Cross-Border Data Transfer and Processing in International Financial Centers: Legal Challenges and Implications for Vietnam

Abstract

The establishment of International Financial Centers (IFCs) in Ho Chi Minh City and Da Nang marks an important milestone in Vietnam’s strategy to deepen international economic integration and enhance its position in global financial markets. The operation of IFCs relies heavily on the collection, processing, storage, and transmission of large volumes of financial data and personal data, many of which are highly sensitive and subject to stringent security requirements. In this context, cross-border data transfer and processing have become indispensable for facilitating international financial transactions, investment activities, and digital financial services. This article examines the legal issues associated with cross-border data transfer and processing within IFCs in Vietnam. Using a doctrinal legal research approach, the study analyzes Vietnam’s emerging legal framework, including the 2024 Data Law, the 2025 Law on Personal Data Protection, Resolution No. 222/2025/QH15 on International Financial Centers, and relevant implementing regulations. The article also draws comparative insights from international practices, particularly those of Hong Kong, Singapore, and the CPTPP framework. The findings indicate that while Vietnam has established important safeguards to protect national security, data sovereignty, and personal data, existing regulatory requirements may create compliance challenges for IFC participants and potentially constrain data-driven financial activities. The article argues for the development of a specialized legal framework governing cross-border financial data flows that balances regulatory oversight with the operational needs of globally integrated financial centers.