Vietnam - rules and pilots

(Section: "Markets and Jurisdictions")

1) Mode picture

• Casinos and electronic slot machines (EGD) - allowed for foreigners and persons with a residence permit abroad; for Vietnamese nationals, there is a limited pilot clearance in individual IRs when strict conditions are met.
• Online casinos/bets for residents - prohibited (blocking domains/applications and payment curbs).
• Lotteries - public sector (traditional provincial and computerized Vietlott).
• Betting pilots (horse racing/dog racing/international football) - allowed in a strictly project format, after separate approval.

2) Institutions and roles

Ministry of Finance (MoF) - political and fiscal framework, licensing/supervision of casinos and lotteries.
Provincial People's Committees - site approvals and on-the-ground enforcement.
Ministry of Public Safety - Beneficiary/Personnel Review, Enforcement.
State Bank of Vietnam (SBV) - AML/CFT for payments/banks, cashless rules.
Antitrust/advertising authorities - control of marketing and consumer communications.

3) Segments and tolerances

3. 1 Casino and EGD

Main mode: entry for foreigners and non-residents; playing tables and EGDs at licensed IR/hotels.

• age 21 +;
• proof of income (minimum per month, documented);
• lack of family/custody bans;
• entrance fee (daily/monthly subscription);
• absence of convictions/prohibitions through government agencies.
• The pilot is extended based on the results of monitoring the socio-economic effect and RG indicators.

3. 2 Lotteries

Provincial traditional lotteries (paper tickets) and Vietlott (computerized games) are legal channels. Sales are predominantly offline, with age control and licensed points.

3. 3 Bookmaker drivers

The legislation allows for pilot projects for horse racing/dog racing/international football. Each project requires: investment plan, site, IT/cash infrastructure, provincial alignment and MoF.

3. 4 Online Games for Money

Prohibited. Sites/applications are blocked, payment routes are suppressed; criminal and administrative liability for organization and promotion.

4) Licensing and IR requirements

Capital/investment: for IR - significant minimum investment, hospitality and entertainment infrastructure, jobs/tourism report.
Control architecture: cash desks/cages, safes, PIT zones, CCTV, entry control, separate EGD metering circuit.
Reporting: Regular reports to MoF/province on GGR/NGR, attendance, RG incidents, taxes and social effect.

5) Age, entry and behavioral rules

Foreigners/non-residents: passport/ID-check 21 +.
Citizens (by pilot): 21 +, income ≥ the established minimum in months; daily/monthly entry fee; the right of relatives/authorities to declare a ban on visiting; refusal for signs of gambling/debt.
Alcohol/behavior: denial of service for intoxication/aggression; blacklists/self-exclusion.

6) Taxes, fees and accounting (high level)

Gambling tax/fees: rates vary by product (tables/EGD), location and project conditions; license duties and local fees are required.
Corporate taxation: according to the general regime, preferences for large IRs in FEZ/investment zones are possible.
Separate accounting: tables/EGD/F & B/show/hotel; correct reflection of bonuses, jackpots, void/cashout; otchetnost↔billing reconciliation.

7) AML/KYC и Responsible Gambling

KYC/CDD: passport/ID, for citizens - verification of income/local conditions, refusal to get on the exception lists; sanctions/POP screening of suppliers/VIP clients.
Transactional monitoring: large buy-in/cache-outs, fragmentation, device/card connectivity; SoF/SoW by trigger.
STR/CTR: mandatory communications to competent authorities and bank; retention logs/dossiers.
RG tools: entrance fees (for citizens), limits on visits/spending, "cooling," self-exclusion/family bans, hall warnings, staff training.

8) Advertising and Communications

Strictly limited: No "guaranteed win," "no risk," target vulnerable groups/minors

Pilot for citizens: any creatives - without stimulating mass demand; a focus on tourism/entertainment rather than "excitement."

Digital platforms: removal of applications/advertisements of illegal immigrants; banning online casino/bookmaker promotions.

9) IT/Security/Surveillance

CCTV: full coverage of halls/checkouts/cells/PIT; regulatory retention and redundancy.
WORM logs: immutable logs "exchange of chips/loans → bets/wagering → payment → adjustment" with NTP synchronization.
Certification: RNG/EGD, cash and reporting modules, regular inspections.
DR/BCP: target RPO/RTO, exercises; pentests/scans, secret management, RBAC/SoD.
Supervisory access: inspections, test accounts, secure uploads; SLAs for responses to organ requests.

10) Enforcement and block measures

Police raids against underground halls/internet cafes with slot software; withdrawal of equipment; criminal liability of organizers.

Network locks of domains/applications/mirrors;

Payment curbs: closing "pseudo-merchants," monitoring e-wallet/banks, banning anonymous routes.
Sanctions: fines, suspension/cancellation of license, blacklists for visitors, disciplinary measures against staff.

11) Entry roadmap (operator & provider playbook)

A) IR/Casino Operator

1. Investment package: capex, hotel/entertainment, jobs, social effect; alignment with the province and MoF.
2. Admission regime: basic (foreigners/non-residents) + pilot of citizens (if applicable): entrance fee, income requirement, exclusion procedures.
3. Operations/cash desk: table accounting/EGD, computers, chip/credit inventory, PIT audit, reporting.
4. AML/RG: KYC, SoF/SoW, STR/CTR, limits/self-exclusion, RG intervention journal.
5. IT/IS: certifications, WORM logs, CCTV, DR/BCP, API for supervision.
6. Marketing: authorized channels only; refusal of "aggressive" induction; compliance journal.

B) B2B providers (content/EGD/platform/IDV/anti-fraud/IS)

1. Accreditation/certification: RNG/EGD/platforms, safe-SDK, local reporting formats.
2. Contracts: SLA, DPIA, escrow/versions; personnel training.
3. Tools: GGR/NGR showcases, RG/AML signals, anti-collation/anti-bot, retention monitoring.
4. Service: spare parts, calibration, regular site checks.

12) Compliance checklists

Licensing/Perimeter

• Current IR/EGD license; pilot conditions for citizens are spelled out
• Responsible persons: Compliance, AML, RG, IT-Security, Ads
• Reporting and payment calendar; otchetnost↔billing reconciliation <0.5%

AML/KYC & RG

• KYC 21+; income requirement (for citizens, by pilot); sanctions/RAP
• SoF/SoW on triggers; STR/CTR procedures; log/dossier retention
• Limits/" cooling "/self-exclusion; family bans; personnel training

IT/IS

• RNG/EGD/cashier certification; WORM logs; NTP
• CCTV coverage/retention; RBAC/SoD; secret management; pentests/scans
• DR/BCP exercises; protected offloads for supervision

Advertising/PR

• No "guaranteed win "/" no risk"; age disclaimers
• Compliance log (creatives/URL/dates/target); instant recall procedure
• Prohibition of digital promo of illegal immigrants; Remote Materials Report

13) First year KPI

Fiscal: timely filing ≥99%; discrepancy otchetnost↔billing <0.5%

AML/KYC: proportion of valid STRs; mean KYC time; reducing "split" transactions

RG: proportion of guests with active limits; Self-exclusion TTR <1 min

IS/resilience: MTTR incidents; closing high-vulns on time; successful DR tests

Operations: chip/credit shrinkage <0.05%; stable hold on EGD/desks

14) FAQ

Can I launch an online casino in Vietnam?
No, it isn't. Online gambling for residents is prohibited and blocked (network and payments).

Can Vietnamese citizens play casinos?
Yes, only within the pilot and only if the conditions are met (21 +, income, entrance fee, no prohibitions). The basic regime is access for foreigners/non-residents.

Are sports betting acceptable?
Only in pilot format with separate approval, infrastructure and reporting.

How does risk control work?
Through KYC/AML (SoF/SoW, STR/CTR), RG tools, CCTV and WORM logs, inspections and reports to MoF/province.

Note

Tax/fee formulas, IR listings in the pilot, entry fee sizes, and bookmaker pilot designs are reviewed periodically. Before legally significant decisions, update parameters on current regulations/clarifications, provincial conditions and MoF/SBV requirements.