The MIMO Pilot Program: A Strategic Step in Vietnam’s Digital Asset Governance

Da Nang’s approval of the MIMO pilot program — a non-custodial intermediary solution enabling the conversion between digital assets (USDT) and fiat currency (VND) — represents a meaningful milestone in Vietnam’s evolving approach to digital asset governance.

Beyond its technological significance, this initiative reflects a measured, forward-looking regulatory mindset, balancing innovation with systemic stability, consumer protection, and regulatory accountability.

Vietnam’s First Licensed Non-Custodial Conversion Model

Developed by Dragon Lab JSC, the MIMO solution has been approved for controlled pilot deployment at three strategic innovation hubs in Da Nang:

• Da Nang Software Park No.1
• Da Nang Software Park No.2
• Da Nang Innovation Startup Support Center

According to the project operator, MIMO is currently the first and only solution in Vietnam authorized to pilot a non-custodial USDT–VND conversion model under a regulatory sandbox framework.

Unlike traditional digital asset exchanges, MIMO does not take custody of user funds. The platform functions exclusively as a verification, coordination, and transaction-orchestration layer, ensuring that both digital assets and fiat funds remain under the direct ownership and control of users at all times.

This architecture directly addresses one of the most critical vulnerabilities observed in global digital asset markets — custodial risk — while reinforcing transparency and trust.

Technology-Enabled Compliance and Risk Management

Participation in the pilot requires users to complete electronic Know-Your-Customer (eKYC) procedures via state-licensed telecommunications providers. Users must register:

• A bank account held under their legal identity
• A personal blockchain wallet

The MIMO system integrates blockchain analytics and transaction-monitoring tools to assess wallet integrity, identify potential exposure to illicit activities, and mitigate risks associated with money laundering, fraud, or regulatory breaches.

Data protection and cybersecurity standards are applied throughout the transaction lifecycle, reflecting a growing shift toward “compliance by design” — embedding regulatory safeguards directly into system architecture rather than relying solely on ex-post supervision.

Alignment with Vietnam’s New Digital Asset Legal Framework

Effective January 1, 2026, Vietnam’s legal framework governing digital assets officially comes into force, providing statutory recognition and regulatory clarity for this emerging asset class.

Under the law, digital assets are recognized as civil assets represented in digital form, created, stored, transferred, and authenticated through digital technologies. The framework establishes clear state oversight across ownership rights, operational responsibilities, cybersecurity requirements, and anti-money laundering and counter-terrorism financing obligations.

Within this context, controlled pilot programs such as MIMO serve as institutional learning mechanisms, enabling regulators to test governance models, assess compliance capacity, and collect real-world operational data before broader market authorization.

Da Nang as a Strategic Sandbox for Digital Finance

Da Nang is one of two cities selected by the central government to host Vietnam’s International Financial Center (IFC). The city’s vision extends beyond traditional finance, positioning the IFC as a platform for experimentation, policy prototyping, and next-generation financial infrastructure.

With strong digital foundations, a skilled technology workforce, and a dynamic innovation ecosystem, Da Nang is uniquely positioned to pilot:

• Digital and tokenized asset frameworks
• Blockchain-based payment and settlement models
• AI-assisted compliance and risk-monitoring systems

The MIMO pilot represents a practical and credible step in validating Da Nang’s readiness to supervise and govern digital finance activities at scale.

A Sandbox-First Regulatory Philosophy

Globally, leading financial centers — including Singapore — have adopted sandbox-first regulatory approaches to navigate the rapid evolution of digital finance. This strategy allows authorities to encourage innovation while preserving market integrity and financial stability.

By implementing a controlled pilot rather than immediate large-scale deployment, Da Nang demonstrates alignment with international best practices, emphasizing evidence-based policymaking and phased market development.

A Measured but Strategic Advancement

Vietnam’s high smartphone penetration, digitally fluent population, and growing interest in blockchain and Web3 technologies provide a strong foundation for digital finance innovation. However, long-term success depends on robust governance frameworks and institutional capacity.

The MIMO pilot program should therefore be viewed not merely as a technical initiative, but as a strategic governance milestone — one that contributes to:

• The development of transparent and compliant digital asset infrastructure
• Enhanced supervisory capabilities for regulators
• Institutional preparedness for the future International Financial Center

If executed effectively, MIMO may serve as a blueprint for how Vietnam integrates digital assets into its financial system — responsibly, securely, and in alignment with global standards.