How Vietnam’s New Outward Investment Proposal Aligns with Global Movements

Vietnam is entering a new phase in its outward investment policy. The government is moving away from a system that placed heavy emphasis on pre-approval procedures and replacing it with an Ex Post Review framework that focuses on risk management. This marks a transformation in how the country manages capital flows for investing in Vietnam and abroad.

The change reflects Vietnam’s ambition to position itself as a more mature and internationally integrated economy. According to the World Bank, Vietnam has already achieved one of the fastest growth rates in Asia over the past three decades, and sustaining the momentum requires institutions that can support innovation and cross-border expansion.

In this article, BBCIncorp will analyze how the proposed approach aligns with international best practices and its implications for investors.

The pre-approval model as a barrier to efficiency

Before the change suggestion, outward investment was governed by a highly centralized system that placed government agencies in a gatekeeping role. Understanding how the system worked and why it became a constraint helps explain the importance of the current transition.

The current system and its gatekeeping role

Vietnam’s earlier outward investment regime placed the Ministry of Planning and Investment at the centre of a stringent pre-approval process. Under this model, investors were required to obtain clearances for every aspect of their project, from objectives and capital structure to location and timeline, long before commencement.

Investment policy approval could come from the National Assembly, the Prime Minister, or provincial bodies, each with different timelines and requirements. For instance, approval from the National Assembly could take at least 165 days, while Prime Minister-level approval typically requires 55 days, and provincial approval is extended to 35 days or more.

The consequences for businesses and economic efficiency

The implications of this system are significant. Administrative timelines were lengthy and unpredictable. According to Grant Thornton Vietnam⁽¹⁾, outward investment could be delayed anywhere from three to twelve months, disrupting business plans and undermining the agility of enterprises seeking cross-border expansion.

These challenges were particularly onerous for small and medium-sized enterprises, which cannot, in most cases, navigate complex procedures or absorb prolonged waiting periods.

Beyond time, compliance costs rose sharply. Investors had to prepare exhaustive dossiers, secure multiple agency confirmations, and often engage in informal consultations to avoid rejection. The environment discouraged risk-taking and innovation, creating an investment bottleneck where only large firms with a high tolerance for bureaucratic complexity could thrive.

Moreover, the system functioned as a deterrent to outward investment. Some companies resorted to routing investments through foreign hubs like Singapore to sidestep domestic clearance procedures. Such workarounds not only added cost but also fragmented strategic planning and diluted the efficiency of Vietnam’s global expansion efforts.

The new approach shows trust through post monitoring

Vietnam’s proposed outward investment framework signals a decisive move toward efficiency and trust. Instead of holding back capital until every approval is secured, the government has introduced reforms that allow businesses to invest more freely. This reflects a shift to a modern, risk-based system that strengthens transparency without slowing down enterprise activity.

Streamlining procedures for outward investment

The introduction of Law No. 57/2024/QH15 and Decree 19/2025/ND-CP has streamlined procedures that once required multiple government clearances. The rules focus on reducing upfront checks and creating a single, more predictable pathway for investment approval. This reform has been especially significant for high technology sectors, where the timelines have dropped from several months to just a few weeks.

The change is not only about efficiency but also about signaling confidence in the capacity of enterprises to act responsibly. Instead of requiring exhaustive dossiers at the start, regulators can now evaluate compliance through periodic monitoring and reporting.

The role of the State Bank of Vietnam 

The State Bank of Vietnam (Ngân hàng Nhà nước Việt Nam), or the SBV, is the central bank of Vietnam, established in 1951. It plays a role similar to the Federal Reserve in the United States or the European Central Bank in the EU.

Key functions of the SBV encompass:

• Monetary policy: Issues currency, controls money supply, and manages interest rates.
• Banking regulation: Oversees commercial banks and other credit institutions to maintain financial stability.
• Foreign exchange management: Sets exchange rate policies, manages Vietnam’s foreign currency reserves, and oversees international capital flows.
• Capital transfer and investment oversight: Regulates registration of foreign loans and outward investment, both private capital and government capital flows, to foster compliance with foreign exchange regulations.
• Financial stability: Protect the safety of the banking system and prevent risks related to cross-border capital movement.

In the context of outward investment, the SBV acts as the key authority for registering capital transfers abroad. Instead of companies waiting for detailed pre-approval from multiple ministries, if the proposal is applied, they will primarily deal with the SBV to make sure that money leaving Vietnam is legal, transparent, and compliant with foreign exchange laws.

This change represents a fundamental rebalancing of responsibilities. Enterprises are trusted to make timely investment decisions. At the same time, the banking system shall be responsible for maintaining compliance through the financial procedures.

Alignment with global standards with the Ex Post Review method

Vietnam’s move from pre-approval to post-monitoring is not just a domestic reform. It also signals a commitment to comply more closely with international standards, especially in areas where scrutiny has been increasing.

Anti-money laundering and counter-terrorism financing

Vietnam has been under the spotlight since the Financial Action Task Force (FATF) placed the country on its grey list in 2023. This highlighted weaknesses in monitoring capital flows, enforcing beneficial ownership transparency, and ensuring consistent reporting across financial institutions. The proposed framework, reinforced by Decree 19/2025/ND-CP⁽²⁾, shifts resources from procedural checks before investment to transaction monitoring after capital moves abroad.

Following the suggestion, the State Bank of Vietnam will take the lead in supervising foreign exchange and capital transfer registrations, allowing for more effective detection of irregularities.

These steps show Vietnam’s determination to address FATF’s recommendations and strengthen its role as a responsible global financial partner, even as full compliance remains a work in progress.

ESG standards as a strategic asset

The global rise of Environmental, Social, and Governance (ESG) standards has made sustainability a core part of investment strategy. In Vietnam, this trend is taking shape through policy guidance, such as the Ministry of Finance’s 2023 ESG handbook and Resolution 68 of 2025⁽³⁾, which encourages investing in Vietnam’s green processing projects.

Under the post-monitoring model, companies no longer rely on government approvals to validate ESG credentials upfront. Instead, they are expected to demonstrate their performance continuously, with both regulators and international partners able to assess their impact over time.

This turns ESG into more than a compliance requirement; it becomes a competitive edge in attracting capital and building trust in global markets.

The broader compliance landscape

Vietnam’s reform comes as global investors expect higher transparency and accountability across all jurisdictions. Stronger reporting practices, closer alignment with climate commitments such as the country’s net-zero 2050 pledge, and enhanced cooperation with foreign regulators are becoming central to Vietnam’s economic strategy.

By shifting the burden of responsibility to enterprises while reinforcing oversight through the SBV and international partnerships, Vietnam is positioning itself to attract more sustainable and reputable investment. The transition is ongoing, but the direction is clear: the country is building a system where efficiency and global compliance work hand in hand.

Vietnam’s transition to post-monitoring is not only an administrative change but also a sign of strategic maturity, and the table below shows how the reforms move Vietnam closer to global standards:

Area	Current approach	Proposed reforms	Global benchmark
AML/CTF compliance	Pre-approval checks by multiple ministries, with little focus on monitoring after the capital moved abroad	SBV oversees capital transfers, increased transaction reporting under Decree 19/2025/ND-CP	FATF recommendations on risk-based supervision and real-time monitoring
Beneficial ownership	Limited disclosure, fragmented records across agencies	Push for centralised databases, stronger due diligence requirements	FATF standard requiring transparency of ultimate beneficial owners
ESG integration	Treated as a secondary compliance issue, no systematic review	ESG guidance by the Ministry of Finance, continuous scrutiny under post-monitoring	Global investor expectations, EU sustainability directives, net-zero targets
Transparency and reporting	Lengthy upfront approval paperwork, less similarity with global requirements	Shorter approval times, focus shifts to ongoing accountability	OECD and World Bank standards on transparency and investment facilitation

Vietnam’s compliance trajectory in the global context

Conclusion from the proposal

Vietnam’s new outward investment proposal signals a clear intention by the government to create an environment where private capital can thrive globally. It reflects a forward-looking mindset that reduces administrative barriers and builds trust through stronger compliance and monitoring.

For businesses, this does not mean a complete shift in operations yet, as the framework is still at the proposal stage. However, staying updated is critical to anticipate changes and prepare for new obligations once they come into effect.

As discussed throughout this article, the potential move places investing in Vietnam and global businesses from Vietnam in line with international practices on risk management, AML, and ESG compliance, and sustainable growth.

Together, these elements highlight how the country is aligning its investment environment with global movements, while giving enterprises the clarity they need to plan for the future.

For staying ahead of Vietnam’s evolving regulatory landscape and unlocking new pathways for global expansion, visit BBCIncorp or email us at service@bbcincorp.com. Our team is ready to support your next move.

References:

(1): https://vir.com.vn/structural-barriers-still-hinder-asean-enterprise-expansion-131346.html

(2): https://vanban.chinhphu.vn/?pageid=27160&docid=212708

(3): https://portal.mof.gov.vn/webcenter/portal/btcvn/pages_r/l/tin-bo-tai-chinh?dDocName=MOFUCM345171

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