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Did a bit more research on this.
It looks like the answers is no. HOWEVER, that gigantic fucking patch we all got a few days ago -was- the Vietnam DLC. Purchasing the DLC, in this case, is actually just purchasing a redeemable code that unlocks the software, and you can buy that shit in the EA Store.
Did a bit more looking, and finally found an intelligent person with a good set of answers:
Edit: Updated with info regarding gifted Vietnam
There seems to be some confusion regarding purchasing Vietnam. I hope this clears things up.
Any stores that "sell BC2 Vietnam", sell a 16-digit code. This code can be entered into the BC2 game client - any version of the game client. Entering this code unlocks Vietnam for that EA account. No additional download is necessary.
Here are some typical scenarios:
You have bought the base game on Steam, and Vietnam on Steam - this works. You will see Vietnam listed in your Steam client.
You have bought the base game on Steam, and someone gifts you Vietnam on Steam - this works. You will see Vietnam listed in your Steam client.
You have bought the base game on Steam, and Vietnam somewhere else - this works. The Vietnam expansion will not be visible in the Steam client, but you can access it in-game.
You have bought the base game somewhere else, and Vietnam somewhere else - this works.
You have bought the base game somewhere else, and Vietnam on Steam - this is not possible, because Steam will not sell Vietnam to someone who does not have the base game on Steam.
[Initially, it was possible to make this specific purchase - but Steam changed that fairly quickly.]
If you somehow did manage to make such a purchase, please contact Steam support to resolve this.
You have bought the base game on Steam, and someone has gifted you Vietnam on Steam - this works. You will also see Vietnam listed in your Steam client.
You have bought the base game somewhere else, and someone has gifted you Vietnam on Steam - well... Long story. The gifting will succeed. Steam will know that you have Vietnam, but you will not see it in the Steam client because you do not have the base game. Therefore you will not be able to view the 16-digit code for Vietnam. Contact Steam support to resolve this.
We have been in contact with Steam, and their support department is aware of the above.
The "Vietnam" menu in BC2 will say 'go buy the expansion' until Dec 18th. (It will still say so after you have bought the expansion.) After the 18th, the dialog will change to one where you are asked to enter your code.