.
