Under this program, Transnational Anti-Money Laundering Assistance Program – Disrupting Money Laundering Through the Casino Sector (AML Gambling Program) in Southeast Asia and Vietnam, the American Bar Association Rule of Law Initiative (ABA ROLI) provides governments, AML regulators and supervisors, with tools and capacity building assistance to strengthen legal frameworks governing AML in the casino sector, to enhance casino-sector money laundering risk assessments, to improve the supervision of casino sector AML controls, and to support casino and online gaming operators to meet their AML obligations. Since the program began in 2020, ABA ROLI has been successfully providing technical assistance to both regulators and reporting entities in Vietnam, Thailand, and Lao PDR, to strengthen their AML legal frameworks and provide tailored training on these frameworks as well as other regional and international instruments, such as the guidelines under the Financial Action Task Force. The program is funded by the US Department of State Bureau of International Narcotics and Law Enforcement Affairs, Office of Global Programs and Policy (INL/GPP).
Transnational Anti-Money Laundering Assistance Program – Disrupting Money Laundering Through the Casino Sector in Southeast Asia and Vietnam
On March 1, 2023, Vietnam put the Anti-Money Laundering Law of 2022 into effect. This law, which amends the 2012 law, is considered a major step toward strengthening the AML legal framework in Vietnam. The new Law provides a legal basis for all AML stakeholders to take appropriate measures to enhance the AML system of Vietnam. In addition to ABA ROLI’s contribution to develop the 2022 AML law, ABA ROLI together with its partners in Vietnam organized a series of hybrid workshops and roundtables on the new law, held in Hanoi, Ho Chi Minh, and Da Nang cities. One of the roundtables for reporting entities, held on February 28, 2023, attracted 149 in-person participants and more than 2,000 joined online. The roundtable was centered on the role of the casino operators to ensure compliance with the new AML law.
In collaboration with local partners, ABA ROLI also held a roundtable for the AML regulators in Vietnam on the new law. The roundtable, held on March 28, 2023, raised awareness amongst the regulators on the 2022 AML Law and provided a platform to share the work of ABA ROLI with the participants (all from AML regulatory agencies), specifically on the findings of the AML Compliance Assessment report developed to support the State Bank of Vietnam and the National Assembly in formulating the new AML Law. In attendance were dozens of government officials drawn from agencies responsible for drafting, reviewing, and appraising legislation before submission to the National Assembly or Government for enactment.
To accompany the new law, ABA ROLI developed two AML Guidelines for the Vietnamese regulators and casino operators. These guidelines underwent a series of revisions and commentaries, facilitated by two Vietnamese consultants, before its finalization in April 2023. The Guidelines were developed to assist regulators and casino operators to assess money laundering risks, and to develop their own internal procedures to comply with the AML laws and/or regulations in the casino sector including the 2022 AML Law.
In Laos, ABA ROLI successfully orchestrated a first-of-its-kind training initiative on AML Supervision Techniques for regulators in both the Financial and Non-Financial sectors. The event took place in Vientiane, capital of Lao PDR from June 1-2, 2023. Over the course of these two days, participants took part in comprehensive training, delving into the fundamental principles of money laundering prevention. The program exposed participants to contemporary and emerging global money laundering issues, with an emphasis on relevant case studies from countries such as the United States and Thailand. This training featured presentations delivered by AML experts from the region and the United States. Additionally, it incorporated interactive discussions and hands-on exercises facilitated by subject matter experts, particularly focusing on AML risk assessment. It is noteworthy that the timing of this training aligned strategically with the adoption of a decentralized model of AML supervision and inspection by the government of Laos. This synchronized effort enhances the regulators’ capabilities, fostering a more robust and effective approach to combating money laundering in the region.