On June 28, 2024, the State Bank of Vietnam issued Circular 18/2024/TT-NHNN (“Circular 18”) regulating bank card operations. Circular 18 primarily supplements new regulations to strengthen the measures of organizations in ensuring safety in card transactions following the implementation of biometric identification for payment transactions on banking application platforms.
Below are some notable contents of Circular 18 updated by ATA Legal Services as follows:
1. Cash withdrawals from credit cards not exceeding VND 100 million/month from January 1, 2025
To limit the use of cash and also to enhance risk management in the practical use of bank cards, Circular 18 has supplemented regulations on the withdrawal limit from credit cards and the transaction limit for prepaid cards as follows:
- For credit cards: the total cash withdrawal limit calculated according to the BIN of the credit card is a maximum of VND 100 million per month (This regulation is effective from January 1, 2025);
- For prepaid cards: the total transaction limit (including cash withdrawal transactions, transfer transactions, and payment transactions for goods and services) on a named prepaid card must not exceed VND 100 million per month.
2. Bank cards must match the cardholder's biometric data before card issuance/electronic payment
To enhance safety and authentication in card issuance and electronic card transactions, Circular 18 has supplemented new regulations on card issuance and card usage for electronic transactions. Accordingly, when verifying customer identification information, card-issuing organizations (“CIOs”) must ensure the cardholder’s biometric data (for individuals) or the legal representative’s biometric data (for organizations) match the biometric data collected/stored according to regulations
Similarly, using the card for electronic transactions must ensure that the identity documents and biometric information of the cardholder match the biometric data collected/stored according to regulations after verification.
This regulation is effective from January 1, 2025. For CIOs that are under special control, this regulation will be effective from July 1, 2025.
3. Enhancing security, safety, and confidentiality measures in card usage
Compared to the old regulations, Circular 18 supplements additional measures for CIOs to ensure security, safety, and confidentiality in card usage as follows:
- Implement measures to check, verify, and authenticate customer information during card issuance and usage;
- Develop criteria to identify cards suspected of fraud, deception, and legal violations;
- Identify and handle various risks in card issuance and usage;
- Check cardholder information with the State Bank's risk management support system;
- Warn and guide customers on criminal methods and information security;
- Re-verify customer information in suspicious cases;
- Check and store documents and transaction records of cards used abroad;
- Monitor the validity period of customer identity documents.
Additionally, Circular 18 supplements the responsibilities of CIOs in cooperating with intermediary payment service providers to comply with relevant legal regulations.
4. Reducing the handling time for review and complaint requests for cards with BIN issued by the State Bank
Compared to the old regulations, Circular 18 reduces the handling time for review and complaint requests from a maximum of 45 working days to a maximum of 30 working days for cards with BIN issued by the State Bank.
Additionally, Circular 18 supplements the requirement for CIOs to provide solutions for cardholders to check online information, progress, and results of review and complaint handling from July 1, 2025. The new Circular also specifies requirements for review and complaint request forms, which can exist in both paper and electronic formats.
Furthermore, the new Circular enhances the responsibilities of CIOs in promptly and timely handling customer requests, requiring CIOs to immediately take card-locking measures when the cardholder suspects fraud or loss and to be responsible for all financial losses of the customer arising after the customer requests to lock the card.
Except for the regulation on the cash withdrawal limit from credit cards, which will take effect from January 1, 2025, Circular 18 will be effective from July 1, 2024, replacing Circular 19/2016/TT-NHNN and its amending and supplementing documents.
Notes:
- For physical card templates printed before July 1, 2024, CIOs are allowed to continue using them until December 31, 2024;
- For customers with cards issued before July 1, 2024, CIOs must coordinate with customers to update and supplement documents, information, and data according to regulations, to be completed before January 1, 2026.
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