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Vietnam 2025

Information technology

Phuoc Doan

Senior director, legal and corporate affairs | M_Service (MoMo)

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Vietnam 2025

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Phuoc Doan

Senior director, legal and corporate affairs | M_Service (MoMo)

What are the most significant cases, projects, or transactions that you and your legal team have recently been involved in?

In late 2024, MoMo announced its strategic rebranding as an “AI-powered financial supporter for everyone”, positioning itself as an AI-embedded platform that connects banks and financial institutions with SME merchants and end-users. To realise this vision, the legal team had an exceptionally active year advising the business on the launch of digital and AI-driven products for dozens of banking partners.

Our mandate covered compliance advisory throughout product development, drafting of terms and commercial agreements, and negotiation with (the legal teams of) our partner banks. The challenges stemmed not only from the highly innovative nature of our products and services, but also from the diverse risk appetites and business models of our partners. This required us to adopt tailored approaches and produce bespoke contractual frameworks for each engagement.

On the regulatory front, Vietnam has recently enacted multiple landmark laws with profound implications for technology companies, including the Law on Science, Technology and Innovation, the Law on Data, the Law on Protection of Data Privacy, and the Law on the Digital Technology Industry. In the pipeline for adoption later this year are the Law on E-Commerce, the Law on Artificial Intelligence, the Law on Digital Transformation, and the Law on Technology Transfer. As Vietnam’s largest fintech and one of only two tech unicorns in the country, MoMo has played an active advocacy role in shaping a more supportive policy environment for domestic tech startups.

How do you approach managing legal aspects during periods of instability or crisis to ensure the organisation’s resilience?

In times of uncertainty or crisis, a General Counsel must reinvent his role, and may be himself — becoming adaptive, open, and connected. Lawyers are often perceived as rigid or overly technical, but I may not share this view. In fact, these traits can hinder organisational resilience during turbulent periods. An effective General Counsel must closely monitor political and market developments, assess their implications, and proactively anticipate risks before they escalate into real issues. This requires agility, foresight, and decisive pre-emptive actions.

Equally important, the role cannot be carried out in isolation. Uncertaint situations demand active engagement with stakeholders across the spectrum, regulators, senior management, business teams, and fellow colleagues. By fostering dialogue, understanding diverse priorities, and encouraging constructive challenge, a General Counsel ensures that legal advice aligns with the organisation’s strategic objectives while also maintaining balance among competing interests.

In short, resilience is achieved not through rigid legalism, but through collaboration, foresight, and strategic openness.

General counsel often speak of the need to be strategic to reach the pinnacle of the profession. What does being strategic mean to you?

To me, being strategic means identifying the right objectives, setting clear priorities, and selecting the most effective methods to achieve those goals in order of importance. Lawyers are trained to care deeply about detail, but too much focus on detail can obscure the bigger picture and the ultimate purpose of our work.

That is why I regularly ask my team, before beginning any task: “Why are we doing this? What does the business really want to achieve? How can we deliver the expected outcomes in the most effective way”. In short, we need to work smart, not just hard.

The role of a General Counsel must also be fully aligned with the organisation’s broader strategy. Understanding the company’s objectives at every stage, whether growth,

consolidation, innovation, or transformation, allows the legal function to design actions that are not just legally sound, but also strategically impactful.

What strategies do you employ to ensure the successful digital transformation of a legal department while maintaining compliance with your country’s data protection laws?

As a technology company with tens of millions of users, MoMo applies stringent data protection requirements across all operations, not just within the legal department. We view digital transformation not as a one-time achievement but as an ongoing process of continuous improvement and innovation.

To balance transformation with compliance, our strategy involves:

Close regulatory engagement: maintaining an active dialogue with regulators to ensure that each new initiative aligns with evolving legal and data-protection standards.

Cross-functional collaboration: working with our technology and security teams to embed appropriate safeguards and mitigation measures into every digital solution.

Business alignment: engaging clients and partners early to ensure that the digital tools we design are interoperable, practical, and beneficial to stakeholders.

Digital transformation, therefore, is not a one-off project within the legal team. It must be a synchronised, company-wide effort, built on collaboration, compliance, and continuous innovation.

Phuoc Doan - Southeast Asia 2024

Senior director of legal and corporate affairs | MoMo

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Phuoc Doan - Vietnam 2024

Senior director, legal and corporate affairs | M_Service (MoMo)

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Phuoc Doan - Vietnam 2023

Senior director, legal and corporate affairs | M_Service (MoMo e-Wallet)

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