The Monetary Authority of Macau (AMCM) prepared new
guidelines for additional due diligence and control by the
banks operating in Macau over customers that engage in
transactions that may be connected to gaming activities.
Effective from the end of August, Circular No.
011/B/2019-DSB/AMCM supplements the Anti-Money Laundering (AML)
and Combating the Financing of Terrorism (CFT) Guideline, as
well as the Industry Guidance on AML/CFT Controls, both issued
by AMCM. As expressly announced, these rules are 'in addition
to the enhanced due diligence and ongoing monitoring measures
over the Macau gaming concessionaires/sub-concessionaires and
licensed junket promoters'.
Banks are required to have clear rules on which
gaming-related customers (as defined on Instruction no. 1/2006
of the Macau Gaming Inspection and Coordination Bureau
– DICJ) may or may not be accepted for business, and,
in the affirmative, shall ensure such customers are duly
licensed by DICJ and have a robust AML/CFT framework and
adequate manpower to implement it.
Banks are expressly prohibited from taking business of
overseas gaming operators, or their related companies and
junket promoters, regarding movement of funds for gaming
Customer due diligence duties are more significant, in
particular regarding the assessment of the purposes of the
accounts (e.g. incoming funds from patrons for gaming in Macau,
repayment of casino markers or other expenses, etc.) and of the
ultimate beneficiaries of the transactions, and where banks
have to rely on information provided by third parties, these
shall be accountable for it and keep respective records in
AMCM requires banks to keep an eye on all transactions
performed by these customers and to have proper monitoring and
reporting systems in place. They must also have proper measures
in place enabling them to terminate banking services in case
suspicious activities are found.
Legacy customers are not exempted from these checks and
monitoring, and banks are requested to review all relationships
previously established with any such customers.