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this model for electronic transactions, particularly those with high value or risk. However,
implementation still faces limitations, such as fragmented data systems, inadequate technological
capacity, and the lack of appropriate digital audit frameworks. This article analyzes the theoretical
foundations of risk-tiered control, synthesizes exemplary international practices, and assesses the
applicability of the model in the Vietnamese context. Based on this analysis, it proposes solutions to
improve the internal risk governance systems in digital banking, aligned with Vietnam’s digital
infrastructure, legal framework, and national digital economy development strategy.

Keywords: Digital transformation; digital banking; risk governance; risk-tiered control;
automated auditing.

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