Mobile Wallet in Vietnam: Check the License First

Mobile wallet in Vietnam services run by a company that is not a bank must hold a licence from the State Bank of Vietnam, and you should confirm it before you add any money. Ask the provider for its licence details in writing. A wallet that cannot show a licence is not one to trust with your cash.

1. What a mobile wallet is, in the rules

A new State Bank rule took effect on March 1, 2015. It is Circular 39/2014/TT-NHNN, signed on December 11, 2014. It covers "intermediary payment services", and the e-wallet is one of them.

The circular describes an e-wallet as an account in your name. The provider creates it on a carrier such as a chip, a mobile phone SIM or a computer. It holds a sum of money. That sum is backed one to one by money moved from your bank payment account into the provider's own guarantee account at a bank. You then use the balance to pay without cash.

In plain words, the balance you see in the app should match real money held in a bank. That is the idea behind the licence.

Sources: State Bank of Vietnam, Circular 39/2014/TT-NHNN of December 11, 2014, definition of the e-wallet service and effective date (Vietnamese text and summary at luatvietnam.vn).

2. Who gives the licence

The State Bank grants, withdraws and reissues the licence. It does this under Articles 15 and 16 of Decree 101/2012/ND-CP on non-cash payments, dated November 22, 2012. This licence is for companies that are not banks, and such a company can apply if it meets the conditions in the decree and in the circular. Banks offer payment services under their own banking licence instead.

The circular also set a short bridge for firms already running trials. Non-bank firms that the State Bank had allowed to run a pilot could be considered for a full licence from March 1, 2015. The pilot papers were to stop having effect nine months after that date. So by early 2016, a provider that is still offering a wallet should be able to name its full licence, not a pilot letter.

The licence has rules of its own. The holder must use the exact name written on it and work only within what it allows. It is banned to fake, erase, sell, rent or lend a licence. It is also banned to hand the licensed activity to another person or shop to run for you.

Sources: Circular 39/2014/TT-NHNN, Articles 4 and 6 and the transition rule; Decree 101/2012/ND-CP, Articles 15 and 16, as cited in the circular.

3. Five checks before you add money

These steps take a few minutes. Do them before the first top up.

First, ask for the licence. Ask for the name of the licensed company, the licence number and the date it was issued. A real licence holder will answer without fuss.

Second, match the names. The company that takes your money should be the company named on the licence. If the app, the website and the licence show three different names, ask why.

Third, ask the State Bank if you are unsure. The State Bank is the body that issues the licence, so it is the right place to confirm one.

Fourth, read the fees. The circular tells providers to agree the types of fees and fee levels with the customer before the customer uses the service. If you cannot find the fees, do not top up yet.

Fifth, look for a complaints route. Providers must handle customer complaints. Ask who to contact and how, before you need to.

Sources: Circular 39/2014/TT-NHNN, Article 13, the duties of providers to agree fees with customers before use and to handle complaints.

4. How your money should move

The circular defines the e-wallet by where the money comes from. The balance is backed one to one by money moved from your own bank payment account into the provider's guarantee account at a bank. That gives you a simple test of any wallet.

First, the money in the wallet should trace back to your bank account. A wallet that takes only cash at a shop or from a third person does not fit that description, so ask how it holds your money.

Second, the balance should be money, not a promise. Ask the provider which bank holds the guarantee account for customer balances. A provider that cannot name the bank has not answered the main question about your cash.

Third, be careful with offers of "interest" or bonus money on a balance. That is not how the circular describes a wallet, so ask the provider to show you where the licence allows it.

Sources: Circular 39/2014/TT-NHNN, Article 3, definition of the e-wallet service (1:1 backing by money moved from the customer's bank payment account to the provider's guarantee account).

5. Which receipts to keep

Keep proof of every top up and every payment. A short record can settle a dispute fast.

• The bank message or receipt for each top up from your bank account.
• The wallet's own confirmation for each payment, with the date, time, amount and the name of the shop or biller.
• A screenshot of the fee page on the day you opened the wallet.
• The licence details the provider gave you, with the date you asked.
• Any complaint you file, with the reference the provider gives you.

The circular expects providers to keep electronic records under the law on electronic transactions in banking. Your own copy helps when the two sides disagree. Report a lost phone or a wrong payment at once, and write down the time you did it.

Sources: Circular 39/2014/TT-NHNN, Article 7, on keeping electronic records under the law on electronic transactions in banking. The receipt list is common sense practice, not a rule from the State Bank.

6. The short version

Ask for the licence, match the name, read the fees, ask which bank holds the guarantee account, and keep your receipts. If a provider refuses to name its licence or cannot say where customer money is held, walk away.

Sources: State Bank of Vietnam, Circular 39/2014/TT-NHNN, Vietnamese text at luatvietnam.vn (https://luatvietnam.vn/tai-chinh/thong-tu-39-2014-tt-nhnn-ngan-hang-nha-nuoc-viet-nam-91444-d1.html); Decree 101/2012/ND-CP on non-cash payments.