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Disrupting Money Laundering Through Gambling in Southeast Asia Program

In late 2020, with support from the U.S. Department of State Bureau of International Narcotics and Law Enforcement Agency (INL), ABA ROLI launched a program to Disrupt Money Laundering through Gambling for the Mekong region, including Vietnam. This program aims to generate multi-jurisdictional support for a common vision for enhancing the anti-money laundering (AML) regime in this region through work with regulators and lawmakers, competent law enforcement, and company compliance officers and managers. Coordination with relevant experts has been undertaken to produce a handbook and other materials to standardize AML practices in the gambling sector in line with international best practices for tracking money laundering threats, trends, and vulnerabilities. Specifically, ABAROLI developed a Handbook for Preventing Money Laundering in the Casino Sector to assist the development and implementation of effective policies and procedures to prevent ML through casinos. ABA ROLI also developed a Compliance Assessment Tool based on the Financial Action Task Force (FATF) recommendations.

In September 2022, ABA ROLI completed an Assessment of the 2012 AML Law of Vietnam. The Compliance Review Report highlights gaps in the AML framework of Vietnam and provides potential solutions that can help pave the way to graduating off the FATF grey list. Subsequently, the National Assembly of Vietnam passed a new AML Law (2022 Law on AML) in November 2022, which became effective on March 1, 2023. It is important to note that this new Law incorporates some of the recommendations of ABA ROLI’s Compliance Review Report, which provided 20 recommendations and proposed 12 articles for amendment of the old Law. To raise awareness on the provisions of the new Law as well as ABA ROLI’s Compliance Report, two workshops for Regulators (including the State Bank of Vietnam, Ministry of Justice, National Assembly, etc.) and Reporting Entities (including Casino Operators) were organized in collaboration with local agencies. ABA ROLI will continue to work with its existing partners such as the Ho Chi Minh National Academy of Politics (HCMNAP) and explore other opportunities for cooperation with the SBV, the Ministry of Finance (MoF) and the Ministry of Public Security (MPS), among others, to maximize impact on the Gambling program in Vietnam, while also working with the Financial Intelligence Units of Lao PDR and Thailand.

To enhance compliance with the provisions of the 2022 AML Law, ABA ROLI and partners developed AML Guidelines for Regulators and Reporting Entities in the casino sector in May 2023. Both Guidelines have gone through a very thorough review process with comments and/or inputs gathered from relevant AML actors in Vietnam. Over 100 copies of these Guidelines have been disseminated to partners including central and provincial authorities. Two roundtables were also held on these Guidelines in August 2023, with a combined attendance of 61 participants, representing competent authorities such as the State Bank of Vietnam and reporting entities from Vietnam’s casino sector. The two roundtables were to introduce as well as train participants on the use of the Guidelines especially on the reporting requirements and tools outlined in the Guidelines, which include a checklist for site inspections and a Suspicious Transaction Reporting template.