DOCUMENTARY CONTROLS FOR DIGITAL OUTWARD UNILATERAL TRANSFERS BY RESIDENT VIETNAMESE CITIZENS

Abstract

Digital outward transfers facilitate legitimate personal payments but raise questions about documentary verification and the origin of funds. This article examines banks’ responsibilities under Vietnamese foreign exchange, anti-money laundering and electronic transactions law, with reference to publicly available professional guidance and information on app-based international transfer services at Military Commercial Joint Stock Bank (MB). It finds that permitted amounts depend on the transfer purpose and that operational document lists cannot replace risk assessment. Receiving a scanned document does not establish its issuer, integrity or correspondence with the underlying transaction. The analysis identifies verification constraints concerning funds passing through multiple transactions, foreign documents and information held outside the bank. The article proposes clearer documentary principles, legally controlled data verification, procedures for exceptional cases and technology that supports accountable human review. It distinguishes changes requiring regulatory action from measures within a bank’s managerial authority. The analysis addresses legal duties and information constraints, without estimating misconduct or measuring the operational performance of individual banks. These proposals aim to improve verifiability while preserving access to lawful transfers.