Vietnam needs to address gaming legal framework gaps: Researchers

Nelson Moura

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December 2, 2024

Vietnam needs to address gaming legal framework gaps: Researchers

Vietnam’s casino industry has grown steadily since the 2017 decree that provided a legal framework for its operations, but while the sector has contributed significantly to the national economy, experts argue that gaps in the legal framework could hinder long-term growth and effective management.

The findings were published in a study by Nguyen Thanh Minh Chanh and Vuong Thi Thu Thuy from the Industrial University of Ho Chi Minh City’s Faculty of Law.

Issues include unclear investment registration requirements, ambiguous conditions for obtaining casino licenses, and inconsistent regulations regarding casino operations, which complicate both business investments and regulatory management.

To address these challenges, comprehensive legislation on casino activities is needed, including clear development strategies, planning, and resolutions for conflicts between legal documents. These measures should be implemented cohesively to ensure that the casino sector effectively supports the country’s economic growth.

According to research sent to AGB by the authors, since the decree’s implementation, Vietnam has seen increased revenue and job creation in the casino industry.

From 2017 to 2023, the Ministry of Finance reported nearly VND9 trillion ($370 million) in state budget contributions and the employment of over 10,000 workers. Notably, the Phu Quoc casino alone generated VND2.18 trillion ($88.2 million) in 2023, contributing VND1.23 trillion ($49.7 million) to the state budget.

The organization, operation, facilitation or participation in organized gambling or casino gaming remains illegal in Vietnam, with very specific exceptions, namely the licensed casinos and electronic gaming clubs legally operating across the country.

Vietnam lacks a specific casino or gaming law; instead, its casino operations are governed by a complex framework of laws and executive decrees. The primary regulation is Government Decree 03/2017/ND-CP, effective March 15th, 2017, which outlines that casino gaming must comply with various related laws, decrees, circulars, and guidelines.

_{Corona Resort & Casino, Phu Quoc, Vietnam}

Additionally, several key regulations address foreign investment, casino operations, tax collection, administrative penalties, and foreign exchange management within the industry.

The study authors warn that regulatory challenges remain, since the requirement for Vietnamese citizens to prove a monthly income of VND10 million ($400) to access casinos has drawn criticism for its complexity and lack of feasibility.

On average, every year Vietnamese people take about VND800 million ($31,511) abroad to gamble at casinos, this is not a small number, not to mention the amount of money played at Vietnamese casinos.

So far only the Van Don and Corona Casino projects have been approved for local play, with Van Don reportedly still under construction and only Corona Casino on Phu Quoc Island open to Vietnamese citizens, who are willing to pay the entry fee and satisfy the specific entry requirements, including providing identification and proof of income.

Phu Quoc, Vietnam — _{Phu Quoc Island, Vietnam}

During the COVID-19 pandemic these rules were relaxed at the Corona Casino in Phu Quoc, with local residents permitted to gamble at the establishment as part of a pilot program that ran for three years. This trial period has been extended until December 31st, 2024.

At the same time, electronic gaming clubs – offering electronic gaming to foreign passport holders only – are permitted to operate in 4 and 5-star hotels predominately located in tourist destinations.

For the authors, the VND10 million ($400) requirement poses challenges, as verifying income for entry is impractical and can lead to fraudulent practices.

‘Observers note that simpler systems, such as identification cards issued by authorities, could streamline the process while maintaining oversight. […] Many Vietnamese travelers seeking leisure do not intend to engage in gambling, making the income verification process cumbersome’ the study points out.

‘In contrast, neighboring regions like Cambodia and Singapore have more lenient regulations, prompting many to travel abroad for simpler gaming options. Despite the Phu Quoc casino generating significant local revenue and attracting over 240,000 visitors, the post-COVID-19 tourism recovery remains challenging. To foster growth in this sector, it is suggested that regulations be relaxed.’

Legal and regulatory gaps

The study also highlights inconsistencies in investment regulations, particularly for casino projects in underdeveloped regions.

Current laws require a minimum investment of $2 billion, with 50 percent disbursed before operations begin, a requirement the authors argue does not account for infrastructure development costs in remote areas, potentially deterring investors.

‘There are many large foreign investors who really want to come to Vietnam to build tourism-resort- shopping-casino complexes. However, legal and institutional problems are still a major barrier that makes investors hesitate’ the study addresses.

‘Therefore, perfecting the legal regulations on regulating casino business activities to suit reality and creating strong progress in this business activity in the coming time in Vietnam is necessary’

The study argues that when businesses want to do casino business in areas with economic difficulties, poor infrastructure or a lack of infrastructure, capital spent on improving connection infrastructure could be included in the total investment for the casino project, capped at 25 percent of the total investment.

Additionally, casino owners would be permitted to transfer their capital contributions within the casino complex for a minimum of five years from the issuance of their casino business license.

Moreover, Vietnam’s casinos face heightened scrutiny due to concerns over money laundering.

While the 2022 Law on Prevention and Combat of Money Laundering has enhanced oversight, experts recommend more detailed guidance, robust enforcement, and international cooperation to counter sophisticated laundering schemes.

The most recent evaluation of Vietnam published in 2022 by The Asia/Pacific Group on Money Laundering (APG), the associate body of The Financial Action Task Force (FATF) concluded that AML/CFT supervision in Vietnam is very limited and the supervision that is conducted is not risk-based.

Casinos have also been scrutinized for their social impact, including gambling addiction and illegal activities. The researchers suggest bolstering measures to prevent gambling-related social issues, such as empowering local authorities, community organizations, and law enforcement to monitor and intervene effectively.

‘Promoting Vietnam’s economy to move forward in a positive direction. However, the process of international integration in Vietnam requires specific changes in law for this ‘smokeless’ industry to develop, it is necessary to improve legal regulations on regulating casino business activities to suit reality and create strong progress in this economic activity in the coming time’, the study authors suggest.

The report underscores the need for a cohesive national strategy for casino development, harmonizing legal documents to minimize contradictions and ensure that the industry contributes positively to Vietnam’s socioeconomic development.

In conclusion, the authors consider that Vietnam’s cautious approach to casino legalization has yielded mixed results. While the industry has bolstered economic growth, particularly in tourism, the regulatory framework requires significant refinement.

By addressing these gaps, experts believe Vietnam could unlock the full potential of its casino industry, positioning it as a driver of economic and social progress in the region.

That being said, she praised what has been accomplished since then, noting “We are now recognized as the nation’s strongest gambling regulator. We have really held the industry to account. Since January 2022, we have levied nearly AU$260m in fines. We had 88 disciplinary actions against the industry just last year”.

Speaking of the departure, VGCCC Chair Fran Thorn noted: “Annette’s leadership, drive and laser-like focus were fundamental to transforming the VGCCC following the Crown Royal Commission and, by extension, the state’s gambling industry.”

“Some companies submit applications for dozens of games at once. To ensure efficient processing, businesses are advised to divide applications into manageable batches,” indicated the nation’s Deputy Director of Department of Broadcasting, Television, and Electronic Information (MIC), Nugyen Thi Thanh Huyen.

The new decree goes further for other operations, with over 200 pages and 62 forms in appendix laying out cross-border information sharing, socials, online games, app stors, internet service management and telecom app service.

Social networks and app stores with monthly visits topping 100,000 per month (over a six consecutive month period) will fall under the regulation.

Failure results in fines, blocks and possible bans from operating in the country, while local internet service and telecom providers are mandated to report and maintain compliance on cross-border information exchanges.

The latest changes, set to take effect on January 1st, 2025, will allow mainland Chinese residents with household registrations in Zhuhai to apply for a ‘one-trip-per-week’ visa. This enables them to visit Macau for up to seven days per trip, compared to the previous restriction of one trip every three months.

Additionally, residents holding household registrations or residence permits for Hengqin Island will qualify for multiple-entry visas, allowing unrestricted trips to Macau. However, each stay will still be capped at seven days.

AGB has learned that some border control measures, namely the policy to avoid gaming addiction, will be implemented internally by the Immigration Administration. This means there may still be limits on the number of visits for residents of Zhuhai and Hengqin traveling to Macau. However, normal leisure visits will not be affected.

Goldman Sachs also notes that reports suggest the ‘one-trip-per-week’ visa for Zhuhai residents could later be extended to other cities within the Greater Bay Area, further enhancing connectivity across the region.

Hengqin’s growing role

An important factor in this strategy is the role of Hengqin Island, increasingly recognized by Chinese authorities as a vital component of Macau’s future development. As Macau faces constraints in hotel capacity that could limit the growth of its tourism industry, Hengqin offers an opportunity to alleviate some of these pressures.

Goldman Sachs highlights Hengqin’s potential as a key growth area for both tourism and business development, with the island’s proximity to Macau providing significant synergies.

In a separate note, Bank of America cites Billy Song, President of the Macau Responsible Gaming Association (MGRA), as emphasizing the importance of improving the business environment for small and medium-sized enterprises (SMEs) and enhancing living standards for residents under Macau’s new Chief Executive Sam Hou Fai.

Billy Song, Macau junkets: 75 percent still inactive under new operation model — _{Billy Song, president of the Macau Responsible Gaming Association}

Song also predicts that the administration will focus on initiatives to strengthen Macau’s integration with Hengqin, aiming to boost visitor numbers to the neighboring region.

According to Song, gaming operators are likely to face increased expectations from the Macau government. Specifically, the government may urge them to:

Increase investment in Hengqin to support regional development
Participate more actively in community activities rather than merely acting as financial investors
Strengthen partnerships with SMEs to foster economic collaboration

Song expects that further clarity on the administration’s policies will be provided in March, when the new Chief Executive is scheduled to deliver his first annual Policy Address.

Bank of America notes Song’s observations on the limited effectiveness of gaming operators’ non-gaming investments in driving Macau’s economic diversification. While high-profile events like concerts and sports tournaments have clear benefits, other initiatives—particularly in sectors like science, healthcare, and urban revitalization—have seen less tangible impacts.

Song suggests that the government could improve transparency in evaluating non-gaming contributions. Clearer criteria could help operators align their investments with government priorities and provide the public with a better understanding of their progress in meeting diversification commitments.

Following meetings with gaming operators, Bank of America also observes differing opinions on how Macau can better leverage Hengqin to provide lower-cost hotel accommodations.

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This partnership further strengthens Relax Gaming’s foothold as a leading provider in the UK, having been offering its much-loved online slot content in the region since gaining a casino license in 2014.

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This forecast, which represents around 81 percent of December 2019 levels, reflects an anticipated slowdown in gaming volumes during President Xi Jinping’s visit to Macau for the celebration of the 25th Anniversary of Macau’s Handover to China on December 20th, along with other Mainland Chinese government officials.

Analysts George Choi and Timothy Chau expect that the visit, coupled with public holidays, will lead to a temporary dip in gaming activity as the focus shifts to state-led celebrations. While the holiday season typically brings an increase in tourist arrivals, this year’s high-profile political event is expected to cause a brief disruption in Macau’s usual gaming momentum.

This projection contrasts with that of Macau’s Chief Executive, Ho Iat Seng, who has a more optimistic view of the territory’s overall performance. In his recent policy address, Ho stated that tourist arrivals to Macau could reach 34 million in 2024, marking a significant milestone. He also expressed confidence that Macau’s GGR for 2024 could reach MOP228 billion ($28.35 billion), which implies a potential 5 percent year-on-year increase for December, bringing the GGR to MOP19.4 billion ($2.41 billion).

Macau Visitor Arrivals October 2024 YoY — _{Visitor Arrivals 2024 YoY}

On a separate note, Seaport adopts a more optimistic tone, forecasting a 5.2 percent year-on-year increase in December 2024 GGR, with a 5.9 percent month-on-month rise. However, the month is still expected to be weaker than usual due to Xi Jinping’s visit, which is likely to temporarily reduce gaming activity during that week.

For the fourth quarter, Seaport projects total GGR to reach MOP58.76 billion ($7.35 billion), reflecting an 8.6 percent year-on-year increase and a 5.7 percent quarter-on-quarter rise in MOP terms. While this growth is more modest compared to the 13.9 percent year-on-year increase seen in 3Q24, Seaport remains confident in the continued growth of the gaming industry throughout the next year.

Macau tourism, golden week, October golden week

November GGR

November 2024 GGR came in at MOP18.44 billion ($2.31 billion), marking a 15 percent year-on-year increase and reaching 81 percent of November 2019 levels. This exceeded both Citigroup’s estimate of MOP18 billion ($2.24 billion) and the consensus estimate of MOP18.1 billion ($2.25 billion).

Citigroup notes that the November performance was bolstered by an improved daily run rate, especially in the last two weeks of the month. The final 13 days of November saw a daily GGR run rate of approximately MOP641 million ($79.7 million), about 2 percent higher than the previous week’s run rate of MOP629 million ($78.2 million).

This suggests that, despite some global economic headwinds, Macau’s gaming sector is demonstrating resilience and continues to attract both visitors and players.

Good morning. With a little help from my friends. Macau’s gaming industry could see a gross gaming revenue (GGR) increase of 4% year-on-year, reaching $29.3 billion, according to CLSA. This jump would harness potential consumer-focused fiscal stimulus advanced by China’s central government. Meanwhile, Curacao’s gaming regulator has issued a statement addressing recent corruption allegations surrounding the island’s gaming licensing system and operator BC.GAME. Returning to Macau, the city’s top court has issued a decisive ruling maintaining the 13-year prison sentence handed to Levo Chan, the former junket Tak Chun Group CEO.

What you need to know

CLSA forecasts a 4% year-on-year increase in Macau’s GGR for 2025, with market share growth and fiscal stimulus playing central roles in the outlook.
Curacao’s Gaming Control Board responds to accusations, but questions remain as to how to restore confidence in the jurisdiction.
Macau’s top court sustains 13-year prison sentence handed to Levo Chan, former president of VIP gaming junket Tak Chun.

On the radar

The Star Entertainment has officially appointed Steve McCann as the new CEO.
Macau’s November GGR reaches $2.31 billion, up 14.9% Y-o-Y.
China eases Macau travel for residents of neighboring cities.
DICJ chief appointed as Macau Customs Commissioner in new government.

AGB Intelligence

MACAU

Macau’s GGR is expected to reach $29.3 billion amid strategic shifts

Macau’s gaming industry is projected to achieve “very modest growth” in 2025, with an anticipated gross gaming revenue (GGR) increase of 4% year-on-year, reaching $29.3 billion, according to CLSA. The report highlights the importance of expanding market share amid subdued growth conditions, alongside strong visitor forecasts of 36.4 million for the year. Ongoing measures by China to stabilize the property market will significantly influence Macau’s GGR, with potential consumer-focused fiscal stimulus expected to boost growth.

Corporate Spotlight

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Industry Updates

Studio City launches Christmas experience Winter-Fun Wonderland.
PAGCOR’s caravan delivers essential health services to Ilocos Norte.
Pronet Gaming announces its participation in ICE Barcelona 2025.

MEMBERSHIP | INTELLIGENCE | ASEAN | CAREERS

Ms. Helena de Senna Fernandes, Director of Macao Government Tourism Office (MGTO) of the Macao SAR Government;
Mr. Antonio Leung, Head of Economic Activities Development Department, Division of Macao Government Economic and Technological Development Bureau of the Macao SAR Government;
Ms. Akiko Takahashi, Executive Vice President and Chief of Staff to Chairman and CEO;
Mr. Kevin Benning, Senior Vice President and Property General Manager of Studio City;
Ms. Helen Wu, Senior Vice President and Chief Marketing Officer – Macau Resorts.

Winter-Fun Wonderland offers a wide range of festive delights, from a Dreamland Ice Park fits for guests of all ages, an 8-meter Christmas tree only available for limited-time for the festive celebration to a Snowflake Bridge where delicate real snow fall, bringing to life the magic of the season.

Visitors may also enjoy exploring Studio City’s illuminated Winter Market with all the Christmas vibes you could ask for, and various giant 3D installations including a 5-meter Penguin Snow Mountain and 2.5-meter gingerbread man—perfect winter photo spots that capture the spirit of the holidays.

Studio City unveils first Winter-Fun Wonderland

The festive campaign also aims to support Macau SAR government in promoting economic diversification as well as supporting small and medium enterprises (SMEs) and NGOs by offering the local vendors with rent-free stalls to showcase their products and services. The Christmas Market features over 40 local SME businesses displaying their unique holiday crafts, gift ideas, and seasonal food and beverages. This marketplace does not only support small businesses but also allows guests to experience Macau’s vibrant local culture.

Winter-Fun Wonderland is open between November 30, 2024, and January 5, 2025, from 1pm to 9pm. Join us at Studio City to celebrate the start of a season filled with joy and holiday spirit.

Limited-time Festive Promotions

Winter Fun Shopping Rewards

This is the season for winter shopping and fantastic rewards! Spend MOP1,000 or more (in a maximum of two same-day transactions) to enjoy these exciting rewards:

A movie voucher to Studio City Cinema;
Admission ticket redemption voucher at Legend Heroes Park;
Buy 1, get 1 free on tickets to Studio City Water Park*;
- Promotion Dates: November 30, 2024, to January 5, 2025;
- Redemption Hours: 13:00 – 21:00;
  - Redemption Location: L1, redemption counter (next to Rossi Pizza);
    - *To redeem buy 1, get 1 free ticket to Studio City Water Park, please present valid same-day receipts (a maximum of two) at the Studio City Water Park Box Office;
- A limited quantity of gifts, available while supplies last.

A Joyous Winter Feast

This winter, make it a magical Christmas by gathering with family and friends at Studio City for a delightful array of festive treats, desserts, and specialty drinks made by our talented chefs.

For a limited time only, special holiday menus are available at Spotlight, Rossi Trattoria, Joyride Diner, Louvre Pastry & Deli, and the Lobby Café at Epic Tower.

Promotion Dates: December 1, 2024, to January 1, 2025;
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For more information, please visit the official webpage at: https://www.studiocity-macau.com/en/offer/winter-fun-wonderland

Vietnam’s casino industry has grown steadily since the 2017 decree that provided a legal framework for its operations, but while the sector has contributed significantly to the national economy, experts argue that gaps in the legal framework could hinder long-term growth and effective management.

Legal and regulatory gaps

Table of Contents

The CEO of the Victorian Gambling and Casino Control Commission (VGCCC), Annette Kimmitt, is going to be retiring despite two years left in her term.

Table of Contents

Vietnam has a special surprise in store for Christmas: Decree 147/2024, a new internet regulation which is set to tighten restrictions on online gaming and card-based games.

Table of Contents

The further relaxation of travel policies for mainland Chinese visiting Macau signals the ‘Chinese government’s ongoing support for Macau’s economic and non-gaming development’, alongside closer integration with the rest of the Greater Bay Area, highlights Goldman Sachs.

Hengqin’s growing role

Table of Contents

Pragmatic Play, a top content supplier to the iGaming industry, has launched Gates of Olympus Xmas 1000, a holiday-themed addition to the popular Gates of Olympus series.

Table of Contents

Relax Gaming, an iGaming aggregator and supplier of unique content has agreed on a deal that sees the studio’s games available to play at Ivy Casino.

Table of Contents

Citigroup has issued a conservative forecast for Macau’s December 2024 gross gaming revenue (GGR), projecting a flat year-on-year performance at MOP18.5 billion ($2.3 billion).

November GGR

Table of Contents

What you need to know

On the radar

MACAU

Corporate Spotlight

Industry Updates

Table of Contents

The Star Entertainment Group has announced the official appointment of Steve McCann as the Group’s Chief Executive Officer and Managing Director, following the receipt of all necessary regulatory approvals.

Table of Contents

Studio City, a flagship property of Melco Resorts & Entertainment, has announced the launch of its enchanting Winter-Fun Wonderland, running from 30 of November until January 5, 2025, promising endless fun for everyone.

An Opening Ceremony was held on Saturday (30 of November) and attended by media and officiating guests including:

Limited-time Festive Promotions

Winter Fun Shopping Rewards

A Joyous Winter Feast

Free Golden Reel Ride

Table of Contents

ENQUIRIES & SUBSCRIPTIONS

CONTACTS

**Pragmatic Play, a top content supplier to the iGaming industry, has launched Gates of Olympus Xmas 1000, a holiday-themed addition to the popular Gates of Olympus series.**