Macao SAR: Further AML / CFT control for gaming-related people

Author: IFLR Correspondent | Published: 5 Dec 2019
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Riquito Advogados

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Suite 1004 AIA Tower, 251A-301 Av. Comercial de Macau
Macau SAR

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+853 2838 9918

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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 activities abroad.

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 proper order.

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.

João Nuno
Riquito
Bruno Almeida