2014
Annual Report
TABLE OF CONTENTS
TABLE OF CONTENTS
CHAPTER I INTRODUCTION108
CHAPTER II BACKGROUND AND ORGANIZATION STRUCTURE111
2.1 Organization Background
111
2.2 GIF’s Organization Structure and Functions
111
2.3 Duties of GIF113
2.4 Human Resources of GIF115
CHAPTER III TREND AND DEVELOPMENT OF SUSPICIOUS
TRANSACTION REPORTS (STRs)116
3.1 Statistical Data
116
3.2 Statistics on Recent Trends of Suspicious Transactions
119
CHAPTER IV ANTI-MONEY LAUNDERING AND COUNTER
TERRORIST FINANCING IN MACAO SAR121
4.1 Coordination of the Interdepartmental AML Working Group
121
4.2 Follow-up of APG/GIFCS Joint Mutual Evaluation and Preparation
for the Next Round of Mutual Evaluation
124
4.2.1 National Risk Assessment124
4.2.2 Revision of Legislation126
4.2.3 Policy Development Studies127
4.3 Participation in International Organizations activities
129
4.3.1 Hosting of APG Annual Meeting129
4.3.2 Chairing of the Mutual Evaluation Working Group of the APG130
4.3.3 Participation in Mutual Evaluations131
4.4 International Cooperation
131
4.5 Cooperation among Government Agencies
132
4.6 Attending International Conferences
134
4.7 Public Awareness
138
4.7.1 Training138
4.7.2 Website148
4.7.3 Publications148
4.8 Courtesy Visit from/to Other Entities
149
CHAPTER V ADMINISTRATION151
5.1 Means of STR Submission
151
5.2 Enhanced Documentary Security and Case Management
152
CHAPTER VI CHALLENGES AND PROSPECTS153
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CHAPTER I INTRODUCTION
CHAPTER I INTRODUCTION
For the Financial Intelligence Office (GIF), 2014 has been a year full of challenges and
achievements.
The views on whether the world economy has regained momentum in 2014 have been mixed.
The economy of the US has shown more convincing signs of recovery compared with previous
years, which could be followed by the kickoff of the interest rise cycle. However, the US alone
could not pull the world economy into new prosperity, as demonstrated by the weak performances
of Europe and Japan which had to be boosted by expansionary policies with uncertain outcome.
For China, the government has been cautious in controlling the inflation and yet preventing the
economy going into a contraction. Nevertheless, it was still able to maintain a GDP growth of 7.4%
in the 4th quarter of the year1, which is still an outstanding figure.
However, in 2014 Macao started to see a decline in GDP growth of -0.4%2 compared to the
14.3% growth of 2013, driven by the fall in export of services growth dominated by the gaming
industry. Macao experienced its first decline in monthly gross gaming revenue seven months in a row
since 2008, which led to a negative growth of 2014 gross gaming revenue of 2.6%3 compared with
2013. Nevertheless, the strong gaming revenue in the first half of the year, together with the growth
in investments, has supported the economy and contributed to the GDP of 2014. Yet Macao must be
prepared for a period of slower growth in economy, which hopefully will stabilize in mid-2015.
1 National Bureau of Statistics of China,
http://data.stats.gov.cn/english/easyquery.htm?cn=B01
2 Statistics and Census Service, Macao SAR Government,
http://www.dsec.gov.mo/Statistic.aspx?lang=en-US&NodeGuid=b35edb8a-ed5c-4fab-b741-c91b75add059
3 Gaming Inspection and Coordination Bureau,
http://www.dicj.gov.mo/web/en/information/DadosEstat_mensal/2014/index.html
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CHAPTER I INTRODUCTION
Despite a general slowdown of the world economy, quick and colossal flows of funds have
never stopped, and experience shows that risks of economic crimes always increase with the
degree of economic downturn. On the other hand, in 2014 the threats of terrorism have become
more imminent in the world, with the rise of extremist groups and an evolution of the form in which
terrorist attacks are perpetrated with violent actions of individuals rather than groups which makes
them harder to track. International organizations against money laundering and terrorism have
always heeded such trends closely and initiated immediate actions. These are reflected in the
revised anti-money laundering and counter-financing of terrorism (AML/CFT) recommendations
and the issues of updated guidance papers, which must be closely followed by member countries.
As a member of the world economy and a free port, Macao also has the responsibility to follow suit
such recommendations and best practices to mitigate the risks.
Regardless of the changes in the economic situation, GIF has closely followed its plan
in enhancing the local AML/CFT system and preparing for the upcoming Asia/Pacific Group on
Money Laundering (APG) mutual evaluation. A major progress made in 2014 was the National Risk
Assessment (NRA) project. GIF, with the support of Macao Special Administrative Region (Macao
SAR) Government, has worked closely and diligently with members of the cross-departmental AML
Working Group (which was established via Order of the Chief Executive in January 2014) and an
external consultant to set up the risk assessment framework after numerous studies, visits and
discussion. Despite the difficulties encountered during the process, all member agencies involved
in the assessment process have gained valuable experience and enhanced their communication
and data collection mechanisms, which form the basis of the proof of effectiveness of the AML/
CFT system. With the completion of the framework, the second phase of the NRA project
commenced immediately at the end of 2014 with the actual collection of data by different agencies.
The collection and analysis of supervision and private sector data will contribute to a detailed
assessment of the AML situation of Macao, which has never been conducted before.
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CHAPTER I INTRODUCTION
Another major achievement of GIF in 2014 is the completion of the drafting work of AML
Law Revision, which incorporates new measures recommended in the APG Mutual Evaluation
Report of 2007 and revised Financial Action Task Force (FATF) Standards. At the same time, with
the assistance of Law Reform and International Law Bureau (DSRJDI), the drafting of the law on
freezing of terrorist assets has also come to the final stage.
Apart from these important projects, GIF always takes the training to public and private
sectors seriously and a number of seminars, workshops and courses have been conducted in the
past year to raise the overall AML standard of Macao as a whole. A major breakthrough in this year
is the successful cooperation with Law and Judicial Training Centre (CFJJ) in inviting prosecution
experts from Portugal and Hong Kong to share their money laundering crime prosecution
experience with local judicial and law enforcement entities. Another major event was the hosting
of the APG Annual Meeting in Macao. Details of the projects and work above can be found in the
upcoming chapters of this annual report.
For all the accomplishments above in 2014, GIF would like to express its heartfelt gratitude
to the Macao SAR Government, in particular to the Secretary of Economy and Finance and his
Office for their continuous support throughout the previous years. Contributions from the team of
GIF during 2014 would never be understated. At the same time we have to thank the members
of the Inter-departmental AML Working Group, including the supervisory, law enforcement and
judicial agencies who have been working very hard in the past year to build a more effective AML
system for Macao. With the end of 2014, 2015 marks the year of the new Macao SAR Government
and under the leadership of Mr. Leong Vai Tac, our new Secretary, GIF will strive to make further
progress in fulfilling its duties.
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CHAPTER II BACKGROUND AND ORGANIZATION STRUCTURE
CHAPTER II BACKGROUND AND
ORGANIZATION STRUCTURE
2.1 Organization Background
GIF was established on 8th August 2006 under Executive Ruling no. 227/2006 with the
primary role of collecting, analyzing and disseminating information on suspicious transactions of
money laundering and terrorist financing. It was established for coping with the implementation of
Law no. 2/2006 and Law no. 3/2006 on Prevention and Repression of Crimes of Money Laundering
and Prevention and Repression of Crimes of Terrorism.
Under Executive Ruling no. 227/2006, GIF was set up in the form of a project entity with a term
of three years that could be extended under the order of the Chief Executive. The mandate of GIF
was extended in May 2012 for three years until 7th August 2015 by Executive Ruling no. 80/2012.
2.2 GIF’s Organization Structure and Functions
Director/
Deputy Director
Legal
Counsel
Policy and
Compliance
STR Technical
IT Support
Administration and
General Affairs
Collection and
Analysis of STR
Statistics and
Typologies
Training and Public
Awareness
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CHAPTER II BACKGROUND AND ORGANIZATION STRUCTURE
The core function of GIF is to collect, analyze and disseminate relevant information to law
enforcement agencies, judicial authorities or other entities vested with the authority to prevent and
suppress crimes relating to money laundering or terrorist financing. In exercising such duties, GIF
is granted with the following specific competence:
• To receive information provided by different entities and to establish and maintain a
database with such information;
• To analyze the information received and report the suspicious money laundering activities
to the Public Prosecutions Office (MP);
• To provide assistance to law enforcement agencies, judicial authorities and other
entities empowered to prevent and suppress money laundering and terrorist financing
crimes, based on their requests with stated legitimate reasons, particularly in the form of
information sharing and technical support;
• To provide to and receive from entities external to the Macao SAR information about money
laundering and terrorist financing crimes, under authority of any inter-regional agreements
or any other international law instruments;
• To collaborate with public entities to establish and revise anti-money laundering and
counter-terrorist financing guidelines; and
• To develop promotional and educational programs for public awareness about AML/CFT.
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CHAPTER II BACKGROUND AND ORGANIZATION STRUCTURE
2.3 Duties of GIF
The Director takes on the leadership, coordination and management responsibilities so as
to fulfill the duties stipulated in paragraph 2 of Article 8 of Law no. 2/2006, Article 11 of Law no.
3/2006, and Executive Ruling no. 227/2006.
The duties of GIF are categorized into 4 main areas: Policy and Compliance, Suspicious
Transaction Reports (STRs) Collection and Analysis, Statistics/Typologies and Training and Public
Awareness. Such duties are performed with the support of the following three teams of back office
staff: Legal Counsel, IT Support and Administration and General Affairs.
Policy and Compliance
GIF has the duty to keep track of international developments and update the information
on international standards, laws and conventions. It liaises on continual basis with international
bodies such as FATF, APG, and the Egmont Group, and answers assessment questionnaires
and enquiries of the same nature. Domestically GIF follows up with the change in local laws and
recommends new measures for keeping abreast with the latest developments.
STRs Collection and Analysis
GIF is responsible for collecting and analyzing STRs submitted by different reporting entities
as well as inputting data collected through these STRs into the database. All incoming reports will
be verified to ensure all data is properly filled in and a first feedback will be sent to the reporting
entity accordingly. The initial feedback will be followed by subsequent follow-up replies if deemed
necessary. At the same time analysis will be carried out, including data matching against existing
records and intelligence provided by local law enforcement and foreign counterparts. GIF has been
granted the authority to request additional information from reporting entities, if necessary, for indepth analysis on any case, and to propose reported cases deemed suspicious to the MP.
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CHAPTER II BACKGROUND AND ORGANIZATION STRUCTURE
Statistics/Typologies
GIF has to extract statistical data periodically from received STRs, as well as providing
instructive information such as trends and typologies to the supervisory agencies and reporting
entities. Analysis reports on typologies and transaction types will be prepared for internal and
cross-departmental reference, and these reports may serve as insights for further policy review.
Training and Public Awareness
To arrange training and public awareness programs on AML/CFT is one of GIF’ s important
responsibilities. For this reason, GIF needs to search for suitable training resources provided
by international bodies, arrange local courses by inviting experts from abroad, and take part
in seminars and workshops overseas. At the same time, promotional campaigns by means of
brochures, newspaper articles and advertisements in mass media are necessary to raise public
awareness about the importance of AML/CFT.
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CHAPTER II BACKGROUND AND ORGANIZATION STRUCTURE
2.4 Human Resources of GIF
The overall manpower of GIF remained stable in the past four years and the human
resources structure of GIF is as follows:
Year
2011
2012
2013
2014
Director
1
1
1
1
Legal Counsel
1
1
1
1
STR-Technical
12
12
12
13
STR-Administration
4
4
3
3
IT Support
5
5
5
5
Administration
and General Affairs
14
13
14
13
Total
37
36
36
36
In 2014, one new staff member was recruited in the area of STR Technical section, while one
staff member in the Administrative and General Affairs section has left. The overall head count of
GIF has remained unchanged. As shown from the constant number of staff in the past few years,
staff of different sections accumulated more experience from their work and performed more
efficiently, which ultimately adds value to GIF.
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CHAPTER III TREND AND DEVELOPMENT OFSUSPICIOUS TRANSACTION REPORTS (STRs)
CHAPTER III TREND AND DEVELOPMENT OF
SUSPICIOUS TRANSACTION REPORTS (STRs)
3.1 Statistical Data
GIF continues to carry out its duties as provided under Executive Ruling no. 227/2006 to
perform strategic analysis on STRs received. In comparison with the same figure of the previous
year, there has been an increase of 14% in total number of STRs reported. The increment of STRs
reflects the continual improvement of AML/CFT awareness among industries, in particular the
gaming sector.
The total number of STRs received and their variances are as follows:
Year
Number of STRs
Variance
2007
725
+34%
2008
838
+16%
2009
1,156
+38%
2010
1,220
+6%
2011
1,563
+28%
2012
1,840
+18%
2013
1,595
-13%
2014
1,812
+14%
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CHAPTER III TREND AND DEVELOPMENT OFSUSPICIOUS TRANSACTION REPORTS (STRs)
Among all STRs received in 2014, the gaming sector submitted 1,370 reports which
accounted for over 75% of the annual submissions. The financial sector on the other hand
submitted 441 reports to GIF. The gaming sector has the major growth momentum in terms of
reporting. The number of STRs related to the gaming sector has increased by 20.4% as compared
with the figure of 2013. The major reason for the increase is due to the adoption of a new policy
by several gaming concessionaires on customer due diligence as well as a better control of funds
transfers. The submission of STRs without identity details of subjects continued to decline and this
phenomenon is consistent with the tendency of the previous year. The number of STRs submitted
by the financial sector has slightly decreased by 3.5% to a total of 441 as compared with that of last
year. Despite such small drop, the overall quality of STRs has improved as shown by the reduction
in defensive reporting which is replaced by reporting supported by more details. Statistical
information relating to the number of STRs received in 2014 is given in Table 1 & Chart 1.
Table 1: Statistical data of STRs received in 2014
Reporting Entity
Number
of STRs
Reporting
Entity
Financial
Institutions*
Number of STRs
Variance (%)
20072008200920102011201220132014
'13 vs '14
343386382338477510457441 -3.5%
Games of
Fortune Operators
374 443 767 814 1,0821,3281,1381,370 +20.4%
Other Institutions
897684201 N/A
Total 725 838 1,1561,2201,5631,8401,5951,812 +13.6%
*including exchange counters
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CHAPTER III TREND AND DEVELOPMENT OFSUSPICIOUS TRANSACTION REPORTS (STRs)
Chart 1: Number of STRs Filed by Sectors in 2007 - 2014
2000
1800
1600
1400
1200
68
1000
600
200
0
1,138
1,082
800
400
1,370
1,328
443
767
814
382
338
374
343
386
477
510
457
441
2007200820092010 20112012 20132014
Financial Institutions
Games of Fortune Operators
Other Institutions
During 2014, GIF has submitted 163 STRs to MP, which represents an increase of 10.9%
as compared with the figure of 147 submitted in 2013. The rise was caused by increased reporting
of supplementary information, although the number of new cases reported to MP has decreased
moderately.
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CHAPTER III TREND AND DEVELOPMENT OFSUSPICIOUS TRANSACTION REPORTS (STRs)
3.2 Statistics on Recent Trends of Suspicious Transactions
“Chips Conversion without/with minimal Gambling Activities” continues to be the most
common typology in 2014; this casino-related typology appeared in 766 STR cases. “Suspicious
Wire Transfers” and “Use of Cheques/Promissory Notes/Account Transfer to Transfer Funds” are
most commonly seen in the financial sector. “Currency Exchanges/Cash Conversion” was once
a typology commonly related to the gaming sector and has now dropped out of the top 10 due to
the more stringent control of cash exchange activities. Another most significant drop in ranking
could be seen on “Unable to Provide ID/Important Personal Information” which ranked the fifth and
saw a larger decrease in number by nearly 50%. This shows that reporting entities have shifted
their attention from transactions with unidentifiable suspects to those with useful identification
information. The top 10 most prevailing typologies (in terms of occurrence) in 2014 are given in the
following Chart 2 & Table 2.
Charts 2: Ranking of Statistics on Typologies of STRs
800
700
600
500
400
300
766
200
433
346
100
274
173
0
172
143
125
120
97
68
12345678910
11
STRs
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CAPÍTULO III SITUAÇÃO ACTUAL RELATIVAMENTE AOS RELATÓRIOS DE TRANSACÇÕES SUSPEITAS
Table 2: Ranking of Statistics on Typologies of STRs (in order of occurrence)
Typologies
Number of STRs
1
Chips conversion without/with minimal gambling activities
766
2
Suspicious wire transfers
346
3
Use of cheques/promissory notes/account transfer to
transfer funds
274
4
Suspected underground banking/alternative remittance services
173
5
Unable to provide ID/important personal information
172
6
Irregular large cash withdrawals
143
7
Significant cash deposit with non-verifiable source of funds
125
8
Suspected Politically Exposed Person (PEP) related transaction
120
9
Possible match with international watch-list or other black list
97
10
Counterfeit currency
68
11
Others*
433
* Other typologies including Account holder issues/receives casino cheques, Currency
exchanges/cash conversion, Use of ATM/phone banking/cash deposit machines, Attempted but
unsuccessful transaction, Bank account holder with gambling activities (casinos, horse racing,
internet gambling etc.), etc.
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CHAPTER IV ANTI-MONEY LAUNDERING AND COUNTER TERRORIST FINANCING IN MACAO SAR
CHAPTER IV ANTI-MONEY LAUNDERING
AND COUNTER TERRORIST FINANCING
IN MACAO SAR
4.1 Coordination of the Interdepartmental AML Working Group
The Interdepartmental AML Working Group was established informally in 2002 and is an
interdepartmental group of different government agencies with an aim to coordinate all the AML/
CFT related works in Macao. GIF continued to be the coordinator of the AML Working Group and
meetings were held regularly.
Taking into account the changing environment and the international standards as well as the
emerging trends and typologies, the Macao SAR Government strengthened its scrutiny in the AML/
CFT regime through the formal establishment of the AML Working Group by the Chief Executive
Internal Order no. 11/CE/2014 in January 2014. Functions of the AML Working Group are now
formally specified as follows:
1) Coordination and follow-up of the works related to the evaluation and assessment of
Macao conducted by international and inter-regional AML/CFT organizations, especially in
coordinating the collection of related necessary data;
2) Carrying out policy studies related to AML/CFT;
3) Provision of AML/CFT training and public awareness programs to the economic sectors
involved in the fight against money laundering and terrorist financing (ML and TF);
4) Exchange of information on trends related to AML/CFT;
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5) Establishment of special sub-Working Groups whenever deemed necessary for the study of
some particular AML/CFT related issues.
All the Working Group members show their enthusiasm to fight against ML and FT by reappointing experienced officers at higher levels to participate in Working Group meetings and
discuss policy issues.
Two new members were introduced into the AML Working Group in 2014, bringing in a total
of 16 different agencies of supervisory, legal and law enforcement nature, including (in alphabetical
order of Portuguese acronym):
(1) Monetary Authority of Macao (AMCM)
(2) Commission against Corruption (CCAC)
(3) Independent Committee for the Exercise of Disciplinary Power over Solicitors (CIEPDSS)
(4) Gaming Inspection and Coordination Bureau (DICJ)
(5) Legal Affairs Bureau (DSAJ)
(6) Macao Economic Services (DSE)
(7) Financial Services Bureau (DSF)
(8) Law Reform and International Law Bureau (DSRJDI)
(9) Housing Bureau (IH)
(10) Macao Trade and Investment Promotion Institute (IPIM)
(11) Public Prosecutions Office (MP)
(12) Judiciary Police (PJ)
(13) Public Security Force (PSP)
(14) Macao Customs Service (SA)
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(15) Unitary Police Service (SPU) and
(16) Financial Intelligence Office (GIF).
During 2014, GIF organized 3 AML Working Group meetings and a number of bilateral
meetings with individual government agencies. The following issues were discussed:
• Follow up the implementation of the recommendations of the APG/Group of
International Finance Center Supervisors (GIFCS) Joint mutual evaluation report
(MER) and preparation for the next round of mutual evaluation (ME), in particular
the coordination with other government agencies to identify and assess ML and TF
risks in Macao SAR through the NRA Project (see Section 4.2.1);
• Follow up the revision of Law no. 2/2006 “Prevention and Suppression of the Crime
of Money Laundering” and Administrative Regulation no. 7/2006 “Preventative
measures for the crimes of money laundering and financing of terrorism” (see
Section 4.2.2);
• Coordinate with the members of sub-Working Group on the implementation of
freezing measures (Freezing Study Group) to enforce United Nations Security
Council Resolutions (UNSCR) sanctions and to collect comments from different
competent authorities in drafting the Freezing Law (see Section 4.2.3);
• Coordinate training activities for different government agencies; and
• Report on APG Annual Meeting and Typologies Workshop.
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4.2 Follow-up of APG/GIFCS Joint Mutual Evaluation and Preparation for the Next Round of Mutual Evaluation
As the 3rd round of Mutual Evaluation for Macao, China is tentatively scheduled for late 2016,
the AML Working Group has already commenced the relevant preparation work. Given that the
next round of Mutual Evaluation will mainly focus on the risk and effectiveness of implementation,
the major task carried out by the AML Working Group in 2014 was the NRA Project (details of
which will be discussed in the section below). Besides that, the AML Working Group continued to
follow up the law revision and other study projects. Supervisory agencies also initiated the revision
of AML/CFT guidelines to address the gap with international standards requirements.
4.2.1 National Risk Assessment
The NRA on Macao SAR was officially kicked off in late 2013. Since then, tremendous efforts
were exerted by AML Working Group members, and because of their active participation, Phase I
of the NRA project could be completed by August 2014 as scheduled.
In order to facilitate the NRA Project, the AML Working Group and the external consultant of
the project, Deloitte Touche Tohmatsu, had meetings in early 2014 and agreed on the timeline to
achieve major milestones in Phase I, including:
• Establishment of the NRA Framework
• Establishment of a Centralized Coordination System
• Identification of the High Risk Areas
• Design of the NRA Skeleton, Data Collection Matrices (DCMs) and Sector Questionnaires
• Training to government agencies and relevant private sectors
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During 2014, a number of meetings were held, both within the scope of the government
agencies themselves, or with the participation of Deloitte. A kick-off meeting was held in December
2013 and 4 NRA Steering Committee meetings were held before August 2014, between the AML
Working Group and Deloitte, to report and follow up with the status of the NRA Project. Around
48 individual one-to-one meetings were held with the government agencies and private sector,
the main purpose of which was not only to get information from the industries, but also to get the
stakeholders aware of the importance of the risk assessment. With the concrete efforts inputted
by the AML Working Group members, the NRA Skeleton, DCMs and Sector Questionnaires were
finalized and endorsed by all NRA team members in Phase I of the NRA Project.
In the mean time, the relevant supervisory agencies grasped the time to roll out Sector
Questionnaires as preparation for Phase II of the project which was later kicked off in November
2014. Different sector questionnaires covering the financial sector (namely banks and insurance
companies) and designated non-financial business and professions (DNFBPs) (namely gaming
operators, dealers of high value products, real estate intermediaries, company service providers)
were sent out by the respective supervisory agencies during the period from August to November
2014. Explanatory sessions were arranged respectively to brief the different sectors about the
content of the sector questionnaires. This kind of industry-wide and in-depth risk assessment
sector questionnaires provided a very good opportunity for the different agents of each sector to be
aware of the associated risks of their particular industries.
As a continuation of Phase I of the NRA Project, Phase II of the project is mainly composed
of data collection, analysis, evaluation and report writing. Individual sector review reports will be
prepared based on the results of the Sector Questionnaires mentioned above, and threat analysis
report on the judiciary and law enforcement areas will also be prepared. These individual reports
will be compiled into the final NRA report.
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Challenging but rewarding, the final end product of the NRA project will serve as a very good
reference for Macao SAR to identify, assess, and understand its money laundering and terrorist
financing risks, and to establish high-level strategic AML/CFT policies for prioritization of resources
according to the high risk areas identified.
4.2.2 Revision of Legislation
Revision of AML/CFT Legislation
The main objective of revising the AML/CFT Law and Administrative Regulation is to
incorporate the recommended measures given in the APG/GIFCS Mutual Evaluation Report in
2007 and the new requirements emerging from the revised FATF 40 Recommendations adopted
in February 2012. The final draft of the law revision project has already been submitted to proceed
with the legislative process.
Asset freezing legislation
The drafting of the special law on implementation of freezing measures required under the
UNSCR sanctions has come to the final stage and will proceed with the legislative process once
the final draft is approved.
Revision of AML/CFT Guidelines
In 2014, supervisory agencies in the AML Working Group commenced their review work
on revision of AML/CFT guidelines. The guideline for the insurance sector (Notice No. 15/2014AMCM) has already been revised and published in Official Gazette on 31 December 2014 and
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will be effective from 2 January 2015. On the other hand, the guideline for the banking sector is
also under review. In 2015, GIF will commence discussion work with the supervisory agencies of
DNFBPs to revise the AML/CFT guidelines.
4.2.3 Policy Development Studies
Another important function of GIF is to carry out different study projects for policy
development. These study projects can serve as a useful reference for the Working Group
members for their prioritization of work, allocation of resources and development of operation
procedures, supervisory guidelines, etc. Below are the major analytical reports prepared by GIF in
the past.
Non-profit Organization (NPO) Sector Review Report
Since the last NPO review report in 2011, there have been substantial changes in
international requirements regarding the abuse of NPO for terrorist financing activities. Therefore,
with the assistance of DSF and Identification Bureau (DSI), GIF completed another NPO sector
review in March 2014 as planned to address the new revision of FATF Recommendation 8 and
to reassess the extent the NPO sector in Macao conforms to international requirements, as well
as the sector’s potential vulnerabilities of fundraising activities in Macao. Short- to long-term
recommendations were proposed to the relevant government authorities in the report. It is expected
that the existing registration requirements for NPOs and the transparency and governance of NPO
activities can be further improved.
Furthermore, as part of an ongoing NPO review work, the Working Group continues with the
quarterly survey on review of the cross border fund movement of NPOs through the banking sector
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to assess the underlying risks of banks who deal with NPO customers.
Annual Large Transaction Reports (ROVE) and Casino STR Analysis
Report
For the past few years, GIF has prepared annual ROVE and Casino STR analysis reports
with the information gathered from STRs and ROVE. These reports serve to analyze the nature of
ROVE transactions in terms of its turnover and breakdown of transaction types so as to understand
the nature of casino transactions and its implications in risk control.
Another part of the analysis concentrated on the STRs reported by casinos, in which the
general trend of casino ML risks could be observed by looking at the typologies involved. Trends
identified in casino STRs are a key element in understanding the risks and introducing the
mitigation measures required. Some STRs can also highlight possible deficiencies in the AML
control of casinos, which in turn will be of high reference value for the monitoring work of DICJ.
Such information has been shared with DICJ through bilateral meetings and annual summary
analysis reports.
Analysis Report on Alternative Remittance Systems
Alternative Remittance Systems (hereinafter referred as ARS) are financial services,
traditionally operating outside the conventional financial sector, where value or funds are moved
from one geographic location to another.
For the purpose of understanding the transaction pattern and associated risks involved with
the ARS in Macao, GIF commenced study work in this area in 2013. With collection of relevant data
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in daily STR analysis, GIF has compiled yearly review report of Alternative Remittance Systems in
2013 and 2014 respectively. Several major ARS transaction patterns and trends were observed,
which were conducive to understanding the underlying risks and developing effective strategies
and measures against the findings from the report. Positive feedbacks were received from the
departments concerned, including MP, PJ, AMCM, DICJ, DSE and DSF, after the reports were
shared with them.
4.3 Participation in International Organizations activities
Money laundering and terrorist financing never confine themselves to domestic borders and
always involve international movements of funds. As such, different international organizations
foster cooperation and compliance globally with the internationally recognized standards in AML/
CFT, in particular the 40 Recommendations of FATF. Macao joined the APG in 2001 and GIF
joined the Egmont Group in 2009. During its years of membership, Macao has been proactively
enhancing its AML/CFT efforts through the participation in the meetings as well as the assessment
missions of member jurisdictions.
4.3.1 Hosting of APG Annual Meeting
The Macao SAR Government hosted the 17th Annual Meeting of APG from 15 to 18 July
2014. More than 350 delegates from 41 member jurisdictions, together with delegates from
international organizations and other observers gathered in Macao to discuss the AML/CFT issues
of common interest and share experiences in fighting money laundering and terrorist financing
activities. This is the second time that the Macao SAR hosted this event after it previously hosted
the 6th APG Annual Meeting in 2003.
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As the major contact point with international organizations in the AML/CFT area, GIF was
the coordinator of this event. The Secretary for Economy and Finance of Macao SAR Mr. Tam Pak
Yuen, the Deputy Governor of the People’s Bank of China Mr. Li DongRong and the President
of FATF Mr. Roger Wilkins were honorably invited to join the opening ceremony of the 17th APG
Annual Meeting. Throughout the 5 days of the meetings, the 17th APG Annual Meeting produced
fruitful outcomes in AML/CFT areas. The hosting of such event in Macao not only brought together
professionals from Asia-Pacific region to share experiences but also reflected the commitment and
responsibility of Macao SAR in the fight against money laundering and financing of terrorism.
4.3.2 Chairing of the Mutual Evaluation Working Group of the APG
Along the end of the revision of the FATF Recommendations and Assessment Methodology,
a new Working Group, the Mutual Evaluation Working Group, was established within the APG
with the core function to report back to the APG Secretariat and to provide technical assistance
related to the follow-up of the 2nd round Mutual Evaluation as well as the arrangement of the new
3rd round Mutual Evaluation. With the fruitful experience gained in previous assessments and
technical assistance work, the Legal Counsel of GIF was nominated as one of the Co-Chairs of this
Working Group in the margin of the 2014 APG Annual Meeting. After a rigorous review process and
with unanimous consent from members, the Legal Counsel of GIF was appointed Co-Chair of the
Mutual Evaluation Working Group in September 2014, in co-operation with another Co-Chair from
Australia.
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4.3.3 Participation in Mutual Evaluations
Another commitment of Macao SAR as member of international organizations is the
nomination of assessors for the 3 rd round of APG Mutual Evaluations. Four representatives
from the AML Working Group joined the assessor training workshops organized by the APG in
September 2013 and May 2014 respectively, to provide their professional expertise in financial,
legal and Financial Intelligence Unit (FIU) fields. As a commitment for their participation in the
assessor training workshops, they will have to take up assessment work for APG member
jurisdictions. The participation in assessment work not only demonstrates Macao’s active
participation in international interface but also provides valuable inputs for preparation for the next
round Mutual Evaluation of Macao.
4.4 International Cooperation
Globalizations, interconnection of world economies and financial systems, as well as new
technologies, allow instant transfer of funds around the globe. Therefore, the prevention and
suppression of ML/TF can never succeed without international strategic alliances. GIF realizes
that good relationships with foreign counterparts and commitment to international cooperation is
an important aspect in its operations, and thus has been actively seeking opportunities to establish
cooperation and financial intelligence exchange channels. In 2014, GIF has signed Memoranda
of Understanding (MOUs) with Australia and the United States, making a total of 13 MOUs signed
with foreign countries and jurisdictions.
GIF values every new relationship as it can create opportunities to share intelligence and to
uncover illegal cross-border financial flows. As such, a cooperation mechanism with focus on AML/
CFT regime has been established among LEAs, supervisors and FIUs of China, Hong Kong and
Macao. The first meeting was held in July 2014.
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The following table indicates the data on information exchange between GIF and foreign
counterparts during 2014:
Statistical Data of Information Exchange
2014
Number
Incoming Requests for Information
25
Outgoing Requests for Information
167
Intelligence Received
6
Intelligence Sent
6
During 2014, GIF received a number of delegations representing different authorities/entities
from other countries or jurisdictions, including Hong Kong, the United Kingdom, Korea, Australia,
Japan and China. GIF values these visits as face-to-face communication channels can enhance
bilateral relationships and provide direct contact points for future cooperation and information
exchange.
4.5 Cooperation among Government Agencies
Pursuant to the objective to fight against money laundering and terrorist financing, GIF
continued to maintain close cooperation with members of the AML Working Group. During 2014,
the following meetings were held among supervisory agencies and law enforcement agencies to
exchange information with common interests:
Supervisory Agencies
• Four bilateral meetings were held quarterly between AMCM and GIF to discuss AML/CFT
issues including the scope of coverage under the NRA and sector questionnaires to be
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sent out, revision of AML/CFT guidelines, follow up on results of international meetings and
workshops, highlights of STR cases, sharing of information on STR quality and compliance,
as well as cooperation in AML/CFT training, seminar and public awareness campaign;
• A bilateral meeting between DICJ and GIF were held in August to discuss the annual ROVE
report, STR statistics, progress on the preparation of NRA, highlights of STR cases and
sharing of information on STR quality and compliance;
• A tripartite meeting was held in September with DSE and IH to discuss about the current
practice of DSE in AML/CFT supervision of real estate agents and the resources required,
and to share experience on the main challenges faced.
Project Groups
• Pursuant to the kick-off meeting of the NRA Project held in 2013, 4 Steering Committee
meetings were held in 2014 among the law enforcement agencies, supervisory authorities
and external consultant concerned, including MP, Office of the Secretary for Security
(GSS), PJ, CCAC, PSP, SPU, SA, AMCM, DICJ, DSE, DSF, IPIM, IH, DSRJDI, DSAJ,
CIEPDSS, Deloitte and GIF. Forty eight one-to-one meetings were arranged to meet both
the government agencies and the private sector. The high level of cooperation from the
departments contributed to the successful completion of Phase I of the NRA Project;
• One meeting was held in April with DSRJDI to follow up on the drafting of the Freezing Law
as well as the schedule for the legislative process;
• Four meetings were held in the first and second quarters respectively with SA, PJ and GSS
to follow up the implementation of the Cross-border declaration system.
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4.6 Attending International Conferences
During 2014, representatives of GIF continued to participate in the following international
meetings:
January / March / May / September: APG Missions and Asia/Pacific
Regional Review Group (APRRG) meetings
The legal counsel was invited by ICRG to take part in the face-to-face meeting held in Hanoi,
Vietnam from 13 to 18 January 2014 as well as to provide technical assistance to Timor-Leste from
10 to 14 March 2014. Furthermore, the legal counsel was invited by APRRG again in May and
September to take part in the face-to-face meetings held in Ulaanbaatar, Mongolia from 12 to 16
May 2014 and Siem Reap, Cambodia from 1 to 5 September 2014.
February: Egmont Working Group and Committee Meeting
The legal counsel and an analyst of GIF attended the Egmont Working Group and Committee
Meetings held in Budapest, Hungary, from 16 to 19 February 2014.
2014 Egmont Working Group and Committee Meeting in
Budapest, Hungary
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June: 22nd Egmont Plenary
The Director, the legal counsel along with an analyst attended the 22nd Egmont Plenary,
which was held in Lima, Peru from 1 to 6 June 2014. During the Plenary, the Head of FIUs have
adopted a number of documents, among which the most important ones are the Egmont Strategic
Plan 2014-2017 and the Support and Compliance Procedure with revised triggers criteria.
The 22nd Egmont Plenary in Lima, Peru
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July: The 17th APG Annual Meeting
The 17th APG Annual Meeting was hosted by the Macao SAR Government in July 2014, and
GIF was the main co-ordinator of this meeting. Please refer to section 4.3.1 for more details of the
17th APG Annual Meeting.
The 17th APG Annual Meeting in Macao, China
Opening ceremony of the 17th APG Annual Meeting
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November: The 17th FATF/APG Joint Experts’ Meeting on Typologies and
APG Technical Seminars 2014
Delegates from AMCM, CCAC, DICJ, PJ, and PSP along with the legal counsel and 2
analysts from GIF attended the 17th FATF/APG Joint Experts’ Meeting on Typologies and APG
Technical Seminars 2014 hosted by the Government of Thailand in Bangkok from 24 to 28 November
2014. A number of typology projects were discussed during the Workshop including “Transparency
of beneficial ownership”, “Third party money laundering”, “Trade-based money laundering”, “Making
asset recovery work” and “Understanding cybercrime”.
2014 FATF/APG Joint Experts’ Meeting on Typologies in
Bangkok, Thailand
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4.7 Public Awareness
In view of the increasing complexity of anti-money laundering issues, GIF continued to
raise public awareness through publications and coordination of appropriate on-going training
programs for different stakeholders to cope with this challenge. Awareness raising programs have
been carried out progressively from the top involving the supervisory agencies, moving down
to the reporting entities and eventually to the general public through training tailored to different
stakeholder groups and the publication of newsletters and annual reports, as well as the website
with updates on AML/CFT issues accessible to the public. Apart from the usual training on AML/
CFT, special explanatory sessions in regard of the NRA sector questionnaires have been held for
some specific sectors during the year. The sessions not only provided clarification on questions in
the sector questionnaires and collected valuable comments but also raised the awareness of the
reporting entities on the high risk areas and expected risk mitigation measures.
4.7.1 Training
Local Training for GIF Staff and other Government Agencies
During 2014, the following training sessions have been attended by staff of GIF and other
government agencies of the AML Working Group:
February
As part of the promotion program for customs supervisor, an AML/CFT seminar was
organized by SA on 21 February 2014 for the potential customs officers. The Director and an
analyst from GIF were the guest speakers in that seminar.
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May
Four analysts of GIF attended the 1-day workshop on 28 May 2014 at the invitation of AMCM.
The intensive workshop was organized by VISA and was intended to discuss the economic and
social benefits of electronic payments, strategic considerations in developing an effective payment
system that would facilitate the growth of electronic payments in a country.
The analysts attended the 1-day workshop organized by VISA
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September
Three analysts of GIF attended a half-day seminar held by AMCM on 19 September 2014,
where presentations on “Trusts and Companies: Beneficial Ownership Issues” and “Reform and
Marketing Transformation of Electronic Banking” were provided.
A seminar entitled “The challenges facing prosecution and hearing of ML/FT cases”, targeted
at judges, registrars, notaries, legal professionals, solicitors and trainee solicitors, etc., was held
by CFJJ in collaboration with GIF on 26 September 2014. The Director and an analyst of GIF were
among the group of over 80 participants while the legal counsel was invited to be the moderator
of the seminar. The topics covered were mainly related to the collection of evidence, production of
evidence, different prosecution standards in different regions and the international trends observed.
A seminar held by CFJJ in collaboration with GIF.
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November
In November, CFJJ invited legal experts from Portugal and France to provide 2 half-day
seminars on 13 and 14 November 2014 respectively. The Director, the legal counsel and the
analysts of GIF with other participants from legal profession attended the seminars. During the 2
seminars, the guest speakers shared with the participants their experience in the investigation and
prosecution of money laundering, fraud and corruption cases.
Legal experts Dr. José Francisco Nota Ribeiro and Dr. Nicolas Baïetto
from Portugal and France were invited by CFJJ and GIF
Overseas Training for GIF Staff and other Government Agencies
During 2014, under the coordination of GIF, the AML Working Group members attended the
following workshops held by international bodies:
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May
A delegation of 7 representatives from MP, PJ, AMCM, DICJ and GIF attended a 3-day
workshop entitled “APG Pre-Mutual Evaluation and NRA Training Workshop” in Seoul, Korea from
28 to 30 May 2014. This course was designed for jurisdictions to be evaluated in the next round
of mutual evaluation. Topics covered the FATF assessment methodology and the APG 3rd round
mutual evaluation procedures including the main steps of the evaluation process.
GIF attended the “APG Pre-Mutual Evaluation and NRA Training
Workshop” in Seoul, Korea.
August
The Director of GIF attended a 5-day assessor training workshop hosted by the APG in
Seoul, Korea from 18 to 22 August 2014. The objective of the workshop was to identify potential
assessors for the 7 mutual evaluations of member jurisdictions in the period 2015-2016.
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Training for Private Sector
Raising the awareness of stakeholders, particularly the reporting entities, on their AML/CFT
obligations is always crucial to the functions of GIF. During 2014, the following training sessions
have been conducted:
April/May
The Director and the analysts of GIF were invited by AMCM to attend the “8th Annual Seminar
on AML/CFT” held by the Banking Supervision Division and the Insurance Supervision Division
on 16 April 2014 and 5 May 2014 respectively. One analyst from GIF was invited to deliver a
presentation regarding the latest trend of money laundering, STR quality and compliance, as well
as updates on the STR feedback mechanism in both seminars. Deloitte as the external consultant
of the NRA Project was also invited among the other speakers to have a discussion on Customer
Due Diligence measures, high risk customers and PEPs.
The Director and the analysts attended the “8th
Annual Seminar on AML/CFT”
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The Director and an analyst of GIF were invited by AMCM and UnionPay to be the speakers
in a seminar with the participation from merchant acquirers namely the jewelry shops and the pawn
shops. Discussions on the risk posed by CUP card transactions, and the new payment methods (i.e.
alternative remittance system) were covered in that seminar. Three analysts of GIF were among
the 100 participants joining the seminar.
May/August/November
As in last year, GIF was invited by the Labor Affairs Bureau (DSAL) to provide training on
AML/CFT to real estate agents as part of the mandatory training programs for qualified real estate
agents. A total of 4 training sessions were carried out on 17 May, 30 August and 14 November
during 2014. The speakers from GIF presented the topics on AML/CFT legal framework,
introduction to guidelines for real estate agents issued by DSE, risk management strategy for real
estate sector and case studies.
GIF provided training on AML/CFT to real estate agents
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August/September/October
In order to assist the different sectors with the NRA sector questionnaires, a total of 5
explanatory sessions were held by different supervisory agencies in association with GIF in August,
September and October respectively. The explanatory sessions were intended to provide the
financial sector and other business sectors (namely the real estate agents, pawn shop and jewelry
shop owners) with a deeper understanding of the sector questionnaires.
GIF visited Association of Property Agents and Realty Developers of Macau
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September
The Director and an analyst of GIF were invited by the Asia/Pacific Academy of Economics
and Management and Institute for the Study of Commercial Gaming of University of Macau, as
guest speakers for a seminar held on 25 September 2014. The seminar was targeted at the middle
management of gaming concessionaires and intermediaries. Topics covered included government
requirements on AML preventive measures to be implemented by casinos and junkets, ML cases,
FATF standards and how to comply with such standards.
GIF held a seminar for the managerial staff of the gaming operators and junkets
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October to December
GIF was invited to provide training sessions on AML/CFT to the front line staff of Tai Fung
Bank, China Life and OCBC Wing Hang Bank on 15 October, 17 October and 25 November
2014 respectively. Topics such as the legal framework of AML, functions of GIF, statistics of STRs
as well as the latest typologies were covered. A total of around 500 staff members attended the
training sessions.
GIF provided a training session on AML/CFT to the front line
staff of OCBC Wing Hang Bank.
An analyst of GIF was invited to be the principal speaker in the seminar entitled “International
Standards on AML and the Measures for combating money laundering”, which was held on 12
December 2014. The seminar was jointly organized by The Macao Association of Banks and
The Hong Kong Institute of Bankers, with a participation of 100 attendees from the banking
sector. By integrating theory with practical case studies, the participants were able to achieve a
better understanding of the international standards on AML and the requirements imposed by the
supervisory agencies in Macao and Hong Kong.
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4.7.2 Website
Over the years, GIF has been renovating and strengthening its website through the
enhancement of information system’s security and facility of access. The website of GIF serves as
a platform for the public to access the latest news of GIF and the recent AML/CFT developments
in Macao, which includes the publications issued by GIF, e.g. the annual reports, newsletters for
different industrial sectors of reporting entities, information on financial intelligence units with which
GIF has signed MOU/Cooperation agreements, APG MER and the updates on GIF activities.
Members of the AML Working Group can also access through the secured intra-Working Group
information system to receive the updated information and internal documents from international
organizations, mainly the FATF and the APG.
4.7.3 Publications
Aside from the Annual Report, the semi-annually published newsletters are another key
channel for GIF to provide to the public and reporting entities the latest information on AML/CFT,
including recent trend of money laundering typologies and indicative case studies. As usual,
the newsletters for the financial sector and the gaming sector were published in May 2014 and
November 2014 respectively to present information on STR statistics, relevant case studies,
international trends and developments related to AML/CFT regime.
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4.8 Courtesy Visit from/to Other Entities
In 2014, GIF has received several courtesy visits from foreign counterparts as well as local
financial institutions, including FIU of United Kingdom, Korean and Japanese Consulate General in
Hong Kong, Bank of China, etc. Through these visits, GIF had an opportunity to introduce to them
the AML/CFT work of the Macao SAR government and the recent trends on money laundering
activities. These visits also helped to enhance the cooperation to fight against money laundering
activities with the nearby regions and provided direct communication channels to discuss about the
AML/CFT compliance issues.
Courtesy visit by FIU of United Kingdom
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Courtesy visit by Consulate General of South Korea
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CHAPTER V ADMINISTRATION
CHAPTER V ADMINISTRATION
5.1 Means of STR Submission
In order to provide a more secure and rapid delivery of STRs other than the traditional
channels in paper form and electronic STR filing, GIF rolled out another STR reporting channel
for the reporting entities to submit their STRs to GIF via Online System (Secured Website) in June
2011. Since then, the efficiency of the STR submission process and the accuracy of information
reported are significantly enhanced. The table below shows the utilization rate of the three current
methods of STR submission in the past three years.
Table 3: Statistical Data for the Methods of STRs Submission
Methods of Submission
Number of STRs
2012
%
2013
%
2014
%
Paper Form
533
28.97%
360
22.57%
424
23.40%
Encrypted Email
49
2.66%
40
2.50%
35
1.93%
Secured Website
1,258
68.37%
1,195
74.93%
1,353
74.67%
Total
1,840
100%
1,595
100%
1,812
100%
In 2014, the number of STRs submitted through secured website remained at the same level
of 2013 in terms of percentage. Out of 74.67% of online submission, 111 STRs were reported
by financial institutions while 1,242 were submitted by casino operators. It is expected that the
secured website reporting system will still be the major method for the reporting entities to submit
their STRs in the near future, and enhancement of the system will be carried out in 2015.
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5.2 Enhanced Documentary Security and Case Management
Considering the development of money laundering/terrorist financing activities overseas,
GIF has been continuously improving its AML/CFT analytical system and network infrastructure, in
particular focusing on the electronic data exchange channels, workflow enhancement, integration
and tracing of external information exchange, better utilization of office automation to support local
and regional cooperation in information exchange, as well as optimizing its multi-analytical tools to
improve the efficiency in financial intelligence analysis.
Maintaining the stability of the information system and network infrastructures is crucial to
achieving operational efficiency in GIF. With the extension in the degree of server virtualization,
system management and allocation of resources have become more effective, and the impact on
system performance for hardware repair is greatly reduced, ultimately providing better stability in
the overall information system.
In response to the complexity and ever-changing network security threat, GIF is always
alert to the potential risks and new methods of virus attack. In order to ensure that the connection
between GIF and external networks are secured, GIF implemented feasible and effective security
patches and deployed prevention policies, which include the timely upgrade of server systems,
integration of intrusion prevention systems, mail security with anti-spam filtering and end-point
computer security.
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CHAPTER VI CHALLENGES AND PROSPECTS
CHAPTER VI CHALLENGES AND PROSPECTS
Although the previous years have always been challenging for GIF, 2015 is especially crucial
due to a number of targets that have to be achieved:
Revision of Legislation, Supplementary Rules and Regulation
The work on the revision of the AML Law and the drafting of special law on implementation of
freezing measures required under UNSCR sanctions will be continued in 2015. To prepare for the
new measures that come with the law revision, GIF will collaborate with the supervisory authorities
on the necessary work such as review of existing guidelines and communication with different
sectors about the new AML requirements with the conduction of seminars and training workshops.
National Risk Assessment
Phase II of the NRA Project has entered an important stage when most of the data from both
government agencies and private sectors have been collected and analyzed in early 2015. The
NRA exercise has been proceeding according to schedule and it is expected that the project could
be completed by the end of August 2015. The working schedule is tight and every government
agency is working hard to meet the targeted deadlines.
It must be emphasized that the NRA is an exercise that requires continuous follow-up and
renewal of data. The end of Phase II only marks the completion of the first stage, which will be
followed by a series of follow-up work on the recommendations given in the report. An important
purpose of the NRA exercise is to let the stakeholders understand the inherent ML/TF risks of their
sectors, so that proper risk mitigation measures can be introduced to deal with and mitigate the
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CHAPTER V ADMINISTRATION
risks. Lots of follow-up work will be needed by government agencies to ensure that the necessary
risk mitigation measures are properly implemented. A new round of the NRA will be performed
after a reasonable period to assess the progress on implementation of the recommendations and
updated status of the risks.
Enhancement of GIF
As an essential part of the NRA Project, the result of analysis on threat from crimes
provides guidance on how GIF should improve its present practice, an example of which is the
enhancement of typologies collection and analysis which can better identify the new ML trends
and initiate immediate response. On the other hand, in accordance with the policy of Macao SAR
Government to streamline structures and procedures, GIF has already undergone restructuring
to raise efficiency and meet the higher demands of work in terms of both quantity and quality.
Collaboration with different local and international agencies will be further enhanced.
Training and awareness programs are always an essential part of GIF’s activity. The training
programs in 2015 will be focused on the effective implementation of risk mitigation measures, and
more practical courses will be organized to enhance the general understanding among supervisory
and law enforcement agencies on the international standards requirements.
Many of the tasks above are orientated towards meeting international requirements or
preparation for the upcoming mutual evaluation, but at the same time only with such work can
Macao deal with the fast changing local and international environment. With the fall of the gaming
revenue, a downturn of the economy is expected in 2015 for which the Macao SAR Government
will take a prudent approach, including preparation for the possible increase in crimes. At the
same time the world is suffering from a new threat of terrorism signified by the rise of new terrorist
groups and terrorist activities. For the past year the whole AML Working Group, including GIF,
has invested great efforts to strengthen the AML environment, and we will continue our common
endeavor to protect Macao from the risks of ML and TF crimes.
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APPENDIX – GLOSSARY
APPENDIX – GLOSSARY
AMCM
Monetary Authority of Macao (Autoridade Monetária de Macau)
AML/CFT
Anti-Money Laundering/Countering the Financing of Terrorism
APG
Asia/Pacific Group on Money Laundering
APRRG
Asia/Pacific Regional Review Group
CCAC
Commission against Corruption (Comissariado contra a Corrupção)
CFJJ
Legal and Judicial Training Centre (Centro de Formação Jurídica e Judiciãria)
CIEPDSS
Independent Commission for the Exercise of Disciplinary Power over Solicitors (Comissão Independente para o Exercício do Poder Disciplinar sobre os Solicitadores)
DICJ
Gaming Inspection and Co-ordination Bureau
(Direcção de Inspecção e Coordenação de Jogos)
DNFBP
Designated Non-Financial Business and Profession
DSAL
Labour Affairs Bureau (Direcção dos Serviços para os Assuntos Laborais)
DSAJ
Legal Affairs Bureau (Direcção dos Serviços de Assuntos de Justiça)
DSE
Macao Economic Services (Direcção dos Serviços de Economia)
DSF
Financial Services Bureau (Direcção dos Serviços de Finanças)
DSI
Identification Bureau (Direcção dos Serviços de Identificação)
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DSRJDI
Law Reform and International Law Bureau
(Direcção dos Serviços da Reforma Jurídica e do Direito Internacional)
FATF
Financial Action Task Force
FIU
Financial Intelligence Unit
GIF
Financial Intelligence Office (Gabinete de Informação Financeira)
GIFCS
Group of International Finance Center Supervisors
GSS
Office of the Secretary for Security (Gabinete do Secretário para a Segurança)
IH
Housing Bureau (Instituto de Habitação)
IPIM
Macao Trade and Investment Promotion Institute
(Instituto de Promoção do Comércio e do Investimento de Macau)
JFIU
Joint Financial Intelligence Unit of the Hong Kong Police Force
Macao SAR
Macao Special Administrative Region
ME
Mutual Evaluation
MER
Mutual Evaluation Report
ML and TF
Money Laundering and Terrorist Financing
MOU
Memorandum of Understanding
MP
Public Prosecutions Office (Ministério Público)
NPO
Non-profit Organization
156
Financial Intelligence Office
2014
Annual Report
APPENDIX – GLOSSARY
NRA
National Risk Assessment
PEP
Politically Exposed Person
PJ
Judiciary Police (Polícia Judiciária)
ROVE
Large Transaction Report (Relatório de operação de valor elevado)
SA
Macao Customs Services (Serviços de Alfândega)
SPU
Unitary Police Services (Serviços de Polícia Unitários)
STR
Suspicious Transaction Report
UNSCR
United Nations Security Council Resolution
157
Financial Intelligence Office