Executive Summary: Evaluation Report on Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Measures in Macao, China
The evaluation report provides an assessment of the current state of AML/CFT measures in Macao, China. The report highlights key areas for improvement and provides recommendations to enhance the effectiveness of these measures.
Risk Assessment: Understanding Money Laundering Risks
- National Risk Assessment (NRA): Provides a sound understanding of money laundering (ML) risks.
- Private Sector Understanding: Needs improvement, particularly for:
- Junket promoters
- Dealers of precious stones and metals
The report emphasizes the importance of improving private sector understanding of ML risks to effectively address these threats.
Supervision and Enforcement: Enhanced Procedures and Guidance
- Supervisory Authorities: Have enhanced procedures and guidance in place.
- LEA Investigations: Do not match the risk profile, highlighting a need for improvement.
The report highlights the importance of enhancing LEA investigations to match the risk profile and increase their effectiveness.
Financial Intelligence and Investigations: Multi-Source Information and Sound Analysis
- GIF’s Use of Multi-Source Information: Results in a high number of financial intelligence disseminations opened for investigation.
- Interpretation of Intelligence Value: Gaps exist in officers’ ability to interpret intelligence value and use GIF information in predicate investigations.
The report emphasizes the need to improve the interpretation of intelligence value and enhance the use of GIF information in predicate investigations.
Prosecutions and Confiscation: Low Conviction Rate and Heavy Evidentiary Requirements
- Convictions: Only five ML convictions since 2017, with a low average sentence length.
- Prosecutorial Resources: Shortage of resources hampers quantity and quality of ML investigations and prosecutions.
- Heavy Evidentiary Requirements: Limit the effectiveness of prosecutorial efforts.
The report highlights the need to strengthen prosecutorial resources and improve evidence collection for predicate offences.
Key Recommendations
- Improve private sector understanding of ML risks
- Enhance LEA investigations to match the risk profile
- Increase cooperation among GIF, supervisors, and LEA
- Develop a comprehensive policy directive for LEA to adopt a risk-based approach for ML investigations
- Strengthen prosecutorial resources and improve evidence collection for predicate offences
Conclusion
The report provides a critical assessment of AML/CFT measures in Macao, China, highlighting areas for improvement and providing recommendations for enhancing effectiveness. By addressing these gaps, the territory can strengthen its ability to prevent money laundering and counter terrorist financing.