Vietnam’s Decree No. 391/2026/NĐ-CP: The Maximum Administrative Gambling Fine Remains VND200 Million; Decree 137 to Be Replaced From December 5

File photo: Thê Húc Bridge at Hoan Kiem Lake in Hanoi, Vietnam, 15 January 2025. Geographic context only; not a scene of the decree’s signing or a gambling enforcement action. Photo: David Stanley / Wikimedia Commons, CC BY 2.0. Display cropped to fit. Image source.

Vietnam’s government issued Decree No. 391/2026/NĐ-CP on October 20, setting out administrative penalties in three areas: betting, casinos, and electronic gaming machines for foreigners. Signed on behalf of the government by Deputy Prime Minister Nguyễn Văn Thắng, it takes effect on December 5, 2026, when it will replace Decree No. 137/2021/NĐ-CP of 2021.

Some foreign-language industry media reported it under headlines saying that “Vietnam raises illegal-operator fines to VND200 million.” That description is inaccurate: under Article 5 of Decree 137, the maximum fine for organizations in the betting and prize-winning gaming sectors was already VND200 million, and VND100 million for individuals. Article 4 of Decree 391 sets exactly the same ceilings. The changes in the new decree concern the classification of violations and the specific amounts in each penalty band, not the maximum fine.

51 Groups of Violations

According to the government’s electronic information portal, Decree 391 lists 51 groups of violations: 17 in betting, 15 in casinos, 15 in electronic gaming machines for foreigners, and another four specifically concerning anti-money laundering, counter-terrorist financing, and counter-proliferation financing of weapons of mass destruction. All fine amounts apply to organizations; individuals face half those amounts.

Some of the more heavily penalized conduct includes:

• Operating betting outside the permitted scope, using event results to place bets or illegally organizing betting, or operating betting types or products not permitted by law, where the conduct does not constitute a criminal offence: a fine of VND180 million to VND200 million;
• Operating betting without a certificate of business eligibility: a fine of VND180 million to VND200 million (Article 9, Clause 3);
• Lending money to players to place bets: a fine of VND160 million to VND180 million;
• Selling betting tickets to people who are not permitted to participate in betting: a fine of VND130 million to VND150 million;
• Opening or maintaining anonymous accounts or accounts under false names, or illegally providing services that receive cash, cheques, and similar instruments and make payments on others’ behalf: a fine of VND130 million to VND150 million;
• Organizing, participating in, or assisting money laundering, failing to report terrorist financing, and similar conduct, where it does not constitute a criminal offence: a fine of VND180 million to VND200 million.

For casinos and electronic gaming machines for foreigners: violations involving applications for certificates of business eligibility carry fines of VND40 million to VND100 million; violations involving the management and use of certificates, VND90 million to VND200 million; violations concerning the layout of business premises, VND180 million to VND200 million; and breaches of operating-hour rules, VND40 million to VND200 million. Casinos conducting business inconsistent with their authorization face fines of VND180 million to VND200 million (Article 26, Clause 3), as does operating electronic gaming machines without authorization (Article 41, Clause 3(a)).

Additional penalties include suspension of operations for a specified period and confiscation of evidence and instruments used in violations. Remedial measures include surrendering unlawful proceeds and destroying or re-exporting non-compliant gaming machines and gaming tables. The limitation period for imposing penalties is one year: for ongoing violations, it runs from discovery; for violations that have ended, it runs from the date they ended.

What VND200 Million Means

VND200 million is equivalent to approximately US$7,700, according to foreign-language media conversions. For a casino or betting company, that ceiling is not high. This also shows that administrative penalties are only the first line of enforcement in Vietnam: most provisions specify “where the conduct does not constitute a criminal offence,” and once the criminal-law threshold is reached, the case moves into criminal prosecution. The measures with real weight are suspension of operations, confiscation, and surrender of unlawful proceeds.

Listing anti-money laundering separately in four groups is one of the most visible structural changes this time. It is consistent with Vietnam’s recent amendments to its Anti-Money Laundering Law (the decree’s preamble cites Law No. 14/2022/QH15, as amended by Law No. 23/2026/QH16).

Timeline

• Around October 14: the Finance Ministry advanced a draft decree to replace Decree 137;
• October 20: the government issued Decree 391;
• December 5: Decree 391 takes effect, and Decree 137 simultaneously ceases to have effect.

The original decree is a scanned document. The provisions listed in this article are based on the government’s electronic information portal announcement and excerpts from Vietnamese legal databases. For portions not checked against the full text article by article, the original text prevails.

Sources

Original source document: The first page of Decree No. 391/2026/NĐ-CP, issued on October 20, 2026. Document attribution: Vietnam’s Government Office.

Original PDF of Decree No. 391/2026/NĐ-CP (republished by the Vietnamese legal database LuatVietnam): https://static3.luatvietnam.vn/uploaded/others/2026/10/21/391-2026-nd-cp-090104-091738.pdf

Vietnamese government electronic information portal announcement (October 20, 2026, republished by Thư viện Pháp luật): https://thuvienphapluat.vn/chinh-sach-phap-luat-moi/vn/ho-tro-phap-luat/chi-dao-dieu-hanh/4109/vi-pham-ve-dat-cuoc-tro-choi-co-thuong-bi-phat-den-200-trieu-dong

LuatVietnam’s interpretation of the provisions (Articles 4, 9, 26, and 41): https://luatvietnam.vn/tin-van-ban-moi/da-co-nghi-dinh-391-2026-nd-cp-quy-dinh-xu-phat-vi-pham-hanh-chinh-trong-kinh-doanh-dat-cuoc-va-tro-choi-co-thuong-186-114167-article.html

Decree No. 137/2021/NĐ-CP (government legal database): https://vanban.chinhphu.vn/?classid=1&docid=204922&orggroupid=2&pageid=27160

Related foreign-language media report (headline says “raises ... fines to VND200m”): https://globalgaminginsider.com/news/8084/vietnam-raises-illegal-operator-fines-to-vnd200m