Sovico Neobank Launch Workspace
What is your role?
Pick your role to get a launch plan, your next 3 actions and the evidence each step needs. Independent planning tool — not an official Sovico, HDBank or VIFC document, and not legal advice.
Three proposed workstreams
Proposed allocations for planning — not agreed roles or commitments of any company.
Regulatory & Legal (Viet Nam / VIFC)
Proposed: Regulatory Affairs with external Vietnamese counsel
- City/jurisdiction memo and Executive Agency liaison
- Art. 12 eligibility memo, dossier completeness, written-evidence register
- AIFC licences do not passport to Viet Nam — every permission is obtained locally
Banking (HDBank / proposed licensed bank)
Proposed: Bank Sponsor and Bank Applicant teams
- Board/GMS resolutions, capital plan, blocked SBV capital account
- Business plan, governance, AML/CFT, controls manual
- No deposit-insurance claim (Art. 5); customer risk warnings (Art. 7)
Partnerships & Technology
Proposed: Sovico PMO with technology, crypto and RWA partners
- Integrated plan, data room, steering committee
- Core banking, security testing, opening readiness
- Any regulated partner (custody, crypto, RWA) must obtain its own permissions
Step 1
Choose your role
Step 2 · Critical fork
Record the strategic path and the city
Path: Not decided City: Unresolved
This records your internal working decision in this browser. It is not an official approval.
Two-city issue
HDBank's 26 Mar 2026 draft referenced VIFC Ho Chi Minh City; previous Sovico collaboration focused on VIFC Da Nang. Each has a distinct Executive Agency. The draft's current status (adopted, amended or withdrawn) must be verified. Decide and document the city and jurisdiction before any formal file. P09 P06
Red lines
- Never describe the entity as a licensed bank without the written licence on file.
- Never claim deposit insurance — VIFC bank deposits are not covered (Decree 329 Art. 5).
- No crypto yield, Earn or crypto lending before the provider holds its own written permission.
- A bank licence does not include any crypto-asset permission.
Banking launch
0% 0/47
Gates G0–G6, G8–G9 banking tasks. Crypto and partner work do not block this.
Crypto-enabled launch
0% 0/55
Banking tasks plus all crypto tasks incl. G7 provider authorisation.
Partner ecosystem
0% 0/3
Trade finance and partner contracting (phase 2, proposed roles).
Gate progress is a planning indicator. A gate is never legally signed off by this tool — only official written approval evidence does that.
Stop / go check before any live business
'Done' means an employee recorded an evidence reference — not that a regulator approved anything. This check never grants approval: live business needs the formal written regulator permission and proper internal sign-offs, verified by counsel.
Banking launch
NO-GO0/17 checks recorded
- Strategic path not recorded
- City not recorded
- G0-01 · Signed project charter (internal)
- G0-02 · Strategic path decision memo
- G0-03 · City & jurisdiction memo
- G1-01 · Signed eligibility memo
- G1-03 · Board resolution (adopted)
- G1-04 · Adopted GMS resolution or amendment record
- +9 more
Crypto-enabled launch
NO-GO0/20 checks recorded
- Strategic path not recorded
- City not recorded
- G0-01 · Signed project charter (internal)
- G0-02 · Strategic path decision memo
- G0-03 · City & jurisdiction memo
- G1-01 · Signed eligibility memo
- G1-03 · Board resolution (adopted)
- G1-04 · Adopted GMS resolution or amendment record
- +12 more
Step 3
Critical path to launch — 10 gates
Legal basis: Resolution 222/2025/QH15 (two VIFC locations); HDBank draft 26 Mar 2026 references VIFC HCMC.
Exit evidence: Signed charter, recorded path decision and city/jurisdiction memo.
- G0-01Issue the project charter and mandateProject Owner / Sovico PMOP1Not started
Why: Without a mandate nobody can speak to authorities or commit budget.
What to do: Draft a charter naming sponsor, PMO lead, proposed applicant entity, budget envelope, decision rights and steering cadence; obtain internal signature.
Output: Signed project charter (internal) · Prerequisites: — · evidence reference required
- G0-02Decide the strategic path (A / B / C)Bank Sponsor / HDBank board & group strategyP1Not started
Why: Each path has a different applicant, licence and timeline; the dossier cannot start without it.
What to do: Compare new VIFC bank, partner-led front-end and staged bank + digital asset services on control, capital, time and legal risk; record the choice and rationale.
Output: Strategic path decision memo · Prerequisites: G0-01 · evidence reference required
- G0-03Resolve city and jurisdiction (HCMC vs Da Nang)Regulatory Affairs / legal counselP1Not started
Why: HDBank's 26 Mar 2026 draft references VIFC HCMC while prior Sovico work focused on Da Nang; each has a distinct Executive Agency.
What to do: Map which Executive Agency, procedures and local rules apply in each city; confirm the sponsor's intent; document one city before any formal filing.
Output: City & jurisdiction memo · Prerequisites: G0-01 · evidence reference required
- G0-04Draw the legal entity mapProject Owner / Sovico PMOP2Not started
Why: One app can hide several legally distinct providers; regulators review each.
What to do: Show bank, any digital asset provider, technology vendors and trade partners with ownership, licence needed and contract link; mark every partner role as proposed.
Output: Entity map v1 · Prerequisites: G0-02
- G0-05Open the data room and document registerBank Applicant / establishment team, CFO, CROP2Not started
Why: Dossier evidence must be versioned and traceable.
What to do: Set up an access-controlled repository with folders per gate, naming rules and a register of document owners; keep personal data out of this web tool.
Output: Data room index · Prerequisites: G0-01
- G0-06External view: what an Executive Agency asks firstRegulator view (external perspective)P3Not started
Why: Authorities first identify the applicant, location and requested activity.
What to do: List the public forms and guidance of the chosen city's Executive Agency and the documents to request from it; do not assume any timetable.
Output: List of external documents to request · Prerequisites: G0-03
Step 4
Task tracker
'Done' = evidence reference recorded by an employee. It is not regulator approval and does not authenticate the document.
58 / 58 tasks shown
Issue the project charter and mandate
Signed project charter (internal)
Decide the strategic path (A / B / C)
Strategic path decision memo
Resolve city and jurisdiction (HCMC vs Da Nang)
City & jurisdiction memo
Draw the legal entity map
Entity map v1
Open the data room and document register
Data room index
External view: what an Executive Agency asks first
List of external documents to request
Prepare the Art. 12 parent eligibility memo
Signed eligibility memo
Assemble the parent evidence pack
Indexed evidence pack
Adopt the parent board resolution
Board resolution (adopted)
Finalise the shareholder (GMS) resolution
Adopted GMS resolution or amendment record
Check group approvals, related-party and parent notifications
Approvals register
Build the product / client scope matrix
Scope matrix v1
Write the perimeter classification note
Perimeter note
Scope crypto services separately
Crypto perimeter annex
Draft mandatory customer disclosures
Disclosure set (draft)
Shortlist trade finance products
Trade product shortlist
Outline the target architecture
Architecture outline
Send the clarification request to the Executive Agency
Clarification request letter
Hard stop: path/city
Run the meeting plan and minutes register
Regulatory meeting minutes
Hard stop: path/city
Consult the supervisory authority / SBV
SBV consultation record
Hard stop: path/city
Pre-consult the Ministry of Finance on the crypto route
MoF consultation note
Hard stop: path/city
File the written scope confirmation
Scope agreement record
Hard stop: path/city
External view: possible response types
Response-type contingency note
Hard stop: path/city
Write the business plan
Business plan
Hard stop: path/city
Prepare the capital plan
Capital plan
Hard stop: path/city
Prepare governance and key-person files
Governance pack
Hard stop: path/city
Check completeness against the Art. 15 procedure
Dossier completeness checklist
Hard stop: path/city
Write the IT & security description
IT & security dossier section
Hard stop: path/city
Draft the AML/CFT programme
AML programme (draft)
Hard stop: path/city
Submit the dossier and record receipt
Submission receipt
Hard stop: path/city
Obtain confirmation that the dossier is complete
Completeness confirmation
Hard stop: path/city
Run the request-for-information log
RFI log
Hard stop: path/city
Register the written licence and its conditions
Written licence & conditions register
Hard stop: path/city
External view: the decision step
Decision-outcome plan
Hard stop: path/city
Track the 12-month opening deadline
Opening deadline plan
Hard stop: path/city
Pay in charter capital to the blocked SBV account
Blocked-account confirmation
Hard stop: path/city
Constitute the board, committees and risk framework
Board minutes & risk appetite statement
Hard stop: path/city
Adopt the business controls manual
Business controls manual
Hard stop: path/city
Implement core, security and data controls
Configuration & control evidence
Hard stop: path/city
Secure and evidence office premises
Premises evidence
Hard stop: path/city
Finalise the AML programme and appoint the MLRO
AML programme (final)
Hard stop: path/city
Obtain the digital asset provider authorisation
Provider authorisation copy
Hard stop: path/city
Sign the custody agreement
Custody agreement (signed)
Hard stop: path/city
Approve the crypto-backed loan policy
Crypto loan policy
Hard stop: path/city
Decide on Earn (default: do not launch)
Earn decision record
Hard stop: path/city
Negotiate partner term sheets (proposed)
Partner term sheets
Hard stop: path/city
External view: MoF review of a crypto provider
MoF document request list
Hard stop: path/city
Complete end-to-end and penetration tests
Test & pen-test reports
Hard stop: path/city
Run an independent controls readiness audit
Audit readiness report
Hard stop: path/city
Publish the opening announcement (≥ 30 days)
Opening announcement record
Hard stop: path/city
File the 15-day pre-opening notification
Pre-opening notification receipt
Hard stop: path/city
Test onboarding, disclosures and complaints
Customer journey test log
Hard stop: path/city
External view: the pre-opening check
Inspection evidence binder
Hard stop: path/city
Give the internal go-live sign-off
Go-live sign-off
Hard stop: path/city
Launch a controlled bank-only pilot
Pilot plan & limits
Hard stop: path/city
Run hypercare and incident management
Hypercare plan
Hard stop: path/city
Enable crypto services in phase 2
Phase-2 crypto release record
Hard stop: path/city
Launch phase-2 trade finance with partners
Trade pilot review
Hard stop: path/city
RACI matrix
R = responsible, A = accountable, C = consulted, I = informed. 'Ext' = external authority receives or reviews — never an internal approver. * = proposed, subject to agreements and licences.
| Work package | Project Owner | Bank Sponsor | Bank Applicant | Regulatory Affairs | Digital Asset Partner | Technology, Operations & Security Delivery | Trade Finance & Partner Ecosystem | Regulator view (external perspective) |
|---|---|---|---|---|---|---|---|---|
| Project charter & steering | R | A | C | C | I | I | I | — |
| Strategic path decision | R | A | C | C | C | I | I | — |
| City & jurisdiction decision | C | A | C | R | I | I | I | — |
| Parent eligibility (Art. 12) | I | A | R | R | — | — | — | — |
| Board & GMS resolutions | I | A/R | C | C | — | — | — | — |
| Product / client scope matrix | C | A | R | R | C | C | C | — |
| Authority consultations | C | I | C | A/R | C | I | I | Ext |
| Business & capital plan | C | A | R | C | I | C | I | — |
| Licence dossier & submission | C | I | R | A | C | C | I | Ext |
| AML/CFT & controls manual | I | I | A/R | C | C | C | I | — |
| IT, security & testing | I | I | A | C | C | R | I | — |
| Crypto provider authorisation & custody | I | C | C | C | R* | I | — | Ext |
| Partner term sheets (proposed) | C | A | C | C | C | I | R* | — |
| Opening procedures & go-live | R | A | R | C | I | R | I | Ext |
First 10 working days
A realistic internal working plan — not a statutory timeline.
Days 1–2
Sponsor alignment, project charter, city alignment
- Project charter (draft for signature)
- City & jurisdiction issues note (HCMC vs Da Nang)
Days 3–4
Owner criteria and product classification
- Art. 12 criteria table with evidence requests
- Scope matrix v0
Days 5–6
Initial regulator clarification request and data room
- Draft clarification request (12 questions)
- Data room index
Days 7–8
Partner technical and commercial term sheets
- Non-binding term sheet outlines (subject to contract)
- Crypto perimeter annex
Executive brief for the steering committee
EXECUTIVE BRIEF — VIFC NEOBANK LAUNCH PLAYBOOK (working copy, 2026-10-29) Internal planning instrument, not legal advice; no official approval is recorded here unless backed by written evidence. 1. Recorded path: Not decided. City: Unresolved. HARD STOP: path and city must be decided before any formal filing. 2. Banking launch readiness: 0/47 tasks (0%). Crypto-enabled readiness: 0/55 (0%). 3. The parent must evidence each Decree 329 Art. 12 criterion; eligibility is not assumed. 4. The 120-day review (Art. 16) runs only after a complete, valid dossier. Full charter capital in a blocked SBV account ≥30 days before opening; announcement ≥30 days; notification ≥15 days; open within 12 months. 5. VIFC deposits have no Viet Nam deposit insurance (Art. 5). Crypto services need separate MoF-route authorisation; a bank-only pilot can go first. 6. HDBank's 26 Mar 2026 paper is a draft proposal referencing HCMC; it is not a licence. Steering committee asks: confirm path and city; approve sending the 12 authority questions.
Authority Engagement Kit
12 questions in the suggested meeting order. Copy the agenda text into your own official correspondence — nothing is sent from this site, and no reply or acknowledgement is implied.
Meeting 1
VIFC Executive Agency (of the chosen city)
- Which Executive Agency is competent for a bank establishment application by our proposed applicant, and through which official channel should the dossier be filed?
- Please confirm the current dossier list and forms under Decree 329 Art. 15 and any local implementing guidance.
- Which client categories (VIFC members, non-members, non-residents) may the proposed bank serve, and in which currencies?
- Does the bank licence also serve as enterprise and VIFC membership registration, with no separate membership filing?
- How is the date of a 'complete and valid dossier' communicated for the Art. 16 review period?
Possible response types: Written guidance, pre-filing meeting, list of required documents, or request for more information.
Meeting 2
Supervisory authority / State Bank of Viet Nam
- What evidence does the authority expect to demonstrate each Decree 329 Art. 12 parent criterion (capital, safe operation, NPL, rating, scale, profitability)?
- Does the parent bank require any separate SBV approval or notification for investing in a VIFC subsidiary bank?
- What are the practical steps to open the blocked, non-interest SBV account for charter capital before opening?
- Which prudential reports and supervisory interfaces apply from day one of operation?
Possible response types: Consultation meeting, written view on eligibility evidence, or referral to the Executive Agency.
Meeting 3
Ministry of Finance — crypto-asset pilot
- Which of custody, crypto-backed lending, Earn/yield and stablecoin services fall within the Resolution 05/2025 pilot, and which do not?
- May a VIFC member bank refer clients to, or integrate with, a separately authorised crypto-asset service provider, and on what conditions?
- Which MoF procedure and dossier apply to the proposed provider, and what is the expected sequence relative to the bank licence?
Possible response types: Reference to published administrative procedures, written clarification, or no view at this stage.
Playbook sources
Official primary texts and local registration pages, as checked to 29 Oct 2026. AFSA banking, lending and custody precedents are in the source library.
- P01Decree 329/2025/ND-CP — official English text (PDF)
Arts. 5, 7, 12, 15, 16, 18, 19 used throughout the playbook.
- P02Decree 329 — Government legal documents portal
Official metadata and Vietnamese text.
- P03VIFC Da Nang — Business Area guidance
States the bank licence also serves as enterprise/membership registration.
- P04VIFC Da Nang — Registration
Membership registration route (5–7 working days listed) — not a banking licence.
- P05VIFC Da Nang — Legislation index
Index of applicable instruments.
- P06Resolution 222/2025/QH15 on the VIFC
National Assembly basis for the centre in HCMC and Da Nang.
- P07Resolution 05/2025/NQ-CP — crypto-asset market pilot (full text)
Pilot framework; not a blanket licence.
- P08MoF — administrative procedures for the crypto-asset pilot (Jan 2026)
Provider licensing procedures.
- P09HDBank — draft GMS resolution, 26 Mar 2026 (PDF)
DRAFT corporate proposal referencing VIFC HCMC — not a licence or final shareholder approval.