La Défense Works with the Ministry of Agriculture and Environment to Protect Investor Rights

Protect Investor Rights continues to shape the legal strategy as national authorities re-examine the investor’s legitimate claims.

The Minister’s request for the provincial leaders to participate directly is an encouraging signal. If the legal obstacles are addressed in accordance with the law, the Movenpick Central Project can be fully reinstated.

Ministerial Verification Team Established

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On October 10, 2025, the Ministry of Agriculture and Environment issued Decision No. 4178/QĐ-BNNMT establishing a verification team to review the complaint of Viet Group Central concerning the provincial decision revoking land for the “Movenpick Central – Hotel, Residential and Shophouse Complex Project” in Đồng Hới City (now within Quảng Trị Province).

This marks an important step forward in safeguarding the legitimate rights and interests of the investor, especially since the Ministry requires the leadership of the Quảng Trị Provincial People’s Committee to participate directly, without delegating to subordinate departments. This unprecedented requirement in complaint-verification procedures underscores the Central Government’s seriousness regarding a long-standing and complex local matter.

A Major Project with Substantial Investor Input

The Movenpick Central Project received its initial investment approval in 2018 under Document No. 2192/UBND-TH. In 2022, the investment policy was amended under Decision No. 1569/QĐ-UBND of Quảng Bình Provincial People’s Committee, with a total investment capital of VND 936 billion and Movenpick Hotel & Resorts (Switzerland) as the strategic partner.

The project covers 2,911.6 m², of which 2,808.4 m² had been granted a land-use right certificate since 2016. Between 2020–2022, the investor invested hundreds of billions of VND in planning, design, site clearance, EPC contracting, and test-piling works. The project has full legal documentation and was being implemented in a substantive manner.

Financial Obligations Increased by Over 58%

Under the bidding documents and Decisions 959/QĐ-UBND and 3238/QĐ-UBND (2020), the project’s financial obligations were set at VND 53.456 billion.
However, under Decision 2615/QĐ-UBND dated September 27, 2022, these obligations were recalculated at VND 84.1 billion — an increase of 58%.

From 2023 to 2025, the financial obligations continued to be inconsistently calculated in various documents, fluctuating between VND 84–105 billion.

Changing the financial obligations after land allocation violates Article 108 of the Land Law and disrupts the project’s entire financial structure, causing financing applications to stall. This has been identified as a key reason why the investor could not complete the obligations within the prescribed timeline.

Unresolved Delays in Adjusting the Project Schedule

On March 10, 2023, the investor submitted an application for schedule adjustment under the Investment Law.
The Department of Planning and Investment evaluated the submission and issued Report No. 2076/KHĐT-TĐ (July 26, 2023), affirming that:

“The law does not allow refusal of a schedule adjustment request on the grounds of incomplete financial obligations.”

Nevertheless, the Quảng Bình Provincial People’s Committee neither approved nor denied the request, causing a procedure — which legally should take no more than 32 days — to be delayed for months. As a result, banks could not disburse funds, the investor could not pay land-use fees, and additional legal complications arose.

In contrast, while the investor was continuously seeking support, the Provincial People’s Committee issued multiple penalty decisions, tax code blockades, and on February 4, 2025 issued Decision 242/QĐ-UBND revoking the project land — despite the project never being terminated under the Investment Law.

Protect Investor — *illustrative image of the meeting*

La Défense: “Land cannot be revoked when the investment policy remains valid and delays are caused by administrative agencies”

Representing the investor, La Défense Law Firm will assert during the meeting that Decisions 242/QĐ-UBND and 2064/QĐ-UBND violate:

Article 64 of the 2013 Land Law
Article 81(9) of the 2024 Land Law
Article 48 of the 2020 Investment Law
Article 31 of Decree 102/2024/NĐ-CP

The project has never been terminated under the Investment Law, and no extension adjustment has been granted; therefore, it cannot be considered “behind schedule after extension”. The delays stemmed directly from administrative inaction and lack of support, not from any wrongdoing by the investor.

Attorney Luu Tien Dung emphasized:

“Revoking land when the investor is implementing the project substantively, without meeting any conditions for revocation, and when obstacles arise from administrative authorities themselves — this contradicts the Investment Law and seriously undermines investor confidence in the business environment.”

Ministry of Agriculture and Environment: Requiring Direct Participation of Provincial Leadership

With Decision 4178/QĐ-BNNMT, the Ministry has:

Formed an independent verification team
Required the provincial leadership of Quảng Trị to attend directly, without delegation
Returned the matter to its essence: an objective assessment of the investor’s lawful rights versus local administrative procedures

This reflects a strong message from the Central Government:

“A major international-standard tourism project cannot be left stagnant due to arbitrary application of the law.”

Towards Restoring the Project and Protecting Legitimate Investor Rights

At the working session, La Défense and the investor will request the Ministry to:

Annul the unlawful land-revocation decisions
Recalculate financial obligations in accordance with the Land Law
Issue the schedule-adjustment approval under Report No. 2076/KHĐT-TĐ
Reinstate the investor’s right to continue implementing the project

The Minister’s requirement for provincial leaders to participate directly signals a positive shift. If the issues are resolved in accordance with the law, the Movenpick Central Project can be fully revived — contributing to local tourism and economic development, while reaffirming the principle of protecting lawful investment rights, a cornerstone of a transparent and stable investment environment.

Attorney Luu Tien Dung
La Défense Law Firm