Medium Risk · Caution Advised
Vietnam Expat Housing Network
Active Scam Pattern
Online Job & Freelance Scams Targeting HCMC Expats

Online Job & Freelance Scams Targeting HCMC Expats

2026 expat alert on online employment fraud in HCMC: fake ESL teaching contracts, Telegram task scams, crypto deposits, and A05 reporting steps.

Incident Mechanism Overview

2026 expat alert on online employment fraud in HCMC: fake ESL teaching contracts, Telegram task scams, crypto deposits, and A05 reporting steps.

Quick Takeaway

Key Summary & Expat Answer

Online job scams in Vietnam exploit foreign jobseekers through fake ESL teaching offers, upfront visa processing fee demands ($500–$2,000), and Telegram crypto task fraud. Legitimate employers sponsor Work Permits directly and never charge recruitment fees. Never send funds or un-watermarked passport scans to unverified online recruiters.

With the rapid influx of foreign digital nomads, freelance creatives, and international educators into Ho Chi Minh City, Hanoi, and Da Nang, cybercrime syndicates have engineered sophisticated online employment scams. Operating across LinkedIn, Facebook Expat Groups, Telegram, and WhatsApp, these fraudulent schemes target foreigners seeking remote work, English teaching contracts, or part-time freelance income.

These scams result not only in direct financial losses ranging from $500 to $10,000 USD, but also expose victims to severe passport identity theft, money-mule implication, and immigration blacklisting under Vietnamese labor laws.

                    ONLINE EMPLOYMENT SCAM ATTACK CHAIN
                                     │
       ┌─────────────────────────────┼─────────────────────────────┐
       ▼                             ▼                             ▼
┌──────────────┐              ┌──────────────┐              ┌──────────────┐
│ FAKE JOB AD  │              │ PASSPORT &   │              │ FEE EXTORTION│
│ High salary, │ ───────────► │ DATA THEFT   │ ───────────► │ Demands $500 │
│ remote/ESL   │              │ Harvests ID  │              │ "visa bond"  │
│ on Facebook  │              │ without mark │              │ via crypto   │
└──────────────┘              └──────────────┘              └──────────────┘

1. Taxonomy of Expat Employment & Freelance Scams in Vietnam

Quick Answer: The four dominant employment scam vectors targeting expatriates are fraudulent international school contracts, Telegram affiliate task fraud, ghost recruiter identity theft, and high-yield crypto investment traps. Each relies on deceptive urgency, unverified webmail addresses, and illegal demands for upfront candidate deposits.

Cybercriminals deploy four primary modalities against expatriates in Vietnam:

Scam Vector & Modus OperandiPlatform of Initial ContactFinancial Exploitation TechniquePrimary Indicators of Compromise (IOC)
Fake International School / ESL ContractFacebook Expat Groups / Cold EmailDemands $400–$1,800 “Work Permit deposit” or “Legalization bond” via personal bank account.Recruiter uses free Gmail address (e.g., bis.recruitment.vn@gmail.com); no verifiable office address.
Telegram Affiliate Task ScamWhatsApp / Zalo unsolicited messagesPays small 50k VND test rewards, then requires millions in “VIP task capital top-ups.”Automated bot instructions; demands deposit transfers to individual Vietcombank/MB Bank accounts.
Ghost Remote Recruiter Identity TheftLinkedIn / Remote job portalsCollects full un-watermarked passport scans, criminal records, and bank statements for fake hiring.Job offered after automated text chat without a video interview with corporate HR.
Cryptocurrency Arbitrage / Pig ButcheringTinder / Bumble / Expat MeetupsRomantic or networking approach leading to a fraudulent high-yield staking platform.Unregistered crypto exchange URL; funds cannot be withdrawn without paying 20% “tax fee.”
"
Under Vietnamese labor law (Decree 152/2020/ND-CP and Decree 70/2023/ND-CP), legitimate language centers, international schools, and tech firms bear the full statutory cost of sponsoring your Work Permit. If an entity asks you to pay for your own Work Permit approval letter via a personal bank account, you are 100% communicating with a scammer.
Vu Minh Tuan
Vu Minh Tuan
Cybersecurity & Fraud Intelligence Analyst, LeaseInVietnam

Vector A: The Counterfeit ESL Teaching Contract Deception

English language teaching remains one of the largest expatriate employment sectors in Vietnam. Criminal networks exploit this demand by creating counterfeit websites and social media pages mirroring prestigious educational brands such as VUS, ILA, Apollo, British Council, or elite international schools like the British International School (BIS) and Saigon South International School (SSIS).

The victim is presented with a convincing PDF contract promising:

  • Tax-free monthly salaries of $2,500 to $4,500 USD;
  • Free luxury condominium housing in Thao Dien or Phu My Hung;
  • Annual return business-class flights;
  • Comprehensive health insurance and relocation stipends.

Once the contract is digitally signed, the “HR Director” claims that under Vietnamese immigration rules, foreign candidates must wire a “Statutory Work Permit Guarantee Bond” ($800 to $1,800 USD) or an “Apostille & Translation Expedited Processing Fee” to a personal bank account held by an “authorized immigration attorney.” In reality, no application is ever lodged with the Ministry of Labor, Invalids and Social Affairs (MOLISA), and the funds vanish immediately upon transfer.

Vector B: The E-Commerce Optimization & Task Fraud Funnel

Targeting remote freelancers and digital nomads, this vector initiates with an unsolicited WhatsApp or Telegram message from an alleged recruitment agent representing major digital marketing firms or e-commerce marketplaces (Tiki, Shopee, Lazada, Amazon).

The operational model unfolds in three distinct psychological phases:

  1. The Hook (Small Reward): The candidate is assigned simple tasks, such as subscribing to YouTube channels, liking TikTok clips, or writing 5-star Google Map reviews for local businesses in District 1 or Da Nang. Upon completion of 5 tasks, the scammer transfers 50,000 to 200,000 VND directly to the victim’s local bank account via NAPAS 247 fast transfer.
  2. The Escalation (Capital Deployment): The victim is invited into a VIP Telegram channel where participants (mostly bot accounts and syndicate accomplices) post screenshots of massive returns. To qualify for higher tier tasks, the user must deposit “working capital” into an online dashboard (e.g., 5,000,000 to 30,000,000 VND).
  3. The Rug-Pull (Frozen Funds & Tax Extortion): The dashboard displays a simulated profit balance of 30% to 50%. However, when the user requests a withdrawal, the system locks the account, citing “syntax errors,” “system upgrades,” or “mandatory 20% personal income tax withholding.” The victim is instructed to deposit additional funds to release the balance until they realize they have been defrauded.

Vector C: Ghost Recruiter KYC & Data Harvesting

In this scheme, cybercrime rings establish fictitious recruitment entities on LinkedIn, posing as boutique executive search firms hiring for multinational tech subsidiaries in District 1 or Thu Duc City.

The primary objective is not immediate financial extortion, but harvesting high-fidelity identity packages:

  • High-resolution, un-watermarked scans of foreign passports;
  • Certified university diplomas and TEFL/CELTA certificates;
  • Criminal background checks issued by home-country police agencies (FBI checks, ACRO, RCMP);
  • Recent personal bank account statements showing financial solvency.

These credentials are sold on underground darknet markets to bypass Know-Your-Customer (KYC) identity verification on digital banks, foreign exchange brokers, and unregulated cryptocurrency platforms.

Vector D: The High-Yield Crypto Staking (“Sha Zhu Pan”) Trap

Syndicates operate long-horizon social engineering operations targeting foreign professionals residing in expat hubs. Operatives initiate contact through dating apps (Bumble, Tinder) or professional networking groups (InterNations, Saigon Tech Meetup). Over several weeks of rapport building, the operative casually introduces their secondary income stream: an “insider arbitrage bot” or “liquidity mining pool” hosted on a decentralized application (DApp).

The victim is guided to transfer USDT or USDC from a licensed exchange into a fake decentralized wallet. The platform displays compounding fictitious profits. When the expatriate attempts to liquidate their capital, the smart contract executes a drain transaction, or customer support demands a 25% “anti-money laundering compliance deposit” before release.


2. Legitimate Employer Work Permit Sponsorship vs. Fraudulent Recruitment Schemes

Quick Answer: Under the 2019 Labor Code, employers are strictly responsible for all foreign labor approval and work permit filing fees. Real corporate recruiters utilize enterprise email domains, conduct multi-stage video panels, and require in-country biometric health checks—never demanding upfront wire transfers or crypto deposits.

Understanding statutory employment compliance under Decree 152/2020/ND-CP and Decree 70/2023/ND-CP helps distinguish real corporate job offers from criminal operations:

Recruitment AttributeLegitimate Vietnamese EnterpriseFraudulent Recruitment Syndicate
Work Permit & Visa ProcessingCompany HR files Foreign Labor Approval (Giải trình nhu cầu sử dụng LĐNN) directly with Department of Labor (DOLISA).Demands candidate wire money for “Guaranteed Fast-Track Visa Approval.”
Interview & Vetting ProcessMultiple video/in-person panel interviews with verified corporate executives.Immediate job offer after minimal Telegram/WhatsApp messaging without technical screening.
Corporate Email & IdentityCorporate domain email (e.g., hr@vietnamworks.com, careers@rmit.edu.vn).Free generic domains (@gmail.com, @outlook.com, @zalo.me, @proton.me).
Employment Contract DetailsStandard bilingual contract compliant with 2019 Labor Code specifying gross/net salary, social insurance, and tax withholding.Generic one-page English PDF with fake Ministry of Foreign Affairs stamp or distorted national emblem.
Fee Demands on CandidateZero VND. All official state fees and labor approval costs are legally paid by the employing entity.Requests $300 to $2,500 for “document legalization,” “security deposits,” or “training materials.”
Payment Receiving EntityCorporate bank account matching the registered legal enterprise name on tax license.Personal individual bank accounts or USDT/crypto wallets.

Explore legal working standards in Digital Nomad Working Legally in Vietnam 2026 and Work Permit & TRC Complete Guide 2026.

Statutory Responsibilities Under Decree 70/2023/ND-CP

Decree 70/2023/ND-CP, which amended key provisions of Decree 152/2020/ND-CP, introduced stringent guidelines governing the employment of foreign nationals in Vietnam:

  • Pre-Approval Job Posting: At least 15 days prior to recruiting a foreign national, employers must publicly announce the job opening to Vietnamese jobseekers on the portal of the Ministry of Labor or the local Employment Service Center;
  • Corporate Legal Standing: The sponsoring business must possess a valid Enterprise Registration Certificate (ERC), an Investment Registration Certificate (IRC) where applicable, and demonstrate that the position requires specialized expertise (Expert, Executive Director, General Director, or Technical Worker);
  • Zero Candidate Surcharges: Article 12 explicitly bars agencies or employers from deducting or demanding administrative fees from foreign laborers for statutory labor approval procedures;
  • Health Certification Protocol: Foreign workers must undergo an official in-person medical examination at an authorized Vietnamese hospital (such as Cho Ray, FV Hospital, or Bach Mai) to receive a valid health certificate (Giấy khám sức khỏe)—it cannot be completed online.

3. Passport Watermarking & Identity Theft Defense Protocols

Quick Answer: Sending un-watermarked passport scans enables cybercrime syndicates to pass automated KYC checks, open fraudulent bank accounts, and register illicit SIM cards. Protect your identity by overlaying a diagonal semi-transparent watermark specifying the employer’s name, purpose, and date.

Never send clean, unedited passport scans to prospective employers or online recruiters. Fraudsters harvest stolen passport images to open fraudulent digital bank accounts and register illegal SIM cards across Vietnam, which are subsequently utilized in money laundering and telecommunications extortion.

                    PASSPORT WATERMARKING SECURITY PROTOCOL
                                       │
        ┌──────────────────────────────┴──────────────────────────────┐
        ▼                                                             ▼
┌───────────────────────────────┐                   ┌───────────────────────────────┐
│   SAMPLE WATERMARK TEXT       │                   │    PLACEMENT TECHNIQUE        │
│                               │                   │                               │
│ "FOR EMPLOYMENT APPLICATION   │                   │ • Overlay semi-transparent    │
│  AT [COMPANY NAME] ONLY       │ ────────────────► │   text diagonally across      │
│  DATE: 04-SEP-2026            │                   │   the photo and MRZ lines     │
│  NOT VALID FOR BANKING OR SIM"│                   │ • Obstructs automated OCR     │
└───────────────────────────────┘                   └───────────────────────────────┘

Essential Steps for Securing Identification Scans:

  1. Overlay a Semi-Transparent Diagonal Watermark: Cover the passport photo and Machine-Readable Zone (MRZ) with: “FOR APPLICATION PURPOSES ONLY AT [EXACT COMPANY NAME] - NOT VALID FOR BANK ACCOUNT OR SIM REGISTRATION - DATE: DD/MM/YYYY.”
  2. Never Send Full High-Resolution 600 DPI PDFs: A watermarked 150 DPI image is fully sufficient for initial HR qualification review, while preventing cybercriminals from passing automated banking eKYC scans.
  3. Redact Sensitive Biometric Data: If a recruiter requests initial verification, obscure your national identification number, secondary signature strip, and parents’ details if displayed.
  4. Demand Video Call Verification Before Document Submission: Never release credentials until you have conducted a face-to-face video interview with hiring managers whose professional backgrounds have been cross-verified on LinkedIn and corporate staff directories.
  5. Inspect Digital File Metadata: Ensure the documents shared by recruiters originate from corporate authoring tools rather than desktop graphic suites like Photoshop or Canva.

4. Personal Data Protection Decree 13/2023/ND-CP Compliance

Quick Answer: Vietnam’s Personal Data Protection Decree (Decree 13/2023/ND-CP) grants expats strict legal rights over their personal data. Legitimate employers must provide clear data processing consent agreements and maintain registered Data Protection Officers.

Vietnam’s comprehensive data privacy legislation, Decree 13/2023/ND-CP, established strict obligations regarding the processing, collection, and storage of personal information:

  • Explicit Consent Requirement: Employers and recruiters must obtain explicit, affirmative consent before gathering personal data, including passport scans, academic transcripts, biometric photos, and medical records;
  • Purpose Limitation: Information collected for recruitment cannot be transferred to third-party marketing firms, financial brokers, or unregulated sub-contractors without separate written authorization;
  • Right to Revocation & Erasure: Expatriate applicants have the statutory right to request the complete deletion of their uploaded resumes, identity documents, and correspondence if the application is rejected or withdrawn;
  • Penalties for Illegal Trading: Disclosing or selling candidate personal data is subject to administrative fines up to 5% of corporate revenue, alongside criminal prosecution under Article 288 of the Vietnamese Penal Code.

When dealing with reputable recruitment consultancies (such as Robert Walters Vietnam, Adecco, or Navigos Group), candidates receive formal GDPR and Decree 13 compliant data consent disclosures prior to submitting application dossiers.


5. Emergency Incident Response: Recovering from Employment Fraud

Quick Answer: If defrauded, act within 30 minutes to request an emergency interbank recall through NAPAS 247, compile digital evidence, lodge a complaint with A05 Cyber Police, report to your local ward police station, and notify your consular office.

If you have fallen victim to an employment or task scam in Vietnam, executing rapid emergency procedures significantly improves recovery odds and shields you from legal liability:

Incident PhaseImmediate Tactical Action RequiredResponsible Agency / ContactTarget Timeframe
Phase 1: Immediate Bank FreezeContact sending bank hotline; request urgent interbank transaction recall under NAPAS 247 anti-fraud protocol.Sending / Receiving Bank HotlineWithin 0 – 30 Minutes
Phase 2: Evidence PreservationSave full Telegram/WhatsApp chat exports with phone numbers, bank transfer receipts, and recruiter email headers.Self / Legal CounselWithin 1 Hour
Phase 3: National Cybercrime FilingFile formal high-tech crime complaint with the Department of Cyber Security & High-Tech Crime Prevention (A05).A05 - Ministry of Public SecurityWithin 24 Hours
Phase 4: Municipal Cyber InvestigationSubmit physical crime dossier (Đơn trình báo tội phạm) to PA05 Ho Chi Minh City Police Department.PA05 HCMC Police (268 Tran Hung Dao, D1)Within 48 Hours
Phase 5: Local Ward Police ReportSubmit physical incident report to local Ward Police (Công an Phường) where transfer occurred to obtain official receipt stamp.Local Ward Police StationWithin 48 Hours
Phase 6: Consular NotificationNotify consular protection services of identity theft risk if unedited passport scans were compromised.Country Embassy / Consulate in HCMCWithin 3 Days

Step-by-Step Reporting with Vietnamese Law Enforcement

Navigating the reporting process with local authorities requires structured documentation:

  1. Compiling the Evidentiary Dossier (Hồ sơ tố giác tội phạm):

    • Printed transaction confirmations displaying transaction ID, sending account number, recipient bank name, recipient account number, beneficiary name, timestamp, and amount;
    • Full unedited chat logs printed with visible phone numbers, Telegram user IDs (not just display names), and complete URLs of phishing dashboards;
    • Certified copy of your passport and current Vietnamese visa or Temporary Residence Card (TRC);
    • Written timeline of events drafted in Vietnamese (or accompanied by a notarized translation).
  2. Engaging the Cybercrime Police (A05 and PA05):

    • For residents in Ho Chi Minh City, reports should be addressed to:
      • Phòng An ninh mạng và phòng, chống tội phạm sử dụng công nghệ cao (PA05) - Công an TP. Hồ Chí Minh
      • Address: 268 Trần Hưng Đạo, Phường Nguyễn Cư Trinh, Quận 1, TP. Hồ Chí Minh
      • Hotline: (028) 3838 7200
  3. Obtaining an Official Reception Notice (Giấy biên nhận đơn):

    • Always request an official receipt slip bearing the receiving officer’s signature and departmental seal. This document is required by consular offices to justify emergency passport replacements and by banks when disputing unauthorized transactions.

6. Corporate Verification: National Business Portal Due Diligence

Quick Answer: Verify any Vietnamese employer before signing agreements by searching the National Business Registration Portal (dangkykinhdoanh.gov.vn) and General Department of Taxation portal (gdt.gov.vn) for tax code status, legal representative, and registered office.

Every legally operating business entity in Vietnam is registered in the centralized national database. Expatriates can verify corporate legitimacy in less than 5 minutes without cost:

                  CORPORATE VERIFICATION DECISION TREE
                                    │
               Enter Company Name or Tax Code on
                   dangkykinhdoanh.gov.vn
                                    │
       ┌────────────────────────────┴────────────────────────────┐
       ▼                                                         ▼
[Record Found: Active Status]                       [No Record / Closed / Suspended]
       │                                                         │
       ├─ Legal Rep matches contract?                            ▼
       ├─ Address matches actual office?                 CRITICAL RED FLAG
       └─ Business scope permits hiring?                 Cease all contact immediately
               │
               ▼
[Inspect General Dept of Taxation (gdt.gov.vn)]
       │
       └─ Confirm tax status: "Đang hoạt động (đã được cấp MST)"

Key Verification Metrics:

  • Legal Status (Tình trạng hoạt động): Must indicate “Đang hoạt động” (Operating normally). If marked “Tạm ngừng kinh doanh” (Temporarily suspended) or “Ngừng hoạt động nhưng chưa hoàn thành thủ tục đóng mã số thuế” (Ceased operations without tax closure), the entity cannot legally sponsor work permits;
  • Legal Representative (Người đại diện theo pháp luật): The signatory on your employment offer letter must match the registered legal representative or hold a formal Power of Attorney (Giấy ủy quyền) executed by that representative;
  • Charter Capital & Head Office: Cross-reference the registered street address with Google Street View and physical visits. Fraud syndicates frequently register shell entities at virtual co-working addresses with nominal charter capital of 10,000,000 VND;
  • Foreign Labor Registration History: Established institutions will have documented records of previous foreign teacher and specialist quota approvals filed with DOLISA.

7. Psychological Tactics & Social Engineering Exploited by Syndicates

Quick Answer: Cybercrime syndicates deploy artificial scarcity, sunk cost traps, authority deception, and isolation tactics to manipulate foreign jobseekers into bypassing standard due diligence checks.

Expatriates living abroad often experience isolated support networks, unfamiliar legal systems, and heightened anxiety regarding visa tenure. Scam syndicates deliberately exploit these vulnerabilities through calculated psychological manipulation:

1. The Manufactured Urgency Vector

Recruiters state that school semesters begin in less than two weeks and the immigration quota will close within 48 hours. By forcing rapid decision-making, victims are discouraged from consulting independent legal advisors, expat forums, or consular hotlines.

2. The Sunk Cost Escalation

In task scams, the victim is initially allowed to withdraw small earnings. When a $500 deposit is locked, the scammer insists that depositing an additional $750 will instantly unlock the full $1,250 plus bonus commissions. Because the victim feels close to recouping their funds, they repeatedly comply, often losing thousands of dollars before breaking the psychological loop.

Counterfeit documents are heavily adorned with official-looking stamps, red ribbons, QR codes that route to fake governmental landing pages, and forged signatures of senior officials from the Ministry of Foreign Affairs (MOFA) or Ministry of Public Security (BCA). To foreign eyes unfamiliar with Vietnamese bureaucratic typography, these graphics convey deceptive authenticity.

4. Group Consensus Simulation in Private Channels

In Telegram task scams, the victim is placed into a “Special VIP Operations Team” with 10 to 20 members. These accounts actively post celebratory messages, bank deposit SMS screenshots, and photos of luxury goods purchased with their task earnings. In reality, all other channel members are controlled by a single operator using multi-login bot clients.


8. Expat Jobseeker Due Diligence Checklist

Quick Answer: Never commit to a job offer or send personal documents without verifying the employer’s national tax code, confirming corporate email domains, applying security watermarks to passport scans, and ensuring zero candidate fee obligations.

Before accepting any employment offer or submitting documents in Vietnam:

  • Verified Corporate Existence: Inspected company tax code on the National Business Registration Portal (dangkykinhdoanh.gov.vn).
  • Confirmed Email Domain Authenticity: Recruiter communicates via registered corporate enterprise email (e.g., recruitment@internationalschool.edu.vn), not free webmail (@gmail.com, @yahoo.com, @zalo.me).
  • Conducted Video Screening: Completed live video interviews with senior administrative leadership where faces and corporate offices were clearly visible.
  • Protected Biometric Identification: Applied mandatory semi-transparent security watermarks diagonally across passport photo and MRZ lines prior to transmission.
  • Zero Fee Guarantee: Employer has formally agreed in writing to cover all statutory Work Permit, DOLISA labor explanation, and temporary residence fees without demanding candidate deposits.
  • Vetted Physical Premises: Conducted an in-person or third-party physical inspection of the language center, school campus, or corporate office.
  • Reviewed Rental Housing Provisions: If the employer provides an accommodation stipend, ensure your lease follows legal standards outlined in 10 Lease Contract Clauses to Watch and Pink Book Ownership Check.

Verified Rental Properties & Managed Residences

Expatriate professionals, digital nomads, and educators establishing verified, safe residences in Ho Chi Minh City can explore our managed and vetted housing portfolio:


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Frequently Asked Questions

No, under Vietnamese labor legislation (Decree 152/2020/ND-CP and Decree 70/2023/ND-CP), the employer is legally obligated to sponsor and pay the administrative costs associated with Foreign Labor Approval and Work Permit issuance. Any recruiter demanding upfront visa processing deposits or security bonds is running a fraud scheme.

What is the Telegram daily task scam targeting remote freelancers in Vietnam?

Scammers pose as international marketing agencies on LinkedIn, WhatsApp, or Facebook offering high daily payouts (500,000 to 2,000,000 VND) for liking YouTube videos or reviewing hotels. After small initial payouts to build trust, victims are coerced into depositing millions of VND into a fake crypto platform to unlock higher commissions, after which all funds are stolen.

What should an expat do if scammers possess an unedited photocopy of their passport?

Immediately notify your embassy or consulate in HCMC or Hanoi, report the potential identity theft, and monitor your personal credit. In Vietnam, submit an administrative fraud report to the Department of Cyber Security and High-Tech Crime Prevention (A05) to document that your identity may be misused for money-mule accounts or fraudulent SIM cards.

Can foreign digital nomads work legally for overseas clients while living in Vietnam?

Yes, working remotely on international contracts paid into foreign bank accounts while residing on valid e-visas or temporary residence cards does not violate local labor sponsorship rules, provided you do not execute local Vietnamese employment contracts or accept un-invoiced domestic corporate transfers.

Where is the physical cybercrime reporting office located in Ho Chi Minh City?

Victims can file reports directly with the Department of Cyber Security and High-Tech Crime Prevention (PA05) under the Ho Chi Minh City Police Department located at 268 Tran Hung Dao Street, Nguyen Cu Trinh Ward, District 1, Ho Chi Minh City.

How does Decision 2345/QD-NHNN affect bank transfers and money recovery in Vietnam?

Decision 2345/QD-NHNN mandates biometric facial authentication matching chip-embedded national ID cards or passports for all online transfers exceeding 10,000,000 VND or cumulative daily transfers over 20,000,000 VND, making money-mule accounts easier to trace by law enforcement.



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