Macao has obtained a substantial rating in the Asia Pacific Group on Money Laundering (APG) Mutual Evaluation Report (MER) 2017 regarding the effectiveness of supervision, which is not a common achievement among jurisdictions worldwide being evaluated. According to the MER 2017, licensing controls are robust in the Macao gaming sector for both concessionaires/sub-concessionaires and junket promoters. Macao SAR Government is taking a more stringent approach towards licensing and the supervision of junket promoters which are also subject to enforceable AML/CFT requirements. The MER also states that Macao SAR Government has applied AML/CFT measures, including licensing and fit and proper test requirements to include junket promoters and their formal collaborators.
In future, the Macao SAR Government will continue to improve and strengthen the supervision on the gaming sector, and require its continuous attention to and compliance with the international standards of anti-money laundering and counter-financing of terrorism so as to ensure the development of the sector with integrity and quality.
The MER also states that Macao has applied AML/CFT measures, including licensing and fit and proper test requirements to include junket promoters and their formal collaborators. This is a necessary response to the inherent risks of the sector, and of the reliance of concessionaires/sub-concessionaires on junket promoters to undertake preliminary CDD and introduce business. Under the current regime, the Macao SAR Government has set up a double-scrutiny system for the market entry of junket promoters, in which the DICJ undertakes separate market entry/licensing requirements for junket promoters and their formal collaborators, in addition to the due diligence undertaken by concessionaires/sub-concessionaires before entering into a business relationship with junket promoters.
DICJ also updated its AML/CFT Guideline and became effective from May 2016. The updated AML/CFT Guideline introduced some key changes from the previous AML/CFT Guideline issued in 2006.
In addition, DICJ provides industry training once every year to the gaming sector with a thematic topic/objective. Training provided by DICJ has addressed AML/CFT requirements and ML typologies in the casino sector, large transactions reporting requirements, an overview of the risk assessment, and an explanatory session on the 2016 updated AML/CFT Guideline. The training provided has been directed at the concessionaries, sub-concessionaries, and junket promoters. AML/CFT obligations contained in the updated DICJ AML/CFT Guideline and understanding of ML/TF risks are well understood by the concessionaries and sub-concessionaries. Nevertheless, the Macao SAR Government acknowledge that the understanding of the updated AML/CFT obligations and ML/TF risks in the junket promoter sector could be further improved.
The MER highlights the facts that The DICJ has a designated AML/CFT audit team which is experienced and suitably qualified. The quality of the AML/CFT audits reviewed during the evaluation was robust.
DICJ has had a risk-based approach since 2007. All on-site inspections or off-site inspections carried out by DICJ are based on the audit procedures manual developed by DICJ in 2007, such that DICJ must carry out audit procedures based on a risk assessment model that comprised of both internal controls and legal compliance criteria.