Financial Crime World

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Macau’s Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Measures: A Report by the Asia-Pacific Group on Money Laundering (APG)

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Executive Summary

Macau has made progress in implementing anti-money laundering (AML) and counter-terrorist financing (CFT) measures, but there are still gaps and weaknesses. The risk-based approach to assessing money laundering risks is sound, but needs improvement for certain sectors.

Key Findings:

  • Macau has made progress in implementing AML/CFT measures
  • Risk-based approach to assessing money laundering risks needs improvement for certain sectors
  • Supervisory authorities have enhanced procedures and guidance, but operational shortcomings hinder effective implementation

Financial Intelligence and ML Investigations

Macau’s Financial Intelligence Unit (GIF) has access to a large range of intelligence-rich information and uses multi-source information and sound analysis. However, there are gaps in the ability of officers to interpret the intelligence value and use of GIF information in predicate investigations.

Key Findings:

  • Macau’s GIF has access to a large range of intelligence-rich information
  • Officers have difficulty interpreting the intelligence value and using GIF information in predicate investigations
  • Lack of a cross-border disclosure or declaration system is a major intelligence gap

Coordination Measures

Coordination measures have proven effective for strengthening policy, developing annual plans, and raising AML/CFT awareness among agencies. However, coordination between GIF, law enforcement agencies (LEA), and supervisors is still limited in certain areas.

Key Findings:

  • Coordination measures have been effective in strengthening policy and developing annual plans
  • Coordination between GIF, LEA, and supervisors is still limited in certain areas

Prosecutions and Confiscation

There have been some major successes with domestic corruption-related self-laundering cases, but the quantity and quality of ML investigations and prosecutions are low. The lack of an adequate policy directive and difficulty in obtaining evidence on predicate offenses from foreign counterparts have hampered ML investigations and prosecutions.

Key Findings:

  • There have been some major successes with domestic corruption-related self-laundering cases
  • Quantity and quality of ML investigations and prosecutions are low

Recommendations

The report provides several recommendations to address the gaps and weaknesses identified, including:

Improving the Risk-Based Approach for Assessing ML Risks

  • Improve the risk-based approach for assessing money laundering risks
  • Enhance operational capacity and coordination between GIF, LEA, and supervisors
  • Strengthen cooperation and information exchange among agencies
  • Develop a cross-border disclosure or declaration system
  • Provide additional resources to support GIF’s expanded roles