Regulatory Refinements in Kuwait and Vietnam: What Fund Managers Need to Know 

28th November 2025

As global regulators fine-tune their oversight frameworks, the landscape for cross-border fund distribution remains in motion. New rules emerging in Kuwait and Vietnam demonstrate how even incremental adjustments can redefine what “offshore marketing” really means. Each adjustment reinforces the growing complexity of offshore marketing and fund registration obligations, particularly in emerging jurisdictions where frameworks are rapidly developing. 

In November, our Global Knowledge Hub (‘GKH’) received a broad set of updates across a few jurisdictions. As part of our monthly commitment to keeping clients informed, we are highlighting two key developments from Kuwait and Vietnam that reflect especially notable shifts in offshore marketing and private placement rules. These updates form part of a wider series of refinements made throughout the platform, ensuring that fund managers and compliance professionals continue to benefit from clear, timely, and practical regulatory guidance. 

Kuwait – Registration 

Our updated Kuwait content introduces a new regulatory requirement for offshore marketing. Foreign funds seeking to engage in offshore marketing must not demonstrate a link to the Kuwaiti Dinar (KWD) either directly or through the relevant exchange rate of the KWD. 

This development underscores the importance of ensuring that managers intending to undertake offshore marketing do not imply that funds are directed at Kuwaiti investors. Managers planning regional marketing strategies should factor in this requirement when structuring fund documentation and communications for offshore marketing to Kuwait. 

Vietnam – Private Placement 

In Vietnam, the laws on Advertising and Decree No. 135/2015/ND-CP have been recently amended by the Vietnamese Parliament, expanding the definition of “advertising activity” to cover the introduction of products, services, and organisations involved in their production or distribution. 

Our updated GKH content provides detailed guidance on how these changes affect offshore marketing activities and investments into offshore funds by Vietnamese feeder funds. The new interpretation widens the scope of what may constitute marketing, meaning fund managers should review existing materials and engagement practices to ensure compliance with the revised framework. 

Why These Updates Matter 

The introduction of new marketing definitions and currency-linked requirements across jurisdictions like Kuwait and Vietnam reflects a broader regulatory trend: greater scrutiny of offshore fund activity. Staying informed and agile remains crucial for maintaining compliance and sustaining cross-border access. 

The GKH continues to support fund managers through these shifts, delivering expert-curated guidance, practical compliance insights, and jurisdictional comparisons across 80+ markets, all updated in real time and backed by our legal team. 

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Author

Patricia Nitschke

Author

Sina Abel

Author

Rhiannon Farrell