How Is Money Laundering of Embezzlement and Bribery Proceeds Punished?

Money or assets derived from embezzlement (Article 353), taking bribes (Article 354) or giving bribes (Article 364) are all objects of the crime of money laundering (Article 324 of the Penal Code) — because the provision defines “predicate offences” openly, without limiting the list of offences. Individuals face up to 15 years’ imprisonment; commercial legal entities also bear criminal liability for this offence, with fines up to VND 20 billion or permanent suspension of operations (in Article 79 cases).

Short answer

• Open predicate offences: Article 324 lists no specific predicate offences; the recurring phrase is money or assets “derived from one’s own commission of a crime or known or with grounds to know to be derived from another person’s commission of a crime“. Embezzlement, taking bribes and giving bribes are all crimes under the Penal Code → proceeds of these crimes can all be “laundered”.
• Includes “self-laundering”: a predicate offender who legitimizes their own proceeds (“derived from one’s own commission of a crime”) also commits money laundering.
• Individual frames: from 1–5 years’ imprisonment (paragraph 1) up to 10–15 years (paragraph 3); preparation of the offence: 6 months–3 years.
• Commercial legal entities DO bear criminal liability for money laundering (Article 324 is on the Article 76 list) — a key difference from bribe-giving (Article 364), for which a legal entity is not a subject.
• Applicable text: Article 324 under consolidated text 135/VBHN-VPQH (5 September 2025) — the post–Law 12/2017/QH14 version; Law 86/2025/QH15 did not amend Article 324.

Four groups of constituent acts (paragraph 1 — 1 to 5 years’ imprisonment)

1. Directly or indirectly participating in financial, banking or other transactions to conceal the illegal origin of money or assets derived from one’s own commission of a crime, or known or with grounds to know to be derived from another person’s commission of a crime;
2. Using money or assets derived from crime in conducting business or other activities;
3. Concealing information about the origin, true nature, location, movement process or ownership of money or assets derived from crime, or obstructing verification of such information;
4. Committing any of the above acts with respect to money or assets known to be obtained from the transfer, assignment or conversion of money or assets derived from another person’s commission of a crime.

A terminology note: use the law’s exact wording — “known or with grounds to know to be derived from another person’s commission of a crime”; avoid colloquial labels.

Penalty frames for individuals

• Paragraph 1 — 1 to 5 years’ imprisonment: the four groups of acts above.
• Paragraph 2 — 5 to 10 years’ imprisonment: committed by an organized group; abuse of position or power; committed 2 or more times; professional nature; sophisticated, cunning schemes; money or assets valued from VND 200 million to under VND 500 million; illicit gains from VND 50 million to under VND 100 million; dangerous recidivism.
• Paragraph 3 — 10 to 15 years’ imprisonment: money or assets valued at VND 500 million or more; illicit gains of VND 100 million or more; adversely affecting the safety of the national financial and monetary system.
• Paragraph 4 — preparation of the offence: 6 months to 3 years’ imprisonment.
• Paragraph 5 — supplementary penalties: possible fine of VND 20–100 million; prohibition from holding positions, practising a profession or doing certain work for 1–5 years; or confiscation of part or all of the assets.

Resolution 03/2019/NQ-HDTP of the Judicial Council of the Supreme People’s Court guides the application of Article 324 — use it only as an additional reference for offence-constituting circumstances, not for casual quotation.

Commercial legal entities bear criminal liability for money laundering

This is the core distinction to emphasize: Article 324 is on the Article 76 list → commercial legal entities do bear criminal liability for money laundering — whereas for bribe-giving (Article 364), a legal entity is not a subject.

Penalty frames at Article 324(6) for legal entities:

• Fine of VND 1–5 billion (paragraph-1 cases);
• Fine of VND 5–10 billion (paragraph-2 cases);
• Fine of VND 10–20 billion or suspension of operations for 1–3 years (paragraph-3 cases);
• Permanent suspension of operations — but only in cases prescribed in Article 79 (where the legal entity’s offence causes or is practically capable of causing death of many people, environmental incidents, or adverse effects on security, order and social safety, with no ability to remedy the consequences) — not every paragraph-3 case results in permanent suspension;
• Supplementary penalties: fine of VND 1–5 billion; prohibition from doing business, operating in certain sectors, or raising capital for 1–3 years.

Distinguishing “self-laundering” from laundering for others

Both fall within the letter of the law, but must be clearly distinguished:

• “Self-laundering”: the predicate offender (e.g., the embezzler, the bribe-taker) legitimizes money/assets derived from their own crime — grounded in the phrase “derived from one’s own commission of a crime”.
• Laundering for others: handling money/assets “known or with grounds to know to be derived from another person’s commission of a crime” — e.g., receiving embezzled funds and routing them through multiple accounts to conceal their origin.

Do not self-limit the list of predicate offences: the law writes openly (“derived from commission of a crime”), so any Penal Code offence can be a predicate offence of money laundering — embezzlement, taking bribes and giving bribes are simply the typical examples for this topic.

Frequently asked questions

Are embezzlement and bribery proceeds objects of money laundering?
Yes. Article 324 lists no predicate offences; money/assets “derived from one’s own commission of a crime or known or with grounds to know to be derived from another person’s commission of a crime” are all objects — including proceeds of embezzlement (Art. 353), taking bribes (Art. 354) and giving bribes (Art. 364).

What about someone who “launders” money from their own crime?
It still constitutes money laundering — the law covers money or assets “derived from one’s own commission of a crime”.

Can a company face criminal liability for money laundering?
Yes. Article 324 is on the Article 76 list, so commercial legal entities bear criminal liability: fines of VND 1–20 billion, suspension of operations for 1–3 years, or permanent suspension in Article 79 cases.

Sources

• Penal Code — consolidated text 135/VBHN-VPQH (5 September 2025): Article 324 (paragraphs 1–6); in force at the time of writing (14 October 2026).
• Law 12/2017/QH14 (effective 1 January 2018) — amended Article 324; Law 86/2025/QH15 (effective 1 July 2025) — did not amend Article 324.
• Resolution 03/2019/NQ-HDTP of the Judicial Council of the Supreme People’s Court — guiding application of Article 324 (additional reference on offence-constituting circumstances).

Need to review money-laundering risks in your transactions? The FLAT Law Firm team advises on anti-money-laundering compliance, assessing risks in financial transactions and business operations. Contact us at contact us.

This article is for general reference only based on the laws in force at the time of writing (14 October 2026) and does not constitute legal advice for any specific case.

Transparency note: This article was drafted by FLAT Law Firm’s AI content production system and is undergoing internal review (AI Legal Council QA and owner approval before publication). It has not been reviewed by a human lawyer.