Identifying legal risks in the liquefied natural gas (LNG) supply chain: International experience and implications for Viet Nam

Abstract: In the context of increasingly urgent requirements for ensuring energy security, liquefied natural gas (LNG) has been identified as an important component in Viet Nam’s energy development strategy. However, participation in the global LNG supply chain has given rise to numerous significant legal issues. This article analyzes international experience in identifying the risks of legal disputes arising from liquefied natural gas sale and purchase contracts. On that basis, it provides several implications for mitigating risks in LNG supply activities in Viet Nam.

Keywords: Liquefied natural gas, LNG, gas sale and purchase contracts, energy security, international commercial arbitration.

I. Introduction

In recent years, Viet Nam has been facing an increasingly complex energy challenge. Rapid growth in electricity demand, together with the pace of industrialization and urbanization, has created a need to expand and diversify energy supply sources. In this context, recently issued national energy plans and strategies indicate that gas-fired power generation[1] is increasingly identified as an important component of Viet Nam’s future energy mix. The National Power Development Plan for the 2021–2030 period, with a vision to 2050 (Power Development Plan VIII), identifies gas-fired power generation, including “liquefied natural gas–fired power generation” (or LNG power generation),[2] as one of the pillars to ensure energy security and maintain economic growth in the medium and long term. This orientation is also reflected in Resolution No. 57-NQ/TW of the Politburo on national energy development, which emphasizes the need to diversify supply sources, reduce dependence on traditional fuels, and strengthen the role of gas in the energy transition process.[3]

With the orientation toward no longer using coal for power generation by 2050, the baseload role of gas-fired power plants in Viet Nam’s power system is inevitable, as this is the only power source not affected by weather conditions compared to hydropower, wind power, and solar power. As domestic gas sources are showing a declining trend, LNG is identified as playing a role in ensuring the stability and flexibility of the gas-fired power system, thereby contributing to supporting the energy transition process and maintaining national energy security.[4]

However, despite the acknowledged role of LNG, legal studies in Viet Nam in this field remain relatively limited. Most existing works approach LNG from technical, economic, or state management perspectives, paying little attention to the legal aspects of LNG sale and purchase transactions. On that basis, this article focuses on analyzing legal risks and types of legal disputes that may arise in the LNG supply chain, thereby offering several implications for improving the legal framework governing LNG transactions in Viet Nam in the context of current energy development.

II. Characteristics of the liquefied natural gas (LNG) supply chain

First, it should be noted that gas-fired power generation is a form of electricity generation that uses natural gas as the input fuel. Natural gas sources can be divided into two types, including:

- Produced natural gas; or

- Liquefied natural gas (LNG) imported from abroad.

Gas-fired power plants can only operate when a stable supply of natural gas is ensured. Therefore, LNG is often used to replace or supplement domestic gas sources when domestic supply declines or fails to meet demand.

The supply of natural gas, particularly LNG, involves a chain of processes ranging from extraction or importation, processing, and transportation to distribution to end users. Accordingly, it requires a dedicated infrastructure system to meet these needs.

Second, when examining LNG supply activities, there are three core stages that should be noted, including: (i) extraction and production, (ii) distribution of gas from producers to wholesalers, and (iii) distribution of gas from wholesalers to end users.

(i) Extraction and production: This is the first stage of the LNG supply chain. Natural gas is extracted through wells and undergoes processing to remove impurities, ensuring that the gas meets technical standards for further transportation or liquefaction.

(ii) Distribution of gas from producers to wholesalers: This stage involves the sale of gas from producers to wholesalers and constitutes the central stage of the LNG supply chain. Basically, natural gas can be transported in two forms: by pipeline when it remains in gaseous form, or by sea vessels and trucks when it has been liquefied, namely LNG.

(iii) Distribution of gas from wholesalers to end users: At this stage, gas, after being injected into the domestic pipeline system or after being regasified from LNG, is distributed to power plants, industrial facilities, or end consumers.

In practice, finished LNG is transported by sea vessels or trucks. This allows LNG producers and distributors to access a wider range of markets without being constrained by fixed infrastructure connections such as pipeline transportation of gaseous gas. However, this mode of transportation requires very large upfront investments in liquefaction and regasification facilities.[5] While the cost of transporting gas by pipeline over short distances may be relatively low, it increases more rapidly than LNG transportation costs as pipeline length increases. Therefore, in general, LNG tends to be cheaper than pipeline-transported gas when gas must be transported over long distances, but more expensive when transportation is required only over short distances.[5]

III. Legal risks in the liquefied natural gas (LNG) supply chain

From a legal perspective, all three stages of the LNG supply chain outlined above are associated with distinct types of contracts. Accordingly, when a dispute arises at a particular stage of the LNG supply chain, it may generate complex legal consequences. This gives rise to the need to identify the legal risks corresponding to each stage as a basis for dispute prevention and resolution.

3.1. Legal risks in the liquefied natural gas (LNG) supply chain

By its nature, the extraction and production stage of LNG is a technical–construction stage. It includes drilling activities, construction of gathering pipelines, and operation of gas processing plants in order to ensure that the gas meets commercial standards.

From a legal standpoint, this stage is governed by a group of contracts of a technical and construction nature. In practice, gas producers, which may be the State or exploration and production enterprises (Exploration and Production Companies – E&P), often do not directly carry out drilling and natural gas extraction activities at gas fields, but instead enter into drilling services agreements (Drilling Services Agreement – DSA) with professional oil and gas service contractors.[6] These DSA contracts are not only intended to agree on operational specifications and certain key issues such as payment, but also to allocate risks between the producer and the contractor. A typical example is the dispute between Petrobras (Brazil) and Vantage Drilling (the United States), which arose from Petrobras’s unilateral termination of a USD 1.6 billion DSA in relation to Vantage Drilling’s Titanium Explorer drilling rig.[7] In this case, Petrobras argued that the DSA was invalid because it had been formed on the basis of bribery by Vantage. However, in 2018, the International Arbitral Tribunal determined that Petrobras did not have sufficient evidence to show that Vantage had directly participated in such conduct. As a result, Petrobras was ordered to pay compensation of USD 622 million plus interest (totalling approximately USD 700 million).

After gas is extracted, the next stage is gas processing in order to ensure that the gas meets the technical standards required for transportation and commercial use. Contractual arrangements governing gas processing activities are often diverse and are designed to suit the technical and commercial characteristics of each project.[8] A common model is that the producer enters into a gas processing contract with a third party, under which the processing party may simultaneously be responsible for investing in the construction and operation of gas processing facilities. Within the framework of such contracts, the processing party is remunerated based on the actual volume of gas processed. In addition to the outsourcing model, producers may also invest in and construct gas processing facilities themselves and directly manage operations or engage professional entities to perform these tasks. Regardless of the model chosen, once the gas has been processed to meet commercial standards, it becomes an input ready for the transportation and sale stages within the LNG supply chain.

3.2. Legal risks in the LNG supply stage

3.2.1. Common types of contracts in LNG sales and purchase

Both stages of gas distribution - from producers to wholesalers and subsequently to end users - essentially involve LNG sales and purchase transactions between parties.

In practice, the sale and purchase of liquefied natural gas are usually based on several basic types of contracts, specifically as follows:

First is the Master Sales Agreement (MSA). This is the most fundamental type of contract in LNG sales and purchase activities. An MSA serves to establish the most general legal and commercial terms governing individual LNG transactions between buyers and sellers. Accordingly, the MSA mainly sets out foundational terms that the parties can repeatedly apply to multiple transactions in the future. Detailed arrangements arise when the parties enter into each specific LNG sales and purchase agreement. The advantage of using an MSA lies in reducing negotiation costs and increasing transactional flexibility. Therefore, in practice, MSAs are commonly used in spot LNG transactions.[9]

Second is the LNG Sales and Purchase Agreement (SPA). This is the complete form of an LNG sales and purchase contract, intended to establish specific obligations relating to the sale and purchase of LNG based on the MSA previously concluded by the parties. An SPA typically stipulates key elements such as LNG volume, pricing mechanisms, delivery terms, delivery and receiving ports, payment, force majeure, and related issues. In practice, an SPA is often concluded on the basis of an existing MSA; however, in some cases, it may be executed independently for a single transaction, in which the general terms of an MSA are incorporated by reference and applied supplementarily to the SPA. SPAs are usually agreed for long terms, commonly ranging from 15 to 25 years, in order to mitigate risks inherent in energy projects in general and LNG projects in particular, such as large capital requirements and long capital recovery periods. Maintaining long-term contractual relationships enables the parties to allocate and manage market risks, supply risks, and financial risks more stably than under short-term or spot transactions. At the same time, long-term SPAs constitute an essential legal basis for investors and credit institutions to assess the project’s cash flow generation capacity throughout its financial life cycle, thereby deciding whether to finance infrastructure components such as liquefaction plants, LNG receiving terminals, regasification systems, and ancillary facilities.

Third is the Gas Sales and Purchase Agreement (GSPA). Essentially, this is a contract for the sale and purchase of gas after LNG has undergone regasification from its liquefied form. The arrangements under a GSPA also revolve around issues such as the volume of regasified gas, pricing mechanisms, delivery, payment, and related matters.

3.2.2. Common dispute risks in LNG sales and purchase

When examining international experience in LNG sales and purchase activities, several typical types of disputes frequently arise. Specifically:

The first type of dispute concerns price and price adjustment mechanisms. Such disputes often arise from discrepancies - often significant - between the price agreed in the contract and prevailing market prices. This creates incentives for one party to seek to maximize the economic benefits derived from such price differentials. For example, in SPA contracts, due to their long duration, situations may arise where market LNG prices fall below the contract price. In such cases, buyers tend to seek to invoke price adjustment clauses in order to avoid losses. Conversely, if market LNG prices exceed the contract price, sellers may also seek adjustments to secure higher profits. With respect to disputes over price and price adjustment mechanisms, reference may be made to the case of Atlantic v. GNA.[10] In this case, Atlantic acted as the LNG seller, while Gas Natural was the buyer supplying the European market. The SPA was concluded with an LNG price fixed by reference to gas price indices in the United States market. The dispute arose when GNA took advantage of a sharp decline in U.S. gas prices to purchase LNG from Atlantic at a low price and then resold it in the European and Asian markets at higher prices, thereby causing losses to Atlantic. The arbitral tribunal ruled in favor of Atlantic, ordering the removal of the fixed pricing formula and the application of a price reflecting actual market conditions.

The second type of dispute concerns LNG delivery and receipt. Parties to LNG sales and purchase contracts are required to ensure the performance of their delivery and acceptance obligations as agreed. With respect to disputes over LNG delivery, reference may be made to the case of BP v. Venture Global LNG before the International Court of Arbitration of the International Chamber of Commerce (ICC).[11] In this case, LNG producer Venture Global (United States) entered into SPAs with BP, Shell, Repsol, and several other energy companies. BP alleged that Venture Global failed to deliver LNG in accordance with the obligations agreed under the SPAs. At the same time, BP argued that Venture Global deliberately delayed LNG deliveries by postponing the declaration of the project’s commercial operation date due to equipment issues and generator malfunctions. On that basis, BP claimed that Venture Global profited by selling these delayed LNG cargoes on the spot market at prices higher than those stipulated in the SPAs. The arbitral tribunal found that Venture Global had breached its obligation to timely declare commercial operations and had failed to act as a “reasonable and prudent operator” in accordance with the terms of the SPAs. BP is currently seeking damages in excess of USD 1 billion, with a separate hearing on quantum expected to take place in 2026 to determine the final award.

The third type of dispute relates to the “take or pay” clause in LNG sales and purchase contracts. Under this clause, the buyer is required to commit to purchasing a minimum quantity of product within a specified period. If the buyer fails to take the committed quantity, it must still make payment, even where it is unable to actually consume the LNG. This mechanism is intended to mitigate risks for suppliers, particularly in large-scale infrastructure projects. Disputes arise when buyers are unable to take delivery of LNG due to changes in market demand, infrastructure failures, or operational reasons, while sellers continue to demand full payment obligations under the contract. An illustrative example is Cheniere Energy, Inc. v. Parallax Enterprises LLC.[12] The dispute arose when Cheniere sued Parallax for breaching financial commitments and cost reimbursement obligations after liquefaction projects failed to progress as expected. The court ordered Parallax to compensate Cheniere more than USD 46 million, while affirming that fixed fees and “unconditional” payment commitments constitute core principles for protecting investors’ cash flows. At the same time, the judgment emphasized the enforceability of take-or-pay clauses, holding that once the parties have agreed on the allocation of financial risks, buyers or counterparties cannot easily evade payment obligations even when projects encounter difficulties or market conditions change.

The final common type of dispute concerns force majeure clauses. Energy markets in general, and LNG markets in particular, are highly volatile and subject to a wide range of geopolitical factors, natural disasters, and technical failures. When contractual obligations are not performed, parties often disagree as to whether the invoked event satisfies the definition of force majeure under the SPA. Another factor commonly examined is whether the event genuinely prevents performance of the obligation, or merely renders performance more economically burdensome. Disputes over force majeure clauses are clearly illustrated in the Venture Global LNG litigation discussed above.[13] In all actions brought by claimants such as Shell, BP, and Repsol, the respondent Venture Global declared force majeure due to technical failures in the power system of the plant to justify delays in declaring commercial operations. The claimants Shell and BP argued that the technical failures cited by Venture Global did not meet the contractual threshold of a force majeure event. They further contended that such conduct amounted to “commercial opportunism” disguised as reliance on the force majeure clause.

3.3. Current status of LNG sales and purchase activities in Viet Nam

The LNG market in Viet Nam is a relatively new economic sector, having only truly taken shape and begun operating in practice since 2023.[14] Prior to that time, LNG mainly existed in the form of policy orientations and energy planning. The number of enterprises directly participating in LNG trading in the domestic market remains very limited. By way of example, PetroVietnam Gas Corporation (PV GAS) is the first enterprise to have implemented LNG supply activities through the conclusion of several MSAs.[15] PV GAS currently holds the majority of infrastructure, including pipeline systems, storage facilities, and gas distribution hubs supplying gas-fired power plants. Key LNG gas-fired power projects (such as Nhon Trach 3 & 4) are currently directly dependent on LNG supplied by PV GAS. In addition, there are other private enterprises, such as Hai Linh Co., Ltd. with the Cai Mep LNG terminal in Ho Chi Minh City.[16] Furthermore, the presence of foreign investors and partners such as Tokyo Gas, AG&P LNG, AES Corporation, Mitsubishi Corporation, as well as international LNG suppliers such as Novatek, also plays an important role in the formation and operation of the LNG market in Viet Nam.

When considering the current context of the LNG market, the legal risks identified in international LNG transaction practice exhibit many characteristics that are likely to recur in the Vietnamese market as LNG importation and consumption activities continue to expand.

First, as a relatively late entrant into the international LNG market, the primary purpose of LNG imports into Viet Nam is to supply fuel for LNG gas-fired power plants.[17] Vietnamese enterprises participate in the LNG supply chain under contractual frameworks that have been developed on the basis of pre-existing international practices. In many cases, the ability to negotiate adjustments to key contractual terms such as “take or pay” clauses or price adjustment mechanisms may present significant challenges. This may place Vietnamese enterprises in a disadvantaged position if adequate preparation is lacking.

Although PV GAS has concluded several LNG MSAs, pricing terms have not been publicly disclosed. In theory, if LNG prices are determined on the basis of imported LNG prices from foreign suppliers, exposure to international market price fluctuations is unavoidable. However, the conclusion of MSAs also means that LNG in Viet Nam is often traded through spot transactions.[18] As a result, to a certain extent, LNG price volatility in the Vietnamese market will be less affected by global market prices.

Moreover, infrastructure and the legal framework serving LNG importation, regasification, and distribution in Viet Nam are still in the process of being completed. Although Vietnamese law does not establish a monopoly regime over LNG importation and distribution activities, in practice PV GAS currently holds a dominant market position due to its advantages in infrastructure, experience, and its pioneering role in implementing the first LNG projects in Viet Nam. The development of LNG terminals, regasification plants, and gas pipeline systems is still being carried out according to a roadmap and remains highly dependent on legal, technical, and investment-related factors. During this transitional period, the lack of synchronization in domestic infrastructure development may increase the risk of disputes arising over delivery and receipt obligations among LNG enterprises.

Beyond internal factors, legal risks in the LNG supply chain in Viet Nam are also strongly affected by the geopolitical context and fluctuations in the global energy market. Geopolitical tensions have disrupted, and continue to disrupt, the international LNG market, causing LNG prices to fluctuate unpredictably and thereby increasing uncertainty in long-term contracts. In this context, force majeure clauses are more likely to be invoked and disputed. In practice, the ability of Vietnamese LNG importers to perform their obligations under Master Sale Agreements (MSAs) largely depends on the operation of a very limited number of LNG receiving terminals. During contract performance, if the operation of these LNG terminals is disrupted and no reasonable alternative arrangements are available, in theory, the importer may invoke a force majeure event to temporarily suspend contractual performance. However, it should be noted that proving a force majeure event in practice is far from straightforward. In addition to the event itself, other factors such as the timing of the event, the actual degree of impact on contractual obligations, as well as whether the affected party has fully complied with its notification obligations, are all of critical importance in determining whether force majeure will be accepted.

Another legal issue is that the LNG sector in Viet Nam is currently governed simultaneously by multiple legal normative documents.

At the policy level, LNG is identified in Power Development Plan VIII as a supplementary fuel source of a structural nature for the power system in the context of energy transition and the decline of domestic natural gas sources. At the level of legislation governing business activities, LNG is currently managed mainly through general regulations on petroleum, energy, and commerce. Accordingly, LNG-related activities are subject to the Law on Petroleum 2022,[19] legislation on gas business,[20] legislation on import and export,[21] as well as the Law on Investment,[22] the Law on Construction,[23] and the Law on Environmental Protection.[24] In addition, due to its hazardous characteristics and high technical requirements, LNG business activities are also subject to regulations on industrial safety and fire prevention and firefighting.[25]

Such a fragmented legal framework requires enterprises to carry out multiple administrative procedures under the supervision of various state authorities, thereby increasing costs and legal risks during project implementation. Furthermore, based on the practical experience of key enterprises in the natural gas sector, LNG importation and trading activities in Viet Nam are currently conducted only on a project-by-project basis, associated with LNG terminals and gas-fired power plants that have been approved in the planning.[26] This may reduce the attractiveness of the Vietnamese LNG market to foreign investors, running counter to the Government’s long-term vision of attracting investment and developing the energy sector in recent years.

IV. Implications for Viet Nam

Based on the identification of legal risks and the current context of Viet Nam’s legal framework governing LNG, the author proposes several policy implications as follows:

First, LNG has created important opportunities for ensuring energy security and facilitating Viet Nam’s energy transition, while at the same time posing significant legal challenges. Early and comprehensive identification of legal risks in the LNG supply chain is a necessary condition for Vietnamese enterprises and lawmakers to develop appropriate preventive mechanisms, limit disputes, and ensure the sustainability of the LNG development strategy in the context of deep integration into the global energy market. Given that Vietnamese enterprises have entered the LNG market relatively late, a thorough understanding of contractual structures, risk allocation mechanisms, and the legal consequences of individual contractual clauses is of critical importance for the protection of long-term interests. This issue concerns not only the capacity of individual enterprises, but also the need to develop a pool of legal experts with in-depth expertise in the LNG sector.

Second, for Vietnamese enterprises participating in LNG importation and trading, entry into the LNG market should not be viewed merely as an ordinary commercial activity, but rather as participation in a long-term, complex, and high-risk contractual structure. Legal risks in the LNG sector do not usually arise in isolation; instead, they tend to cascade from one contract to another within the same project chain, for example from LNG import contracts to terminal leasing and regasification agreements. Inconsistent design of LNG sale and purchase contracts may increase the risk of chain disputes, particularly in the context of underdeveloped domestic LNG infrastructure.

Third, international practice shows that LNG disputes often revolve around core contractual clauses such as delivery and acceptance obligations, price adjustment mechanisms, and force majeure. In Viet Nam, LNG transactions are currently conducted mainly through framework agreements and spot transactions, and legal risks may not yet be immediately apparent. However, as LNG import volumes increase and long-term contracts such as Sale and Purchase Agreements (SPAs) gradually emerge to serve large-scale gas-fired power projects, these types of disputes are likely to become more tangible. Accordingly, early research and anticipation of dispute scenarios, rather than merely reacting once disputes have arisen, is a necessary requirement. In addition, particular attention should be paid to take-or-pay clauses, as they represent a typical risk allocation mechanism in long-term LNG sale and purchase contracts. In the context of Viet Nam’s emerging LNG-to-power project chain, enterprises’ clear understanding and negotiation of take-or-pay thresholds, make-up mechanisms, exemptions, and their interaction with force majeure clauses will be decisive in limiting dispute risks and financial consequences for the parties involved.

Finally, from an institutional perspective, improving the legal framework governing LNG in a more coherent and transparent manner is also an important policy implication. Fragmentation of existing legal regulations not only increases compliance costs and legal risks for enterprises during project implementation, but also heightens the likelihood of disputes due to the absence of unified standards on certain core issues. Accordingly, the role of state management authorities should be reflected in the design and operation of a clearer legal framework for LNG, aligned with infrastructure development roadmaps and information disclosure mechanisms, with a view to creating a stable investment environment, reducing information asymmetry in contract negotiations, thereby limiting dispute risks and enhancing the attractiveness of Viet Nam’s LNG market.

REFERENCES

A. Research works, books, and journals

1. The Anatomy of an Oil and Gas Drilling Contract

2. Beyers, Eldi. Drilling and Service Contracts, in Peter Roberts (ed.), Oil and Gas Contracts: Principles and Practice, Sweet & Maxwell (2016).

3. ContractsCounsel. Gas Sales Agreement, https://www.contractscounsel.com/t/us/natural-gas-sales-agreement (accessed December 2025).

4. Dang Dinh Thang, Huynh Quyen & Ta Dang Khoa. Prospect of Gas Industry and the Role of Liquefied Natural Gas (LNG) in Vietnam during 2011–2035, Science and Technology Development Journal, Vol. 19(K6) (2016),https://stdj.scienceandtechnology.com.vn/index.php/stdj/article/view/582 (accessed December 2025).

5. Roberts, Peter. Gas and LNG Sales and Transportation Agreements: Principles and Practice, 4th ed., Sweet & Maxwell (2014).

6. Roberts, Peter. Natural Gas Sales and Trading Contracts, in Peter Roberts (ed.), Oil and Gas Contracts: Principles and Practice, Sweet & Maxwell (2016).

* Master of Laws, University of Limerick – Ireland; Lecturer, Department of International Law, University of Law, Hue University. Email: nguyenpd@hul.edu.vn. Date of acceptance: 27 January 2026.

[1] “Gas-fired power generation” refers to a form of electricity generation using natural gas as fuel, in which the chemical energy of gas is converted into thermal energy through combustion, and subsequently transformed into electrical energy. Gas-fired power plants use two types of fuel, including domestically produced natural gas and liquefied natural gas.

[2] “Liquefied natural gas-fired power generation” or “LNG power generation” is a sub-category of “gas-fired power generation”, in which the fuel used is LNG that is re-gasified before being supplied to the power plant.

[3] Resolution No. 57-NQ/TW on breakthroughs in the development of science, technology, innovation, and national digital transformation.

[4] Dang Dinh Thang, Huynh Quyen & Ta Dang Khoa, Prospect of Gas Industry and the Role of Liquefied Natural Gas (LNG) in Vietnam during 2011–2035, Science and Technology Development Journal, 19(K6) (2016), https://stdj.scienceandtechnology.com.vn/index.php/stdj/article/view/582 (accessed December 2025).

[5] Peter Roberts, Gas and LNG Sales and Transportation Agreements: Principles and Practice (4th ed., Sweet & Maxwell 2014), para. 2-006.

[6] Eldi Beyers, Drilling and Service Contracts, in Peter Roberts (ed.), Oil and Gas Contracts: Principles and Practice (Sweet & Maxwell 2016), pp. 101–125; xem thêm Owen Anderson, The Anatomy of an Oil and Gas Drilling Contract, (1990) 25(3) Tulsa Law Review 359.

[7] Vantage Deepwater Company, Vantage Deepwater Drilling, Inc. v. Petrobras America Inc., Petrobras Venezuela Investments & Services, BV, Petróleo Brasileiro S.A. (Petrobras Brazil), ICDR Case No. 01-15-0004-8503.

[8] Peter Roberts, Natural Gas Sales and Trading Contracts, in Peter Roberts (ed.), Oil and Gas Contracts: Principles and Practice (Sweet & Maxwell 2016), pp. 221–224.

[9] Spot transactions in the LNG market are understood as transactions involving the sale and purchase of individual cargoes, with short delivery timeframes and LNG prices determined by market conditions at the time of the transaction, without giving rise to long-term supply obligations between the parties.

[10] Atlantic LNG Company of Trinidad and Tobago v. Gas Natural Aprovisionamientos SDG, S.A.

[11] BP p.l.c. v. Venture Global LNG, Inc.

[12] Cheniere Energy, Inc. v. Parallax Enters. LLC, Court of Appeals of Texas, Houston (14th Dist.).

[13] Ibid., note 12.

[14] Government Electronic Newspaper, PV GAS: A Pioneering Journey with LNG, https://baochinhphu.vn/pv-gas-hanh-trinh-tien-phong-voi-lng-102250912142946207.htm (accessed December 2025).

[15] On 5 May 2023, the Ministry of Industry and Trade issued Decision No. 01/GCNĐĐK-BCT certifying that Vietnam Gas Corporation (PV GAS) satisfies the conditions to act as an LNG import and export trader. PV GAS is the first enterprise in Viet Nam licensed to import and export LNG. In July 2023, PV GAS received the first LNG cargo and commenced operation of the Thi Vai LNG Terminal, with Phase 1 capacity of 1 million tons per year.

[16] Compilation of LNG Projects in Viet Nam – Latest Update,

[17] Typical examples include the Quang Ninh LNG Power Plant, Son My 1 and Son My 2 Power Plants, as well as Nhon Trach 3 and Nhon Trach 4 Power Plants, etc.

[18] Ibid., note 10.

[19] Law on Petroleum 2022.

[20] Decree No. 87/2018/ND-CP dated 15 June 2018 of the Government on gas trading.

[21] Law on Foreign Trade Management 2017 and Law on Export and Import Duties 2016.

[22] Law on Investment 2020.

[23] Law on Construction 2014, as amended and supplemented in 2020.

[24] Law on Environmental Protection 2020.

[25] Law on Fire Prevention and Fighting 2001, as amended and supplemented in 2013; Decree No. 136/2020/ND-CP dated 24 November 2020 of the Government detailing a number of articles of the Law on Fire Prevention and Fighting.