Sexual Grooming: A Look at the Experience of Some Countries and Suggested Solutions for Vietnam

In the world and in Vietnam, the issue of sexual grooming (seducing minors for sexual abuse) is becoming increasingly painful, as a series of cases of sexual abuse of minors are discovered. To overcome this situation, countries around the world and some Southeast Asian countries have taken effective measures, especially by promulgating and implementing legal regulations. This article presents some theoretical issues on the act of seduction for sexual purposes, such as determining the definition and characteristics of the act of seduction for sexual purposes, systematizing and clarifying the regulations of some Southeast Asian countries on the act of seduction for sexual purposes, and making some recommendations to handle the act of seduction for sexual purposes in Vietnam.

Introduction

Children represent the happiness of the family and, the future of the country. However, in the world and in Vietnam today, a worrying reality is quite common, which is the problem of luring minors to commit acts of sexual abuse, also known as “sexual grooming,” in which the forms and tricks used to get children to voluntarily commit sexual acts are still complicated and tend to increase in both the quantity and nature of acts.

In Vietnam, out of a total of 1,000 cases of sexual abuse, the number of cases in which the victims were minors accounted for 65%, and the majority of victims were females aged 12–15 (accounting for 57,46%). In addition, the rate of victims being children under six years of age is alarming, accounting for 13,2% (Trang, 2024, p. 37). Vietnam has implemented many preventive and combat measures to reduce and repel “sexual grooming” on the internet as well as in real life. However, the current protection work still faces certain barriers and difficulties such as the detection and reporting of cases of sexual abuse of minors is not completely and timely; the law on the protection of minors still has many “gaps” and lacks specificity; the model of victim assistance lacks professionalism; and the management of cyberspace still has many limitations and has not been effectively controlled.

Therefore, it is necessary to research and learn from foreign laws to find lessons for Vietnam to prevent and combat the sexual abuse of minors to protect minors and build a healthy social environment.

Research Methodology

This study employs qualitative research methods as the main method, combined with a comparative approach that compares law and practice. Specifically, the study collected and analyzed secondary documents from scientific works, reports of international organizations, legal documents, and case law related to handling sexual grooming behavior in some Southeast Asian countries. At the same time, applying the analysis-synthesis method to clarify the characteristics, handling mechanisms, and lessons learned, the comparative legal method is used for comparison with current Vietnamese legal regulations. On this basis, this study proposes a number of solutions suitable for the legal and social contexts of Vietnam.

Some Theoretical Issues on Sexual Seduction

Definition of “Sexual Seduction”

The term “grooming” or “sexual grooming” is being used by many experts and scholars around the world to refer to the act or series of acts of seducing and soliciting minors for sexual abuse. In addition, the legal systems of many countries today have also set out sanctions for the subjects who commit this act, including criminal sanctions.

There is currently no exact conclusion about the first time that “grooming” was used as a term referring to a form of sexual offense. According to some studies, the earliest time it was used in this sense may be from the 1970s to the 1980s. One of the most widely referenced and cited studies is that of Kenneth Lanning, a former agent of the US Federal Bureau of Investigation (FBI), who claimed that the term was first used by a group of law enforcement investigators in the US in the late 1970s (Lanning, 2017, p. 5). In addition, Kenneth Lanning is also recognized by some experts as one of the first people to use the term “grooming” in the 1970s (Burgess & Hartman, 2018, p. 22). Later, research on “sexual grooming” grew stronger, especially since the 2000s (Winterset al., 2021, p. 926).

Despite advances in awareness and research, there is currently no official legal or social definition of “sexual grooming.” Many definitions have been proposed, but none have been widely accepted.

Based on a review of some typical definitions as well as the analysis of scholars, the author finds that a correct definition of the type of behavior of seducing minors for sexual abuse should pay attention to the following factors:

First, it is not advisable to set a too specific limit on the type of subject performing it because it can lead to deviations or reduce the generality of the definition.

Second, the definition should clearly indicate that seduction for sexual purposes can include one act or a series of acts, but all of them are of a seduction nature.

Third, the element of consent and voluntariness of the victim after being influenced by the seduction should not be included in the definition, because this can lead to the inaccuracy of the definition.

Fourth, the purpose of the seduction should be fully expressed in the definition. In some definitions mentioned earlier, such as “sexual grooming […] is the steps that pedophiles take to trap their victims and, in a way, resemble the flirting between adults” (Howitt, 1995, p. 176), the purpose of sexual abuse is not expressed or is expressed but is still vague and unclear.

Based on the understanding of the concepts of experts and scholars, the author proposes the following definition: Sexual grooming is an act or a series of acts that are meant to seduce minors to facilitate sexual abuse of minors, while avoiding the possibility of being detected for committing such abuse.

Characteristics of Sexual Seduction Behavior

From the above definition, we can see some characteristics of sexual seduction behavior, including:

First, it is an act or a series of acts of seduction. Accordingly, the acts performed can be very diverse and different depending on the type of subject performing, the type of victim, and the surrounding environmental conditions, but they are all acts of enticing and soliciting victims of a non-violent nature.

Second, the subject performing can be any adult. According to the laws of many countries in the world, including Vietnam, an adult is a person aged 18 or older.

Third, the subject of the seduction behavior is a minor. The age to determine a minor is different according to the regulations of each country.

Fourth, the purpose of seduction includes: (1) facilitating the sexual abuse of minors and (2) avoiding the risk of being discovered. Here, some scholars also believe that seduction has three main purposes: (i) reducing the victim’s resistance during the sexual abuse, (ii) facilitating the recurrence of sexual abuse in the future, (iii) minimizing the risk of being discovered after committing the sexual abuse (Winterset al., 2021, p. 6).

Regulations of Some Southeast Asian Countries on Sexual Seduction

The legal systems of many countries in the world, such as the UK, the United States, and Australia, have regulated the act of sexual seduction, even criminalizing this act in criminal law. In the Southeast Asian region, currently, only four countries in the Association of Southeast Asian Nations (ASEAN), namely Brunei, Malaysia, the Philippines, and Singapore, have criminalized the act of sexual seduction.

In Singapore, the crime of sexual grooming of a person under 16 years of age is regulated in Section 376E of the Penal Code (Penal Code (Cap. 224). (Revised 2019), 2019). In addition, Section 376AE also regulates the crime of sexual grooming of a person over 16 but under 18 years of age (“Exploitative sexual grooming of a minor of or above 16 but below 18 years of age”), with provisions essentially similar to those in Section 376A. Offenders under this article may be imprisoned for up to three years, fined, or both.

In Brunei, Section 377G of the Penal Code (Penal Code (Cap. 22), 1951) regulates the crime of sexual grooming of a person under 16 years of age (“Sexual grooming of person under 16”).

In Malaysia, Part III of the Sexual Offences Against Children Act 2017 (Sexual Offences Against Children Act 2017 (Act 792), 2017) includes provisions related to the grooming of children for sexual abuse. Specifically, it includes Section 11 (“Sexual communication with a child”), Section 12 (“Child grooming”), and Section 13 (“Meeting following child grooming”).

In the Philippines, Republic Act No. 11930 (Republic Act No. 11930, 2022) defines “grooming,” i.e., solicitation for sexual purposes, as illegal and establishes corresponding penalties. Notably, this Act provides a definition of “grooming” and distinguishes between “grooming” and “luring.”

It can be seen that the act of solicitation for sexual purposes has been criminalized in the criminal law in Singapore, Malaysia, the Philippines, and Brunei. The provisions on the crime of solicitation in the above countries also have many things in common, such as regulating acts such as communicating, traveling to meet, or meeting the victim, even if the sexual abuse has not yet been committed but only for the purpose of committing these abuses, can also constitute a crime; or the offender must be an adult, while the age of the victim can have many different thresholds but are all minors (under 18 years old). Regarding the issue of punishment, some countries also set different penalty frameworks when the victim is under different age thresholds. For example, Singapore stipulates that the highest penalty for offenders against children under 16 years old is three years in prison, but if the victim is under 14 years old, the prison sentence can be up to four years. Malaysia also divides criminal acts into different levels, and each act has different penalty frameworks.

Some outstanding points in the laws of the above countries can be mentioned as the expansion of jurisdiction to handle acts of seduction for sexual purposes that occur not only within the country but also outside the national territory. For example, Section 376E of the Penal Code (Penal Code (Cap. 224). (Revised 2019), 2019) provides that Singaporean authorities have jurisdiction regardless of whether the meeting or communication occurs inside or outside the country. Brunei’s law also has similar content. The regulation of sexual solicitation through online platforms (for example, Malaysia’s law refers to communicating with the victim through any means, including network-based means, and the Philippines’ law refers to connecting with the victim through electronic devices and similar devices) is also a bright spot because it creates the basis for responding to the challenges of the new era, when crimes no longer stop in real life but also occur in cyberspace with increasingly sophisticated concealment methods.

Some Recommendations to Handle the Act of Seduction for Sexual Purposes in Vietnam

Current Vietnamese law does not have direct regulations on the seduction of minors for sexual abuse; however, this act is still regulated indirectly, and the subject of the act can still be held legally responsible, including criminal responsibility.

In the Penal Code No. 100/2015/QH13 (amended by Law No. 12/2017/QH14) (2015) (Vietnam), the act of seduction for sexual purposes is indirectly regulated in several articles. For example, Article 141 on the crime of rape stipulates that “anyone who uses […] other tricks to have sexual intercourse or perform sexual acts against the will of the victim” may be imprisoned from two to seven years. If the victim is between 13 and 16 years old, the offender may be sentenced to imprisonment from seven to fifteen years under Article 142 (Penal Code No. 100/2015/QH13 (Vietnam), 2015/2017).

Article 146 provides for the crime of indecent assault against a person under 16 years old: “anyone who is 18 years of age or older and commits an indecent act against a person under 16 years of age without the purpose of sexual intercourse or without the purpose of performing other sexual acts shall be imprisoned from six months to three years” (Penal Code No. 100/2015/QH13 (Vietnam), 2015/2017). Indecent acts involving physical contact may result from a prior seduction process, in which the offender befriends the victim and gradually reduces their resistance, leading to normalization of sexual behavior and facilitating abuse.

Similarly, Article 144 on the crime of rape of persons aged 13 to under 16 stipulates that “anyone who uses any means to force a person aged 13 to under 16 who is in a state of dependence on him or her […] to have sexual intercourse or to perform other sexual acts against his or her will shall be sentenced to between five and ten years in prison” (Penal Code No. 100/2015/QH13 (Vietnam), 2015/2017). This provision can be applied to address the act of seducing a minor for sexual abuse, particularly when the offender is an acquaintance or relative of the victim (Que, 2021).

Therefore, if the behavior of the offender only stops at seduction and solicitation but has not actually performed sexual intercourse or other sexual acts in reality, it is difficult to constitute a crime and be prosecuted for criminal liability according to the provisions of the criminal code. However, early handling of sexual seduction is necessary because it can immediately prevent unfortunate consequences that may happen to minors, who are vulnerable in society.

Seducing children for sexual abuse is very common, especially when seduction in the cyberspace environment (online seduction) is increasing. According to Disrupting Harm in Viet Nam: Evidence on Online Child Sexual Exploitation and Abuse (ECPATet al., 2022, p. 7), one of the three most common online child sexual abuse behaviors is the act of promising money or gifts to entice children to participate in sexual activities. Among the 994 Vietnamese children (aged 12 to 17) surveyed, 1.9% had received unwanted requests related to sexual talk or sexual behavior; 0.5% had received requests to send photos or videos of their private parts when they did not want to; 0.2% had received offers of money or gifts in exchange for sensitive photos or videos of children; and 0.3% had received offers for money or gifts to meet someone in person and perform sexual acts (ECPATet al., 2022, pp. 49–50).

Recently, the Ministry of Public Security has issued a warning about bad individuals taking advantage of online platforms (including social networks such as Facebook, Zalo, and Instagram, online dating applications, and online games such as Lien Quan Mobile, PUBG, and Free Fire) to approach and text to get acquainted with children by sharing topics about studying and hobbies. After a while, they switch from these topics to topics about gender and sex and entice children to watch pornographic movies and images; they then entice them to film and take pornographic images of themselves.

Seducing children for sexual abuse is common in society. Even in the family environment, minors are easily seduced by acquaintances who are difficult to detect, especially when some traditional cultural features of Vietnamese people may have unintentionally created favorable conditions for the abuser.

To promptly detect and handle acts of seduction by subjects intending to sexually abuse minors, thereby preventing the risk of minors being sexually abused early, Vietnamese law needs to supplement regulations on identifying and handling this type of behavior. First, a clear definition of seduction for sexual purposes should be given, creating conditions for people and competent authorities to correctly identify the behavior.

Next, it is necessary to clearly stipulate sanctions for the subjects who commit this act, allowing investigative agencies to intervene promptly when there is clear evidence of seduction of minors before sexual abuse actually occurs. These sanctions can be administrative or criminal; however, according to the experience of the above countries, the act of seducing minors for sexual purposes should be criminalized in the provisions of the Penal Code because of the danger to society when this act can lead to the consequence of minors being sexually abused, even abused for a long time that is difficult to detect. In addition, the fact that the person who commits the seduction can be prosecuted will create a stronger deterrent for individuals in society, and at the same time demonstrate the state’s determination in the fight to protect minors from sexual abuse.

On the other hand, the state also needs to tighten regulations on network security and strictly handle violations in cyberspace to ensure the cleanliness and health of the online environment, which is developing rapidly in the current digital age.

Discussion, Limitations, and Future Directions

Discussion

It highlights that the criminalization of sexual grooming in ASEAN countries reflects a proactive and preventive approach to child protection. Table I suggests that Singapore and Malaysia, for instance, have expanded their legal jurisdiction to address both online and extraterritorial grooming, offering a model that Vietnam could consider when reforming its own legislation. However, the adoption of similar provisions in Vietnam must take into account socio-cultural realities, including strong family-based trust norms, the persistent stigma associated with reporting sexual abuse, and relatively limited levels of digital literacy among children and caregivers. Moreover, Vietnam’s legal framework would benefit from enhanced inter-agency cooperation among law enforcement, educational institutions, and social support services to ensure early detection and intervention in grooming cases. Public awareness and community-based education campaigns are also essential in reducing social silence, encouraging reporting, and preventing the normalization of inappropriate or manipulative online interactions (Table I).

Table I. Comparative Overview of ASEAN Regulations on Sexual Grooming

Country	Legal instrument	Victim’s age	Maximum penalty
Singapore	Penal Code (1871, amended 2019), Articles 376E & 376AE	Under 18	Up to 3 years imprisonment or fine
Malaysia	Act 792–Sexual Offences Against Children Act 2017	Under 18	Up to 10 years imprisonment or fine
Philippines	Republic Act No. 11930 (2022)	Under 18	Up to 12 years imprisonment
Brunei	Penal Code (Cap. 22) (1951), Article 377G	Under 16	Up to 7 years imprisonment

Limitations and Future Directions

This study primarily relies on secondary legal sources and comparative analysis of statutory documents. It does not include empirical data, such as expert interviews or case law analysis, to validate the identified legal gaps in Vietnam. Future research should integrate field data and stakeholder perspectives to assess implementation feasibility. Additionally, combining legal analysis with psychological and sociological studies could deepen understanding of grooming dynamics and strengthen multidisciplinary prevention strategies.

Conclusion

In researching the issue of seduction of minors for sexual abuse, it is necessary to determine a scientific approach, define seduction for sexual purposes, and clarify the point of seduction for sexual purposes. These theoretical issues are necessary, creating a consensus on the understanding and correct orientation of the research process, and at the same time serving as a basis for people and competent authorities to correctly identify the behavior. Seduction for sexual purposes has been criminalized in some Southeast Asian countries, such as Singapore, Malaysia, the Philippines, and Brunei, through criminal law. Regulations in the legal system and sanctions for those who commit seduction have had positive effects in preventing and combating sexual abuse of minors.

To promptly detect and handle acts of seduction by subjects intending to sexually abuse minors, thereby preventing the risk of minors being sexually abused early, Vietnamese law needs to supplement regulations on identifying and handling this type of behavior. It is necessary to clearly stipulate sanctions for the subjects committing the behavior, allowing investigative agencies to promptly intervene as soon as there is clear evidence of seduction of minors before sexual abuse actually takes place. At the same time, the state also needs to tighten regulations on network security, strictly handling violations in cyberspace to ensure the cleanliness and health of the online environment, which is developing rapidly in the current digital age.

Conflict of Interest

The authors declare that there are no conflicts of interest regarding the publication of this paper.