Hope it be an useful textbook for banking investment in Vietnam

1. VIETNAM BANKING REGULATIONS
Contents
Contents......................................................................................................................................................1
1

2. RELEVANT LAWS AND REGULATIONS
No. Laws and Regulations Effective Dates Notes
1. Law on Credit Institutions 2010 Jan 01, 2011 LCI
2. Decree 59/2009/ND-CP on organization
and operation of commercial banks
Aug 10, 2009 Decree 59
3. Decree 01/2014/ND-CP on foreign
investors' purchase of shares of
Vietnamese credit institutions
Feb 20, 2014 Decree 01
4. Circular 02/2013/TT-NHNN providing
guidelines for risk provisioning and debt
classification
Jun 01, 2014 Circular 02
5. Circular 09/2014/TT-NHNN amending
some articles of Circular 02/2013/TT-
NHNN
Mar 20, 2014 Circular 09
6. Circular 36/2014/TT-NHNN regulating
prudential ratios for the operations of
credit institutions and foreign bank
branches
Feb 01, 2015 Circular 36
7. Circular 06/2016/TT-NHNN amending
some articles of Circular 36/2014/TT-
NHNN
July 01, 2016 Circular 06
8. Circular 22/2016/TT-NHNN on the
purchase of corporate bonds by credit
institutions and branches of foreign banks
Aug 15, 2016 Circular 22
9. Circular 39/2016/TT-NHNN prescribing
lending transactions of credit institutions
and/or foreign bank branches with
customers
Mar 15, 2017 Circular 39
10. Circular 41/2016/TT-NHNN prescribing the
capital adequacy ratio for operations of
banks and/or foreign bank branches
Jan 01, 2020 Circular 41
2

3. I. SCOPE OF PERMITED ACTIVITIES OF VIETNAMESE BANKS
1. General View
• Banking activity in Vietnam is governed by the Law on Credit Institutions (“LCI”) as well as a
number of implementing decrees, circulars and decisions issued by the government, the
State Bank of Vietnam (“SBV”) and the Ministry of Finance (“MOF”).
• In general, the cross-border supply of banking services into Vietnam is heavily restricted by
Vietnamese law. Offshore banks may generally not provide services to Vietnamese entities,
with the notable exception of hard currency loans (which are subject to strict exchange
control regulations).
• The SBV performs the traditional role of a central bank and regulates the banking system in
Vietnam by working closely with the MOF and the SBV’s network of provincial branches.
Through its Banking Inspection and Supervisory Agency (“BSA”), the SBV is the authority
empowered to grant establishment and operating licenses to banks in Vietnam. The State
Securities Commission (“SSC”) regulates all securities activity in Vietnam, including securities
activities carried out by commercial banks.
• The scope of a credit institution’s permitted activities is specified in its banking license.
2. Permitted Activities
• Under the LCI, a commercial bank Vietnam shall be allowed to perform the following
activities1
:
(i) Receipt of on-call deposits, fixed term deposits, saving deposits and other type of
deposits; issuance of deposit certificates, promissory notes, bank notes and bonds in
order to raise both domestic and foreign capital;
(ii) Extension of credit in the form of loans, discounts and rediscounts of negotiable
instruments and other valuable papers, guarantees, issuance of credit cards,
factoring (international factoring applicable to banks authorized to conduct
international payment services only) and other forms of extension of credit upon
obtaining approval from SBV;
(iii) Opening payment accounts for clients;
(iv) Provision of payment facilities;
(v) Provision of the following payment services: domestic payment services comprising
cheques, payment orders, authorized payment orders, collection, collection order,
letters of credit, bank cards, services of receipt and disbursement as trustee; and
provision of international payment services and other payment services upon
obtaining approval from the SBV
(vi) Borrowing from both domestic and foreign credit institutions and financial institutions
in accordance with Vietnamese laws;
(vii) Opening accounts at the SBV, other credit institutions and offshore accounts in
accordance with the laws on foreign exchange;
(viii) Organization and participation in payment systems;
(ix) Capital contribution and share purchase in accordance with Vietnamese laws;
(x) Participation in the monetary market organized by the SBV;
(xi) Trading and provision of foreign exchange services and derivative products upon
1
Article 98 of the LCI
3

4. obtaining the SBV‘s approval;
(xii) Trust and agency activities; and
(xiii) Other business activities such as provision of cash management services, banking
and financial consultancy, asset management and preservation services, safe-
keeping services; corporate financial consultancy, consultancy on purchase and sale,
consolidation and merger of enterprises, investment consultancy; purchase and sale
of Government bonds and enterprise bonds; currency brokerage services; securities
depository, gold trading and other business activities related to banking activities are
permitted after obtaining written approval from the SBV.
II. ORGINIZATIONAL STRUCTURE
• In general, under the LCI and Decree 59/2009/ND-CP on the organization and operation of
commercial banks (“Decree 59”), a bank in Vietnam can be established under the form of a
limited liability company (with sole member or two-or-more members) or as a joint-stock
company. However, it is noted that:
(i) Foreign investors are not allowed to directly invest to establish a joint stock bank in
Vietnam, but a 100% foreign owned limited liability bank or a joint-venture bank (as
a two-or-more member bank) with Vietnamese partners2
.
(ii) With respect to indirect investment, foreign investors are allowed to purchase shares
of credit institutions (including joint stock banks) in Vietnam3
with a cap of 30% of
the target’s charter capital4
.
• With respect to a joint stock bank (“JSB”), its governance structure shall include the general
meeting of shareholders (“GMS”), the board of directors ("BOD"), the inspection committee,
general director (“GD”) and other managerial positions. Notably:
(i) The shareholder of the JSB and its related persons must not hold more than 20% of
charter capital of the bank5
.
(ii) The BOD must comprise at least 05 and no more than 11 members, in which there
must be at least ½ of total BOD members being non-executive and independent
members6
; the inspection committee shall comprise at least 03 members7
; and the
appointment of members of the BOD and the inspection committee must be
conducted via the GMS under accumulative voting method8
.
(iii) Any individual or any institutional shareholder represented by an individual who is a
member of the BOD or the inspection committee or a GD may not, while he or she is
in office, sell his or her shares9
.
• The requirements on managers, executives and inspection committee members of the JSB
shall be as follows:
Position Requirements
2
Article 4.8 and Article 6.4 of the LCI
3
Article 16 of the LCI
4
Vietnam’s WTO Commitment
5
Article 55.3 of the LCI
6
Article 62.1 of the LCI
7
Article 44.1 of the LCI
8
Articles 59.2, 59.3 of the LCI
9
Articles 56.1 of the LCI
4

5. Members of
the BOD10
:
- Being an individual shareholder or a person authorized to represent
ownership of at least 5% of the bank's charter capital and having
certificate of at-least 01 year experience working in banking sector; or
- Holding a tertiary or higher degree in economics, business
administration or law; or
- Having at least 3 years working as a manager of a credit institution or
an insurance, securities, accounting or audit business; or
- Having at least 5 years working directly in professional banking,
finance, audit or accounting division
Independent
members of
the BOD11
- Neither currently working for the JSB or its subsidiary nor working for
the JSB or its subsidiary for 3 preceding years;
- Not enjoying salaries or regular pay of the JSB other than allowances
for BOD members under relevant laws;
- Having no spouse, parent, child, sibling and spouses of these persons
being major shareholders of the JSB, managers or Inspection
Committee members of the JSB or its subsidiary;
- Neither directly nor indirectly owning or representing ownership of 1%
or more of the charter capital or voting share capital of the JSB;
together with his/her related persons not owning 5% or more of the
charter capital or voting share capital of the JSB; and
- Not being a manager or Inspection Committee member of the JSB at
any time in the 5 preceding years.
Inspection
Committee
members12
:
- Holding a tertiary or higher degree in economics, business
administration, law, accounting or audit: having at least 3 years‘
experience working directly in banking, finance, accounting or audit;
- Not being an affiliated person of a manager of the JSB; and
- Residing in Vietnam during his/her office term, for a full-lime
Inspection Committee member
GD13
- Holding a tertiary or higher degree in economics, business
administration or law;
- Having at least 5 years‘ experience working as an executive of a credit
institution or GD or Deputy Director of an enterprise with the owner's
capital at least equal to the charter capital required by law for each
type of credit institution or at least 10 years‘ experience working
directly in finance, banking, accounting or audit; and
- Residing in Vietnam during his/her office term.
• In order to efficiently perform its tasks and exercise its powers, The BOD must set up the
supporting commissions, in which the 2 mandatory commissions are Risk Management
Commission and Personnel Commission14
.
10
Article 50.1 of the LCI
11
Article 50.2 of the LCI
12
Article 50.3 of the LCI
13
Article 50.4 of the LCI
14
Article 43.6 of the LCI, Article 16.9 of Decree 59
5

6. III. PRUDENTIAL REGULATIONS
1. Capital Adequacy Ratio (CAR)
• Under the current Circular 36/2014/TT-NHNN (“Circular 36”) amended by Circular
06/2016/TT-NHNN (“Circular 06”), except for foreign banks’ branches, all banks in Vietnam
must regularly maintain a CAR of 9% between their equity and their total risk-weighted assets
(“RWA”)15
.
• The equity herein shall be the aggregate of Tier 1 capital and Tier 2 capital, which are clearly
specified in Appendix 1 of Circular 06.
(i) Tier 1 capital including charter capital, the reserve fund for supplementing the charter
capital, the professional development investment fund, the investment and
development fund, retained profits, shares issuance premium received and added to
the capital less the amounts used to repurchase shares (as the case may be).
Some other assets such as: treasury shares, balance of loans granted to finance the
contribution of equity capital or purchase of shares in other Institutions, investments
in a controlling equity stake in enterprises operating in the insurance sector,
securities sector, foreign exchange, gold, factoring, credit cards issuance, consumer
credit, intermediary payment services and credit information services, shall be
deducted from Tier 1 capital.
(ii) Tier 2 capital including 50% of the additional value of fixed assets following their
revaluation, 40% of revalued financial assets, financial reserves, long-term
unsecured subordinated convertible bonds and other deeply subordinated debt
instruments.
(iii) Tier 2 capital cannot exceed Tier 1 capital
• However, aiming to adopt the BASEL II standards, the minimum CAR shall be adjusted to 8%
from Jan 01, 2020 as stipulated Article 6 of Circular 41/2016/TT-NHNN (“Circular 41”). The
CAR will also be calculated following the formula under BASEL II. There will be also some
changes to the determination of Tier 1 and Tier 2 capitals under Circular 41 in comparison to
the current stipulations in Circular 3616
. Any bank can register with SBV to apply the 8% CAR
before the date Jan 01, 202017
2. Risk Weighting
• With respect to the RWA, credit risk is assessed according to a scale of 0%, 20%, 50%,
100%, 150% and 200% as stipulated in the Appendix 2 attached to Circular 06. Accordingly,
(i) cash and gold or equivalent shall be classified as 0%, (ii) debt recoverable from other
credit institutions or equivalent, claims on non-OECD governments and financial institutions
shall be classified as 20%; (iii) receivables wholly secured with immovable assets, land use
rights shall be classified as 50%; (iv) paid-up charter capital in subsidiary companies and
affiliates shall be classified as 100 %; (v) receivables of subsidiary companies and affiliates,
and loans granted to finance securities sectors shall be classified as 150%; and (vi) loans
made for investment in real estate shall be classified as 200%18
.
• Among the assets with 0% risk weight level, the receivables from or guaranteed by
“international financial institutions” and receivables secured with valuable papers issued by or
guaranteed by “international financial institutions.” Circular 36 provides a detailed list of
15
Article 9 of Circular 36
16
Article 6 of Circular 41
17
Article 23 of Circular 41
18
Appendix 2 of Circular 06
6

7. entities defined as “international financial institutions,” such as the IFC, the IDA (under the
World Bank), the ADB, the EIB, the European Investment Fund and the Council of Europe
Development Bank, etc19
.
3. Risk Provisioning and Debt Classification
• The regulations on risk provisioning and debt classification are currently stipulated in Circular
02/2013/TT-NHNN (“Circular 02”) (which was then amended by Circular 09/2014/TT-NHNN
(“Circular 09”)).
• Accordingly, all commercial banks in Vietnam to set up the internal regulations on risk
provisioning for the following assets (debts)20
:
(i) Lending (loans)
(ii) Financial leases
(iii) Discounting and rediscounting negotiable instruments and other valuable papers;
(iv) Debt factoring;
(v) Credit extended via credit cards;
(vi) Items paid pursuant to off-balance sheet commitments;
(vii) Investments in unlisted corporate bonds (including through arrangements)
(viii) Entrusted extension of credit;
(ix) Monetary deposits (excluding current deposits) at domestic credit institutions, foreign
banks’ branches operating in Vietnam and at foreign credit institutions.
• In relation to the debt classifications, the banks are required to use both qualitative and
quantitative standards for debt classification and must provide the results of assets
classification to the Credit Information Center (CIC-under the SBV) at least once each
quarter. In case there is discrepancy between the two methods, the debts need to be
classified into the group with higher risk21
.
Debt
Classifications
Quantitative Standards Qualitative Standards
Group 1
(Standard
debts)
- Undue debts which, according
to the Bank’s assessment,
could be fully recovered, both
principal and interest, when
they fall due;
- Debts which are overdue for
less than 10 days and
according to the Bank’s
assessment, both overdue
principal and interest could be
fully recovered in accordance
with the remaining repayment
schedule
- Debts which credit institutions,
foreign banks’ branches
assess that there is capability
to recover fully and timely both
of principals and interests.
- Off balance sheet (“OBS”)
commitments which are
assessed by credit institutions,
foreign banks’ branches that
customers have capability to
implement fully obligations
under commitments
Group 2
(Special
- Debts which are overdue from - Debts which are assessed that
19
Article 3.9 of Circular 36
20
Article 1 of Circular 02
21
Articles 9, 10, 11 of Circular 02 (amended by Circular 09)
7

8. mentioned
debts)
10 days to 90 days;
- First-time rescheduled debts
which, according to the Bank’s
assessment, both principal and
interest could be fully recovered
within the rescheduled term.
there is capability to recover
fully both of principals and
interests but there are signs
showing that customers are
declined capability to pay
debts.
- OBS commitments which are
assessed by credit institutions,
foreign banks’ branches that
customers have capability to
implement obligations under
commitments but there are
signs of declining capability to
implement commitments.
Group 3
(Sub-standard
debts)
- Debts which are overdue from
91 days to 180 days;
- First-time restructured debts,
except for first time rescheduled
debts which are classified in
Group 2;
- Debts of which interest was
waived or reduced because
customer was not able to fully
repay interest in accordance
with the repayment schedule;
-Debts which are recovered
under inspection conclusions;
….
- Debts which are assessed that
it is not recoverable both of
principals and interests to due
date. These debts are
assessed to be potential
losses.
- OBS commitments which are
assessed that customers have
no capability to implement fully
obligations under
commitments.
Group 4
(Doubtful
debts)
- Debts which are overdue from
181 days to 360 days;
- First-time restructured debts
which are overdue for less than
90 days within the restructured
term;
- Second-time restructured debts;
-Debts which must be
recovered under inspection
conclusions but fail to be repaid
although recovery term was
overdue for less than 60 days;
…..
- Debts which are assessed to
be high-potential losses.
- OBS commitments which
capability of commitments not
to be implemented by
customers are very high.
Group 5
(Bad debts)
- Debts which are overdue for
more than 360 days;
- First-time restructured debts
which are overdue for more
than 90 days within the
restructured term;
- Debts which are assessed as
irrecoverable and lost.
- OBS commitments which
customers have no capability
to implement committed
obligations.
8

9. - Second-time restructured debts
which are overdue within the
second-time restructured term;
- Debts which are restructured for
the third times or more;
- Frozen debts and debts which
are awaiting resolution;
- Debts which must be recovered
under inspection conclusions
but fail to be repaid although
recovery term was overdue for
more than 60 days; …
• The banks are also required to build Internal Credit Rating system to assess clients based on
qualitative and quantitative standards, business performance, corporate governance. Internal
Credit Rating system needs to be updated on annual basis22
.
4. Solvency Ratio
• The liquidity ratio of a bank is the ratio of its total liquid assets to its total liabilities. A bank
must maintain its continuing liquidity ratio of 10%. Under Article 1.10 of Circular 06, the
formula for calculating the liquidity ratio is as follows:
Liquid ratio (%) =
Highly liquid assets
x 100%
Total Liability
• In addition, the bank is also required to maintain its solvency ratio for a period of 30 days at
50% with respect to VND currency and at 10% with respect to foreign currency. Under Article
1.12 of Circular 06, the formula calculating the solvency ratio is as follows
30-day solvency ratio (%)
Highly liquid assets
x 100%
Net cash outflow within 30 successive days
5. Loan Over Deposit Ratio (LDR)
• LDR is s a ratio between the total loans and total deposits of a bank. According to Article 21
of Circular 36, the total loans of the bank shall include the outstanding loan balance for
individuals and organizations, amounts entrusted to other credit institutions and exclude the
loans extended to other credit institutions, loans from sources entrusted by the Government,
loans sources from overseas credit institutions. Meanwhile, the total deposits of the bank
shall comprise the deposits of individuals and organizations, excluding the deposits of all
types of State Treasury and escrowed deposits.
• A bank must maintain the LDR at 80%23
.
6. Medium and Long Term Loan Financed by Short Term Funding Ratio
22
Articles 5, 11.5 of Circular 02
23
Article 21.5 of Circular 36
9

10. • Under Circular 06, the permitted ratio of short-term funds used for medium-long term
financing is set at 50% maximum until Dec 31, 2017. From Jan 01 2018, this ratio shall be set
at 40% maximum24
. The definitions of short-term, medium-term and long-term loan are as
follows25
:
(i) Short-term loans mean the loans have maturity period of 01 year maximum
(ii) Medium-term loans mean the loans have maturity period of more than 01 year up to
05 years
(iii) Medium-term loans mean the loans have maturity period of more than 05 years
• A bank is allowed to use maximum 35% of its short-term funds (in the most-recent month) to
invest in government bonds26
.
IV. CREDIT LIMITATIONS
1. Lending Limits
• The total outstanding credit exposure of a bank for a single client must not exceed 15% of its
equity27
. Under Article 4.14 and Article 128 of the LCI, the “credit exposure” shall include
loans, discounting, finance leasing, factoring or bank guarantees, investment in bonds issued
by a client and other forms of extension of credit.
• The aggregate amount of credit exposure to a group of related clients must not exceed 25%
of a bank’s equity28
• In exceptional cases where the syndicated loans are not available and based on the socio-
economic requirements, the Prime Minister can allow the bank to raise the aggregate amount
of credit exposure for both of the above single borrower and related borrowers up to 400% of
its equity29
.
• With respect to the enterprises which a bank holds the right to control30
, the bank must
comply with the following restrictions31
:
(i) The total outstanding credit exposure of the bank for an enterprise which the bank
has the right to control must not exceed 10% of the bank’s equity.
(ii) The aggregate amount of credit exposure of the bank for all enterprises which the
bank has the right to control must not exceed 20% of the bank’s equity.
2. Lending Restrictions
• A bank must not provide credit exposure to the following organizations and individuals (as
defined in Article 126 of the Law on Credit Institutions) (“Related Persons”)32
:
24
Article 17.5 of Circular 36, amended by Article 1.17 of Circular 06
25
Article 10, Circular 39/2016/TT-NHNN
26
Article 17.6 of Circular 36, amended by Article 1.18 of Circular 06
27
Article 128.1 of the LCI
28
Article 128.1 of the LCI
29
Article 128.8 of the LCI
30
Including subsidiaries, affiliates or company controlled by the bank
31
Article 127.3, 127.4 of the LCI
32
Article 11 of Circular 36
10

11. (i) Members of the Board of Directors (“BOD”), Members’ Council (“MC”), Inspection
Committee ; the General Director (“GD”), Deputy GD and holders of equivalent posts
in the bank; legal entities being shareholders whose capital share representatives are
members of the BOD or Inspection Committee of the bank, for bank being joint-stock
companies, or legal entities being capital contributors or owners of the bank, for bank
being limited liability companies;
(ii) Parents, spouses and children of members of the BOD, MC or Inspection
Committee , the GD, Deputy GD and holders of equivalent posts;
• A bank must not provide credit exposure to any borrowers who invest and/or trade unlisted
corporate bonds33
• A bank must not provide credit exposure for or entrust its subsidiaries or affiliates for
investment and trading in shares34
.
• A bank must not provide credit exposure to its customers for investment and trading in the
shares of such bank, except for the case of a State-owned commercial bank lending to its
own employees to subscribe for shares issued for the first time upon conversion of such State
owned commercial bank into a shareholding commercial bank.35
• The aggregate credit exposure to its customers for investment and trading in shares must not
exceed 5% of a bank’s charter capital. Commercial banks are only entitled to extend credits
in the form of lending and discounting valuable papers to customers for investment and
trading in shares if they are able to meet the following requirements36
:
(i) ensuring the limits and other prudential ratios regulated in Circular 36;
(ii) having non-performing loan (NPL) ratio below 3%;
(iii) all regulations pertaining to risk management must be strictly observed and
provisions for risks that may happen must be set up in accordance with laws;
(iv) clients are not Related Persons (as defined in Article 126 of the Law on Credit
Institutions); and
(v) customers and their Related Persons are not classified as the entities regulated in
Article 12.1 of Circular 3637
V. EQUITY INVESTMENT
33
Article 11.2 of Circular 36 (amended by Article 1.4 of Circular 06)
34
Article 14.4 of Circular 36 (amended Article 1.8 of Circular 06)
35
Article 14.6 of Circular 36 (amended Article 1.4 of Circular 06)
36
Article 14 of Circular 36
37
Article 12.1 of Circular 36 stipulates that, credit institutions and foreign bank branches must npt extend unsecured credit or
extend credit on preferential conditions to the following entities:
(i) Auditing organizations (comprising auditing organizations and branches of foreign auditing organizations in Vietnam)
or auditors (comprising auditors of auditing organizations and of the State Auditor) currently auditing at credit
institutions or foreign bank branches9; and inspectors currently inspecting at credit institutions or foreign bank
branches;
(ii) Chief accountants of credit institutions and foreign bank branches;
(iii) Major shareholders and founding shareholders of credit institutions and foreign bank branches;
(iv) An enterprise with one of the entities prescribed in Article 126.1 of the LCI owning over 10% of the charter capital of
such enterprise;
(v) Persons evaluating or approving credit extension;
(vi) Subsidiaries and affiliates of credit institutions or enterprises under the control of such credit institutions.
11

12. 1. Conditions
• Under Article 129 of the LCI, a bank shall be allowed to engage in the equity investment38
with the following conditions:
(i) The equity investment of a bank and its subsidiaries and affiliates must not exceed
11% of the total charter capital of the enterprise receiving such equity investment39
.
(ii) The total investment made by a bank and its subsidiaries and affiliates must not
exceed 40% of its own charter capital and its reserve fund40
.
(iii) A bank shall not be permitted to contribute capital or purchase shares in any
enterprise or other credit institution which is a shareholder or capital contributing
member of the bank41
.
2. Investment in Specific Areas
• Under the LCI, a bank must establish or acquire subsidiaries or associated companies if it
wishes to carry out the underwriting of securities issues, securities brokerage, management
and distribution of securities investment fund certificates, securities portfolio management
and sale or purchase of shares, finance leasing and insurance42
. The bank may not exercise
these activities directly.
• In case of purchasing corporate bonds, a bank must not use loans from other credit
institutions to purchase corporate bonds. The bank may repurchase corporate bonds owned
by other organizations and individuals; provided that, such bonds must not be subject to any
disputes or used as security for other obligations, and have not reached maturity date43
.
VI. FOREIGN OWNERSHIP IN VIETNAMESE BANKS
• Currently, under Decree 01/2014/ND-CP (“Decree 01”), the total aggregate shareholding of
foreign investors in a Vietnamese bank shall exceed 30% of its ‘charter capital44
. The
shareholding of any single foreign investor and its affiliated persons must not exceed 20% of
the charter capital of a Vietnamese bank.
• The ownership limits applicable to each type of foreign investor have been aligned with Article
55 of the LCI, which sets out ownership limits applicable to categories of investors, including
Vietnamese investors as follows:
(i) individual investors: 5%;
(ii) organizational investors: 15%; and
(iii) strategic investors: 20%.
In case of necessity for restructuring a “weak” credit institution, the Prime Minister can further
decide other limits of foreign ownership in a Vietnamese bank.
38
Including share purchase and capital contribution
39
Article 129.1 of the LCI
40
Article 129.2 of the LCI
41
Article 129.5 of the LCI
42
Article 103.2 of the LCI
43
Article 5 of Circular 22
44
Article 7.5 of Decree 01
12

13. • The lock-up periods applicable to a foreign investor holding significant stakes in a
Vietnamese bank shall be 03 years if they own at least 10 per cent of charter capital of the
bank, or 05 years in the case of a foreign strategic investor45
.
45
Article 14 of Decree 01
13