financial intelligence office 2019 - moneylaundering.com

Financial Intelligence Office

2 019Annual Report


Annual Report2 019TABLE OF CONTENTS

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TABLE OF CONTENTS

DIRECTOR’S MESSAGE 115

CHAPTER I BACKGROUND AND ORGANIZATION STRUCTURE 117

1.1 GIF’s Organization Background 117

1.2 GIF’s Organization Structure and Functions 117

1.3 Duties of GIF 118

CHAPTER II TREND AND DEVELOPMENT OF SUSPICIOUS TRANSACTION REPORTS 121

2.1 Statistical Data 121

2.2 Statistics on Recent Trends of Suspicious Transactions 123

CHAPTER III COORDINATION OF ANTI-MONEY LAUNDERING AND COUNTER TERRORIST FINANCING WORK IN MACAO SAR 125

3.1 Coordination of the Interdepartmental AML/CFT Working Group 125

3.2 The Result of the Macao SAR ME Follow-Up Report 128

3.3 The 2nd Round ML/TF Risk Assessment of Macao SAR and Future Preparation Work 130

3.4 Coordination of the Asset Freezing Coordination Commission 131

3.5 Participation of International Bodies Activities 133

3.5.1 Chairing of ME Working Group 133

3.5.2 Participation in ME of other APG Member Jurisdictions 134

3.5.3 Representative of APG North Asia Region Steering Group and Related Work 135

3.6 International Cooperation 136

3.7 Attending International Conferences 139

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TABLE OF CONTENTS

3.8 Local Cooperation 142

3.8.1 Cooperation among Government Agencies 142

3.8.2 Joint Meeting on Prevention and Suppression of Financial Crimes 143

3.8.3 Communication with Private Sector 144

3.9 Public Awareness Program 148

3.9.1 Local Training for GIF Staff and other Government Agencies 148

3.9.2 Overseas Training for GIF Staff and other Government Agencies 150

3.9.3 Training for Government Agencies and Private Sector 151

3.9.4 Global Money Week/Financial Education Day 157

3.10 Courtesy Visit from/to Other Entities 159

CHAPTER IV ADMINISTRATION 160

4.1 Means of STR Submission 160

4.2 Enhancement in Information Security and Management 161


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DIRECTOR’S MESSAGE


As the newly appointed Director of the Financial Intelligence Office (GIF), Macao Special

Administrative Region (SAR) since 26th August 2017, I am pleased to present this Annual Report

which highlights the activities undertaken by GIF in combating Money Laundering (ML), Terrorist

Financing (TF) and Proliferation Financing (PF) in the year of 2019.

The year of 2019 was an important year for GIF as Macao SAR became the first member to

have all 40 Financial Action Task Force (FATF) Technical Compliance Recommendations passed

among all globally evaluated members. As reflected in the 1st Follow-Up Report of Macao SAR

adopted by all Asia/Pacific Group on Money Laundering (APG) members in August 2019, Macao

SAR had addressed the technical compliance deficiencies identified in its 2017 Mutual Evaluation

Report (MER) through the revision of Anti-Money Laundering/Combating the Financing of

Terrorism (AML/CFT) guidelines for different sectors as well as the implementation of declaration/

disclosure system for incoming/outgoing cross-border transportation of cash and bearer negotiable

instruments.

Global cryptocurrency adoption continued to expand in 2019. Along with the heated

debates around the globe on how to normalize and regulate cryptocurrencies to mitigate ML

risks throughout the year of 2019, FATF adopted changes to the Interpretive Note to the relevant

Recommendation and the consequential revisions to the FATF Methodology concerning virtual

assets (VAs) in June and October 2019, respectively. In view of that AML compliance for VAs has

become an international standard, apart from being alert on any risks posed by the development

of the global cryptocurrency adoption, GIF will also continue to work with the relevant government

agencies to ensure that VAs fit well into the overall regulatory framework so as to bring it in line

with the revised international standards.


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Effective sanctions have been an issue of global concern and prompt action taken to disrupt

TF in response to the frequent updates in the existing sanctions lists and any new list of United

Nations Security Council Resolutions (UNSCR) is always required. Playing the role as a financial

intelligence unit (FIU) and being the Secretariat of the Asset Freezing Coordination Commission

simultaneously, GIF has been coordinating in this regard to facilitate an effective notification

process and will stay alert on any updated sanctions imposed which are applicable to the territory.

Looking ahead in 2020, GIF will continue to improve the AML/CFT framework of Macao SAR

and to develop its own capacities. Locally, GIF will continue to coordinate the interdepartmental

AML/CFT Working Group on the implementation of FATF Recommendations as well as the findings

of the risk assessment of Macao SAR, and to further enhance the awareness of the public as

regards to fight against ML and TF. Internationally, GIF will continue to reach out for opportunities

to establish cooperation relationship with other jurisdictions through the signing of Memoranda of

Understanding (MOU), and to work closely with the APG to ensure our AML/CFT system remains

in line with the international standards.

Finally, I would like to express my gratitude to the Chief Executive of Macao SAR and the

Secretary for Security for providing support and resources to GIF throughout the year. I would also

like to thank all the AML/CFT Working Group members for their on-going support and effort, without

which our mission of Protecting Macao SAR from the threats of money laundering and financing of

terrorism cannot be achieved.

Director of GIF

Chu Un I


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CHAPTER I BACKGROUND AND ORGANIZATION STRUCTURE


1.1 GIF’s 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

ML and TF. It was established for coping with the implementation of Law no. 2/2006 and Law no.

3/2006 in force, on Prevention and Suppression of Crimes of Money Laundering and Prevention

and Suppression of Crimes of Terrorism.

Under Chief Executive Ruling no. 227/2006, GIF was set up in the form of a project entity

with a term of 3 years that could be extended by Chief Executive Ruling. The mandate of GIF was

extended in June 2019 for one year until 7th August 2020 by Chief Executive Ruling no. 94/2019.

1.2 GIF’s Organization Structure and Functions

Director/Deputy Director

Collection and Analysis of STR

STR Technical IT Support Administration and General Affairs

Statistics and Typologies

Training and Public Awareness

Policy and Compliance

Legal Counsel


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The core function of GIF is to collect, analyze and disseminate relevant information to law

enforcement agencies (LEAs), judicial authorities or other entities vested with the authority to

prevent and suppress crimes relating to ML or TF. In exercising such duties, GIF is granted with the

following specific competence:

- To receive information provided in accordance with the prevalent Article 7 of the

Administrative Regulation no. 7/2006 in force and to establish and maintain a database

with such information;

- To analyse the information received and report the suspicious ML activities to the Public

Prosecutions Office (MP);

- To provide assistance to LEAs, judicial authorities and other entities empowered to prevent

and suppress ML and TF 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 foreign entities information about ML and TF crimes, for the

implementation of inter-regional agreements or any other international law instruments;

- To collaborate with public entities to establish and revise AML/CFT guidelines;

- To develop promotion and education programs for public awareness about AML/CFT; and

- To furnish the Secretary for Security with an annual report on its activities.

1.3 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, paragraph 2 of Article 11 of


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Law no. 3/2006 in force, and Chief Executive Ruling no. 227/2006.

The duties of GIF are categorized into 4 main areas: Policy and Compliance, Collection and

Analysis of Suspicious Transaction Reports (STRs), Statistics and Typologies and Training and

Public Awareness. Such duties are performed with the support of the following 3 teams of back

office staff: Legal Counsel, Information Technology (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 through the participation in the meetings of these

professional bodies, commitments in the assessment missions of member jurisdictions, answer

assessment questionnaires and enquiries in relation to AML/CFT. Domestically GIF follows up with

the change in local laws and guidelines, and recommends new measures for keeping abreast with

the latest developments in AML/CFT regime.

Collection and Analysis of STRs

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 are 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 in-


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depth analysis on any case, and to propose reported cases deemed suspicious to the MP.

Statistics and Typologies

GIF has to extract statistical data periodically from STRs received, as well as providing

instructive information such as trends and typologies to the supervisory agencies. 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 delivering AML/CFT trainings and seminars to reporting entities and public, broadcasting

promotional videos on various platforms, as well as updating the content of WeChat Official

Account of GIF and publication of newsletters on a regular basis are the common channels to raise

public awareness about the importance of AML/CFT.


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CHAPTER II TREND AND DEVELOPMENT OF SUSPICIOUS TRANSACTION REPORTS

CHAPTER II TREND AND DEVELOPMENT OF SUSPICIOUS TRANSACTION REPORTS 3.1

2.1 Statistical Data

GIF continues to carry out its duties as provided under Executive Ruling no. 227/2006 to

perform statistics on STRs data and detailed STRs cases analysis. As compared with 2018, there

was a decline in total number of STRs received in 2019. The total number of STRs received and

their variances are as follows:

Among all STRs received in 2019, the gaming sector submitted 1,913 reports, financial sector

submitted 880 reports, and other institutions submitted 148 reports, which accounted for 65.1%,

29.9% and 5.0% respectively, and the total number of STRs has decreased by 20.9% as compared

with the figure of 2018. The major reduction in number of STRs was from other institutions, which

was mainly due to GIF’s continuous trainings and promotions for different sectors. As a result, the

reporting entities reduced to submit STRs with one-off transaction, but rather report STRs based

on the ML/TF suspicions identified. Statistical information relating to the number of STRs received

in 2019 is given in Table 2 and Chart 1.

Year Number of STRs Variance

2015 1,807 -0.3%

2016 2,321 +28.4%

2017 3,085 +32.9%

2018 3,716 +20.5%

2019 2,941 -20.9%

Table 1: Total Number of STRs Received and Variances from 2015 to 2019


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Table 2: Statistical Data of STRs Received from 2015 to 2019

Chart 1: Number of STRs Filed by Sectors in 2015 - 2019

During 2019, GIF disseminated 179 STRs to MP, which has increased by 47.9% as

compared with 2018. Despitethe decline in the number of STRs received, the number of STRs

disseminated to MP has significantly increased, this indicated that the reporting entities continued

Reporting EntityNumber of STRs Variance

’18 vs ’19 2015 2016 2017 2018 2019

FinancialInstitutions 503 696 746 1,122 880 -21.6%

Games of Fortune Operators 1,247 1,546 2,074 2,087 1,913 -8.3%

Other Institutions 57 79 265 507 148 -70.8%

Total 1,807 2,321 3,085 3,716 2,941 -20.9%

0

1000

2000

3000

4000

2015 2016 2017 2018 2019

其他機構

幸運博彩經營者

金融機構

Other Institutions

Games of Fortune Operators

Financial Institutions


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to improve its effectiveness in the detection of suspicious transactions through enhanced customer

due diligence (CDD) performed, which resulted in higher quality of STRs submitted. These

measures enabled GIF to obtain comprehensive information in a timely manner and to further

improve the efficiency of referring STRs to MP.

2.2 Statistics on Recent Trends of Suspicious Transactions

“Chips conversion without/with minimal gambling activities” continued to be the most

common typology in 2019. The typologies that ranked second to sixth were “Irregular large cash

withdrawals”, “Significant cash deposit with non-verifiable source of funds”, “Chips conversion/

marker redemption/gambling on behalf of third part(ies)”, “Use of automated teller machine (ATM),

phone banking, cash deposit machine (CDM)” and “Currency exchange/cash conversion”, their

ranking remained the same as in 2018. The reason was that GIF received a large number of STRs

related to frequent use of ATM/CDM for cash withdrawal and exchange transactions in 2019. The

top 10 most prevailing typologies (in terms of occurrence) in 2019 are given in the following Chart 2

and Table 3.

Chart 2: Ranking of Statistics on Typologies of STRs

0

200

400

600

800

1 2 3 4 5 6 7 8 9 10

出現的次數Numbers of Occurrence


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Table 3: Ranking of Statistics on Typologies of STRs (in order of occurrence)

* Other typologies including “Attempted but unsuccessful transaction”, “Related to others crimes”, “Possible match with international watch-list or other black list”, “Unable to provide identity/important personal information” and “Suspected underground banking/alternative remittance services”.

Typologies Number of STRs

1 Chips conversion without/with minimal gambling activities 759

2 Irregular large cash withdrawals 758

3 Significant cash deposit with non-verifiable source of funds 750

4Chips conversion/marker redemption/gambling on behalf of

third part(ies)691

5 Use of ATM, phone banking, CDM 545

6 Currency exchange/cash conversion 519

7 Foreign exchange transactions with unidentified source of funds 439

8Use of cheques/promissory notes/account transfer to

transfer funds315

9 Gambling activities (casinos, horse racing, internet gambling etc.) 294

10 Suspicious wire transfers 233

11 Others* 1,491


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CHAPTER III COORDINATION OF ANTI-MONEY LAUNDERING AND COUNTER TERRORIST FINANCING WORK IN MACAO SAR


3.1 Coordination of the Interdepartmental AML/CFT Working Group

In order to strengthen the coordination work in the AML/CFT regime in Macao SAR, the

Interdepartmental AML/CFT Working Group was established in 2002 and formalized in 2014. The

AML/CFT Working Group is an interdepartmental group of different government agencies and it

has been working smoothly and closely for many years. Functions of the AML/CFT Working Group

are specified as follows:

1) Coordination and follow-up of the works related to the evaluation and assessment of Macao

SAR 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 ML and TF;

4) Exchange of information on trends related to AML/CFT; and

5) Establishment of special sub-Working Groups whenever deemed necessary for the study

of some particular AML/CFT related issues.

The Interdepartmental AML/CFT Working Group continued to follow up all the AML/CFT

related works in Macao SAR. GIF continues to be the coordinator of the AML/CFT Working Group

and meetings were held regularly. At present, the AML/CFT Working Group is comprised of 15


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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) Public Security Force (CPSP)

(5) Gaming Inspection and Coordination Bureau (DICJ)

(6) Legal Affairs Bureau (DSAJ)

(7) Macao Economic Bureau (DSE)

(8) Financial Services Bureau (DSF)

(9) Housing Bureau (IH)

(10) Macao Trade and Investment Promotion Institute (IPIM)

(11) Public Prosecutions Office (MP)

(12) Judiciary Police (PJ)

(13) Macao Customs Service (SA)

(14) Unitary Police Service (SPU) and

(15) Financial Intelligence Office (GIF).

During 2019, GIF organized 2 AML/CFT Working Group meetings and 28 meetings with

different government or supervisory agencies, including AMCM, CCAC, DICJ, DSAJ, DSE, DSF,

IH, MP, PJ, SA, SPU and other government departments like The Court of the Macao SAR. The

following issues were discussed:


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- Follow-up work after the Mutual Evaluation (ME) from the APG and the Group of

International Finance Centre Supervisors (GIFCS), to comply with the latest revised

recommendations and requirements of international organizations, and prepare the AML/

CFT Working Group’s strategic plan for the next 5 years; (See Section 3.2)

- Initiate the 2nd round of ML/TF Risk Assessment, coordinate the scope of data collection,

including statistics and other information required, and set up an action plan for ML/TF Risk

Assessment accordingly; (See Section 3.3)

- Coordinate the Asset Freezing Coordination Commission as the Secretariat and follow up

on the implementation of freezing measures to enforce UNSCR sanctions under Law no.

6/2016 on Freezing Asset Regime; (See Section 3.4) and

- Coordinate training activities for different government agencies.

Strategic Analysis

GIF has been coordinating relevant AML/CFT Working Group members to carry out thematic

Risk Assessments in various areas since 2009. Results and findings from those Risk Assessments

have been shared among relevant government agencies and meetings were also arranged to

explain the risks identified and suggest risk mitigation measures. These ongoing Risk Assessment

project studies include:

a) Non-profit organization (NPO) sector review based on international standard requirements;

b) ML/TF risks based on STRs received in relation to the gaming sector;

c) Analytical review on the enhanced CDD data received from supervisory agency;


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d) Thematic review based on particular typologies from STRs; and

e) Review on risks of the cross-border cash declaration system.

These study reports cover the results from STR analysis as well as international AML/CFT

developments. Whenever emerging trends or threats were detected, GIF will share the information

with the AML/CFT Working Group members for follow-up actions, and discuss how to develop the

relevant risk mitigation measures. These study reports served as useful reference for different

government agencies in preparing their AML/CFT work plan and polices, which include prioritizing

their work according to the risks identified, allocating resources on risk based approach, amending

the operational procedures and supervisory guidelines to incorporate risk mitigation measures.

Most of the recommendations have been adopted by the respective agencies, with timely follow-

up, as so to comply with the requirements of international organizations and reduce the ML/TF

risks involved in different industries.

3.2 The Result of the Macao SAR ME Follow-Up Report

In the 2017 APG MER, Macao SAR had

obtained 37 compliant and largely compliant

ratings out of the 40 FATF Recommendations

on technical compliance assessment, and only 3

recommendations required further improvements.

In particular, there were still some gaps identified

in terms of the absence of a declaration/disclosure

system of transportat ion of cash and bearer

negotiable instruments (BNIs) over the boundaries of 1st Follow-Up Report for ME

of Macao, China


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Macao SAR as well as some gaps in the regulatory framework of designated non-financial

businesses and professions (DNFBPs) which lead to the rating of non-compliant in

Recommendation 32 and partially compliant in Recommendations 22 and 23.

In preparation for the submission of the 1st regular Follow-Up Report to the APG in January

2019, the Macao SAR enacted Law no. 6/2017 to cover the gap on Recommendation 32 (cross

border declaration of cash and BNIs), and with the collective efforts of all supervisory agencies

proceeded with the amendment and update of their respective guidelines in order to minimize the

gaps identified in the report, all the revised sector guidelines were effective in 2018 and early 2019.

The Macao SAR submitted the 1st regular Follow-Up Report to APG in January 2019 regarding

the progress of the follow-up actions, with the expectation of upgrades in re-rating for the above 3

recommendations.

Being the coordinator of the AML/CFT Working Group of Macao SAR, GIF participated in

the Annual Meeting of APG from 18th to 23rd August 2019 in Canberra, Australia, together with

representatives of the Working Group members, including CCAC, SPU, DSAJ, AMCM, DSE,

DICJ, SA and PJ. During the meeting, Macao SAR successfully upgraded the remaining 3 FATF

Recommendations to largely compliant ratings, and became the first member which passed all

40 FATF Technical Compliance Recommendations among all globally evaluated members at the

moment. Once approved by all APG members, the Follow-Up Report underwent a stringent ex-

post review process, whereby the report had been circulated to the FATF and its global network

members to ensure the quality and consistency of the evaluation standard. After review, the Follow-

Up Report was published on the websites of the FATF and the APG in October 2019.

The successful milestones achieved in the AML/CFT regime of Macao SAR are built

on the long-time support of all the AML/CFT Working Group members and respective private

sectors. Moreover, this new outcome has escalated the AML/CFT regime to a higher level which


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clearly demonstrates the high commitment of Macao SAR towards AML/CFT work, and also the

determination of Macao SAR to combat related crimes.

3.3 The 2nd Round ML/TF Risk Assessment of Macao SAR and Future Preparation Work

The 1st round ML/TF Risk Assessment for the Macao SAR was completed in 2015 and

released to stakeholders in 2016. As required by the FATF, members are required to continue to

conduct regular Risk Assessments in the areas of ML, TF and PF. In early 2018, GIF convened an

interdepartmental AML/CFT Working Group to re-establish a Risk Assessment steering committee

to launch the 2nd round of the Macao SAR’s Risk Assessment project on ML, TF and PF (referred to

as the 2nd round Risk Assessment).

In 2018, a total of approximate 2,000 questionnaires were sent out by the supervisory

authorities for data collection, involving the participation of thousands of private entities, including

financial institutions, gaming concessionaries/sub-concessionaries, gaming intermediaries and

other DNFBPs, such as real estate intermediaries and agents, dealers of precious metals and

stones, pawn shops, car dealers, notaries and professionals including accountants, auditors,

lawyers, and company service providers, etc. GIF will continue to coordinate with the financial

and DNFBP supervisory authorities to pay visits to business associations, organize seminars

and workshops as well as distribution of publications to raise the awareness of private entities to

understand the ML/TF risks of their sectors and the requirements under the respective AML/CFT

guidelines, in order to have risk-based approach management and risk mitigation measures in place.

In 2019, the supervisory authorities conducted in-depth analysis and collation of the

questionnaires collected, the content and results of the questionnaires had been compiled in

various sector review reports. The 5 sector review reports had been finalized by the end of 2019,


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including for the financial sector, the gaming sector, the real estate sector, the dealers of high unit

value products and the company service providers. In addition, the TF threat analysis report, as

well as the NPO review report had also been completed. The relevant data of the crime threat

analysis report had been basically consolidated. GIF held several meetings with the judicial and

LEAs during the year, discussed the scope and methods of the study for the regional crime threat.

In addition, in accordance with the requirements of international organizations for the

functions of FIU, strategic analysis should be conducted in different areas. In view of this, GIF

regularly conducts thematic studies and analysis reports in different fields to understand the ML

risks and capital flow of different industries. In 2019, the thematic studies and analysis reports that

GIF had conducted includes: NPO, enhanced CDD information, cross-border cash declaration

system, study on the risk for gaming industry, and STR typologies etc. (see section 3.1 for details).

Based on the current ME procedures of APG, Macao SAR is scheduled to have its 5th

year ME Follow-Up Assessment in 2023/2024. In order to have better preparation of the coming

Assessment, the AML/CFT Working Group is planning to commence the 3rd round overall ML/

TF Risk Assessment. Being the coordinator of the AML/CFT Working Group of Macao SAR, GIF

will invite experts from neighboring and overseas jurisdictions to provide thematic trainings and

seminars, preliminarily topics included risk assessments, VAs and virtual asset service providers

(VASPs), asset confiscation and recovery etc.

3.4 Coordination of the Asset Freezing Coordination Commission

In accordance with Article 5 of Law No. 6/2016 Asset Freezing Regime and Chief Executive

Ruling No. 291/2016, the Asset Freezing Coordination Commission (hereafter as “the Commission”)

was established on 1st September 2016, with the following members namely the SPU (Coordinator),

MP, SA, DSAJ, AMCM, GIF (the Secretariat of the Commission) and PJ. The Commission is mainly


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responsible for setting up, maintaining and updating the public database available on its website,

for the lists of the designated natural and legal persons and entities, as well as the record of frozen

assets, communicating to the entities in accordance with the Law, providing guidelines to ensure

the entities to implement their obligations and duties, and issuing technical opinions.

The Commission held 2 meetings in 2019, to discuss the actual implementation for asset

freezing and the procedures of a timely notification mechanism, etc. GIF, being the Secretariat

of the Commission, also held 3 meetings with individual department and supervisory agencies.

In 2019, the Commission had issued several notifications to the supervisory agencies on the

publication of UNSCR in the official Gazette of the Macao SAR.

In order to ensure the effective implementation of the “Asset Freezing Regime” and to raise

the awareness of the industry about the responsibilities and obligations of the relevant laws, the

Secretariat of the Commission (GIF) incorporated the relevant content of the “Asset Freezing

Regime” in the routine AML/CFT trainings provided to the industry. In 2019, GIF provided 6

trainings to different sectors, including real estate agents, jewelry and pawn shops, car dealers,

auction business as well as AML related associations. GIF also provided six thematic seminars on

the "Asset Freezing Regime", which were co-organized with DICJ, to the 6 Concessionaires and

junkets operators, with more than 500 participants.


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The Asset Freezing Coordination Commission Meeting

3.5 Participation of International Bodies Activities

ML and TF crimes never confine themselves to the border of a jurisdiction 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 SAR joined the APG in 2001 and GIF joined the

Egmont Group in 2009. As a member, Macao SAR has been proactively enhancing its AML/CFT

efforts through the participation in the meetings as well as the assessment missions of member

jurisdictions. These commitments not only fulfill the obligations of the Macao SAR being a member

of the international organization, but also enhance the international status of the Macao SAR.

3.5.1 Chairing of ME Working Group

Since September 2013, the Legal Counsel of GIF was appointed as one of the Co-Chairs of

the APG ME Working Group (MEWG). The core function of the MEWG is to support implementation


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of the 3rd round ME under the new assessment methodology and to communicate any outcome

with the APG Secretariat. The MEWG discusses the MER, prior to their discussion and approval in

Plenary, makes recommendations to members concerning some key issues related to each MER

and Follow-Up Reports. The MEWG is also responsible to manage the program of training and

allocation of assessors for the 3rd round ME, contribute to the development and implementation

of procedures and mechanisms to help ensure quality and consistency in ME, including handling

follow-up procedures. In August 2019, the Legal Counsel of GIF had successfully sought the

election as Co-Chair of the MEWG during the APG Annual Meeting for a 3-year term.

Being one of the Co-Chairs of the MEWG, the Legal Counsel of GIF has been participating in

assessor training workshops to provide training to potential assessors and reviewers of the APG,

FATF and other FATF Style Regional Bodies (FSRBs). In March and September 2019, the Legal

Counsel of GIF attended FATF and APG’s evaluation expert training workshop and served as a

mentor to assist member jurisdictions to deepen their understanding of new assessment methods.

3.5.2 Participation in ME of other APG Member Jurisdictions

Being the member of the APG, another commitment of Macao SAR is the nomination of

assessors for the 3rd round APG ME. After joining the assessor training workshops organized by the

APG in the past few years, a number of representatives from the AML/CFT Working Group have

committed themselves to take up assessment work for other APG member jurisdictions, in order to

fulfill its duties as a member of an international organization.

In 2019, the Director of GIF and two representatives from the AML/CFT Working Group have

taken up the assessor role in the ME of APG members, Tonga, Vietnam and Philippines, with one

of the MER adopted in the 2019 APG Annual Meeting. With the invitation from FATF, the Legal

Counsel of GIF has also taken up the assessor role for the ME of Indonesia in 2019. Aside from


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that, another 2 representatives have committed themselves as reviewers of APG members’ Follow-

Up Reports according to their own professional areas.

Director of GIF participated the APG ME of Tonga

3.5.3 Representative of APG North Asia Region Steering Group and Related Work

During the 2017 APG Annual Meeting, Macao SAR has been nominated as the APG North

Asia Region Steering Group Representative for a term of one year. The duty of the APG North

Asia Region Steering Group Representative is to coordinate the works between North Asia

Region members and APG Secretariat. Members of the Steering Group had voted for the next

representative in the 2018 APG Annual Meeting, according to the requirement, Macao SAR would

be the substitute representative from year 2018 to 2019, in order to provide assistance to the

steering group. Later in August 2019, members of the Steering Group had reached the consensus


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that the representative remained unchanged, while Macao SAR was also invited to continue its role

as the substitute representative.

3.6 International Cooperation

Technological innovations can always bring significant benefits to the financial system and

broaden the economic scale; but at the same time, it will also pose emerging threats to financial

stability, and may also be exploited by criminals to perform cross-border transfer of illicit proceeds

in seconds. GIF understands that international cooperation is the key to success in the prevention

and suppression of ML and TF. Therefore, GIF has been actively seeking opportunities to establish

cooperation and financial intelligence exchange channels to foster cooperation with overseas FIUs.

Up to 2019, there were 27 foreign jurisdictions established an information exchange

mechanism under the format of MOUs with GIF.

The following table indicates the data on information exchange between GIF and foreign

counterparts during 2019:

Table 4: Statistical Data of Information Exchange

Apart from intelligence exchanges with foreign counterparts, GIF also seeks opportunities to

strengthen other forms of cooperation in AML/CFT with neighboring regions.

2019 Number

Incoming Requests for Information 33

Outgoing Requests for Information 81

Intelligence Received 14

Intelligence Sent 14


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AML/CFT Tripartite Meeting between Mainland China, Hong Kong SAR and Macao SAR

Since 2013, tripartite cooperation mechanism in relation to AML/CFT regime has been

established between Mainland China, Hong Kong SAR and Macao SAR and 3 meetings had been

held under this mechanism. In order to foster the cooperation mechanism, GIF hosted the 4th AML/

CFT Tripartite Meeting on 10th January 2019 in Macau. The Anti-Money Laundering Bureau of

the People’s Bank of China (China), the Financial Services and the Treasury Bureau (Hong Kong

SAR) and GIF (Macao SAR), in the capacity of respective heads of delegation of each jurisdiction,

coordinated about 70 representatives from judicial, law enforcement and supervisory agencies

of the 3 jurisdictions to join this meeting. Representatives of the 3 jurisdictions shared their

experiences and exchanged opinions on various issues, including the latest laws and regulations,

supervisory measures and international trends in combating ML/TF. In addition, the challenges

encountered during the FATF/APG ME and Risk Assessment were also discussed during the

meeting. The outcome of the meeting is substantial and fruitful.

AML/CFT Tripartite Meeting between Mainland China, Hong Kong SAR and Macao SAR


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GIF visited Anti-Money Laundering Bureau of the People’s Bank of China and China Anti-Money Laundering Monitoring and Analysis Center

With the opportunities posed by the development of the Guangdong-Hong Kong-Macao

Greater Bay Area, the cooperation and exchange of commercial and economic activities

between Mainland China and Macao SAR have become more frequent. To further strengthen the

cooperation and bilateral communication, GIF visits the Mainland’s AML departments on a regular

basis. On 12th September 2019, the Director of GIF together with 3 GIF representatives went to

Beijing and visited the AML Bureau of the People’s Bank of China (PBOC) and the China Anti-

Money Laundering Monitoring and Analysis Center (CAMLMAC). This meeting mainly focused on

experience sharing of ME for the 2 jurisdictions, conducted in-depth discussion and experience

sharing on the statistics of STRs, as well as typologies and latest AML/CFT trends. GIF will

continue to strengthen the cooperation and communication with the FIU in Mainland China, in order

to maintain stable financial system development and financial security.

GIF visited the AML Bureau of the PBOC


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GIF visited the CAMLMAC

3.7 Attending International Conferences

As a responsible member of international organization, GIF proactively participated in

international conferences and the assessment missions of member jurisdictions. The international

conferences participated in 2019 are as follows:

Table 5: List of International Conferences

Table 4: List of International Conferences4.4

Quarters Conferences Venues

1st QuarterEgmont Group Meeting Jakarta, Indonesia

FATF Plenary Meeting Paris, France

2nd Quarter 23rd EU - Macao Joint Committee Meeting Brussels, Belgium

3rd Quarter26th Egmont Group Plenary Meeting 2019

Hague, Netherlands

APG Annual Meeting and Technical Assistance Forum Canberra, Australia

4th Quarter 5th Counter-Terrorism Financing Summit Manila, Philippines


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FATF Plenary Meeting was held in France

26th Egmont Group Plenary

Meeting was held in the Netherlands

23rd EU - Macao Joint Committee Meeting was

held in Belgium


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APG Annual Meeting and Technical Assistance Forum was held in Australia

5th Counter-Terrorism Financing Summit was held in the Philippines


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3.8 Local Cooperation

3.8.1 Cooperation among Government Agencies

Information sharing and collaboration is fundamental to GIF’s operations. Maintaining

effective partnerships with all the relevant government agencies has been a cornerstone of GIF’s

work. Partnerships and collaboration continued to be crucial to the success of cross-agency

task forces in the past year to achieve the objective of fighting ML/TF. During 2019, the following

meetings were held among legal departments, supervisory agencies and LEAs:

Judicial Authorities and LEAs

- A meeting was held with MP, AMCM and PJ in February to discuss the revision of

financial laws.

- Three bilateral meetings between PJ and GIF were held in March, August and October

to discuss the enhancement on sharing of financial intelligence, threat analysis in risk

assessment and the five-year AML/CFT strategic plan.

- A meeting was held with SA and PJ in April to discuss the implementation of the law of “Control

of the cross-border transportation of cash and BNIs” and to foster tripartite cooperation for

data collection and statistical analysis.

- A meeting was held with MP in June to discuss the cooperation mechanism of information

exchange in electronic format.

- A tripartite meeting was held with DICJ and PJ in August to discuss the thematic risk

assessment report on STR typologies.

- A meeting with the Court, MP, CCAC, DSAJ and PJ was held in December to organize the


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first meeting of the working group of central coordination mechanism and asset recovery

mechanism.

Supervisory Agencies

- Several meetings between AMCM and GIF were held between April and October, of

which 2 regular bilateral meetings. Discussion topics included the follow-up work on risk

assessment, highlights of STR cases for financial sector, sharing of information on STR

quality and compliance, five-year AML/CFT strategic plan as well as cooperation in AML/

CFT training, seminar and public awareness campaign.

Legal Departments

- A meeting with DSAJ was held in November to discuss the five-year AML/CFT strategic plan

and the revision of laws and regulatory system related to AML.

Interdepartmental Risk Assessment Meeting

- A meeting with MP, SPU, AMCM, DICJ, DSE, PJ and IH was held in July to discuss the risks

identified in the 2nd round Risk Assessment, the planning and time schedule of the next

round Risk Assessment as well as the 5th year follow-up assessment work.

3.8.2 Joint Meeting on Prevention and Suppression of Financial Crimes

Since 2018, AMCM, PJ, GIF and representatives from various financial institutions

established a routine cooperation mechanism - Public Private Partnership in order to strengthen

the information exchange and cooperation mechanism among the LEAs, regulatory agencies and

the financial sector. In 2018, 2 “Joint Meetings on Prevention and Suppression of Financial Crimes”


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were held, while the 3rd and 4th joint meetings had been held on 29th January 2019 and 15th July

2019 respectively. Discussion topics mainly focused on the latest trends of financial crimes and

suspicious transactions and the implementation of the revised AML/CFT guidelines. Participants

also proactively explored feasible cooperation mechanism to respond to the evolving financial

crime trends, in order to work together in combating ML and financial crimes.

“Joint Meeting on Prevention and Suppression of Financial Crimes”

3.8.3 Communication with Private Sector

In 2019, GIF met with many reporting entities in different industries to discuss the statistics,

typologies and recent trends of the STR. In addition, GIF also enquired about the latest market

development of new payment methods and services, so as to review and amend the relevant AML/

CFT preventive measures when necessary.

GIF will continue to meet with the industry through regular meetings to listen to the views

of all parties and maintain effective communication with all sectors to elevate the effectiveness of

AML/CFT in Macao SAR.


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GIF met with Macao Development Bank Limited

GIF met with Macau Pass S.A.


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GIF met with Luso International Banking Limited

GIF met with Banco Comercial de Macau, S.A.


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GIF met with OCBC Wing Hang Bank Limited

GIF met with Tai Fung Bank Limited


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3.9 Public Awareness Program

GIF continued to raise public awareness on AML/CFT through publications and coordination

of on-going training programs. During 2019, GIF organized a series of public awareness programs

for different sectors and public, including trainings tailored to different stakeholder groups and the

publication of newsletters and annual reports, as well as the website and WeChat Official Account

with updates on AML/CFT issues accessible to the public.

GIF will continue to conduct different types of public awareness programs in order to

deliver AML/CFT knowledge to the public and other practitioners, for the betterment of economic

environment and development for Macao SAR.

3.9.1 Local Training for GIF Staff and other Government Agencies

During 2019, the following training sessions had been attended by staff of GIF and other

government agencies of the AML/CFT Working Group:

Table 6: List of Local Trainings and Seminars

Quarters Topics of Trainings/Seminars Organizers

1st Quarter

Global Financial Crisis and Regulatory Reform: Basel III

Macau University of Science and Technology (MUST)

Cybersecurity Privacy and Data Protection Law in America and Europe

The Macao Association of Banks

2nd Quarter

Seminar on Famous Economists MUST

FinTechstic Innovation and Opportunity

Talents Development Committee and

Macau Institute of Financial Services (IFS)

Financial Leasing Laws and Relevant Tax Incentives AMCM


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“Training on New Payment Methods and POS Transactions”

2nd Quarter

Real Estate Industry and the Greater Bay AreaAssociation of Property

Agents and Realty Developers of Macau

Supervision of Financial Leasing AMCM

New Payment Methods and Point of Sale Transactions AMCM

New Trust System in Macao CFJJ

Controlling Financial Crimes in the Greater Bay Area, Especially on Understanding the

Relationship Between Cybersecurity, Privacy and Freedom of Speech

University of Saint Joseph(USJ)

Enhancing Practical Tools and Techniques for AML/CFT

Macau Anti-Money Laundering Specialists

Association

4th Quarter Network Specialist Event 2019 Office for Personal Data Protection (GPDP)


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3.9.2 Overseas Training for GIF Staff and other Government Agencies

As globalization of financial crimes become more obvious, GIF, foreign LEAs and FIUs have

further strengthened the cooperation on suppressing ML and TF activities. Thus, GIF participated in

a number of trainings/workshops organized by international organizations. The overseas trainings

participated in 2019 are as follows:

Table 7: List of Overseas Trainings

Quarters Organizers Content Venues

2nd Quarter International Monetary Fund (IMF)

Course on Implementing the International AML/CFT Standards Singapore

4th Quarter FATF FATF Supervisors’ Forum 2019 Sanya, China

Course on Implementing the International AML/CFT Standards was held in Singapore


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In addition, the Legal Adviser of GIF attended the APG Assessor Training workshops as an

instructor in New Zealand and Indonesia in March and September 2019 respectively. The details of

workshops are as follows:

Table 8: List of APG Assessor Training workshops

APG Assessor Training was held in New Zealand

3.9.3 Training for Government Agencies and Private Sector

Raising the awareness of supervisory departments and reporting entities on their AML/CFT

obligations is always crucial to the functions of GIF. During 2019, the following training sessions

had been conducted for the staff of government departments, the compliance departments and

management of different industries. Details are as follows:

Quarters Organizers Content Venues

1st Quarter APG APG Assessor Training Auckland, New Zealand

3rd Quarter APG Joint APG/FATF Assessor Training Bandung,Indonesia


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Industries Training Target

Banking Industry Financial Institutions

Gaming Industry Gaming Intermediaries

Precious Goods DealersJewelry Stores and Pawn Shops

Automobile Dealers

Auction Industry Auction Companies

Real Estate Industry Real Estate Agents


Government Agencies

DSE

SA

Narcotics Control Committee


Financial Institutions

Luso International Banking Limited

Banco Comercial de Macau, S.A.

Industrial and Commercial Bank of China (Macau) Limited

Bank of Communications Company Limited

Agricultural Bank of China Macao Branch

Macao Development Bank

Tai Fung Bank Limited

China Taiping Life Insurance (Macau) Company Limited

OthersUSJ

Macau Anti-Money Laundering Specialists Association

Sectoral training – Total number of participants: 750

Government officials training – Total number of participants: 70

Individual training – Total number of participants: 1,200

Table 9: List of trainings and seminars organized by GIF


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Real Estate Agents

Banking Industry

GIF Provided AML/CFT

training to DSE


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Luso International Banking Limited

Banco Comercial de Macau, S.A.

Industrial and Commercial Bank of China (Macau) Limited


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Bank of Communications Company Limited

Agricultural Bank of China Macao Branch

Macao Development Bank


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Tai Fung Bank Limited

China Taiping Life Insurance (Macau) Company Limited

USJ


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3.9.4 Global Money Week/Financial Education Day

Education is crucial in the prevention and suppression of money laundering and terrorist

financing, in order to raise the public awareness of AML/CFT to juveniles, GIF participated in the

“2019 Global Money Week” organized by Macau IFS in March 2019. AML/CFT seminars were

held for MUST, City University of Macao and Macau Polytechnic Institute to discuss about AML/

CFT legal requirements and the preventive measures. Over 250 students participated in these

seminars.

In addition, GIF also participated in the “2019 Financial Education Day” held by Macau IFS in

September 2019. In this event, knowledge of AML and related financial knowledge were promoted to

local residents through seminars and booth games, etc. Over 150 attendees participated in this event.

GIF participated in the “2019 Global Money Week”


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GIF participated in the “2019 Financial Education Day”

AML/CFT Training at the “2019 Financial Education Day”


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3.10 Courtesy Visit from/to Other Entities

GIF had received several courtesy visits from educational institutions including University of

Macau and MUST in September 2019. Through these visits, GIF introduced the AML/CFT related

works conducted by the Macao SAR government, as well as trends, typologies of STRs and related

financial knowledge, so as to raise the awareness of AML/CFT for university students and juveniles .

GIF met with the representatives from University of Macau

GIF met with the representatives from MUST


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CHAPTER IV ADMINISTRATION


4.1 Means of STR Submission

GIF has launched the Online STR Reporting System (secured website) for 8 years. Through

this secured and efficient way to submit STR, paper consumption can be reduced and hence, it is

more environmental friendly. The table below shows the utilization rate of the 3 current methods of

STRs submission in the past 3 years.

Table 10: Statistical Data for the Methods of STRs Submission

Methods of Submission

Number of STRs

2017 % 2018 % 2019 %

Paper Form 281 9.1% 407 10.9% 401 13.6%

Encrypted Email 32 1.0% 29 0.8% 0 0.0%

Secured Website 2,772 89.9% 3,280 88.3% 2,540 86.4%

Total 3,085 100% 3,716 100% 2,941 100%

From the data above, secured website and paper form are the main methods of submission

of STRs. As encrypted email was suspended since January 2019, therefore, no STR was

submitted via encrypted email. In 2019, a total of 2,540 STRs were submitted through secured

website, which accounted for 86.4% of the total submission rate. Out of these 2,540 STRs, 1,905

STRs were submitted by the gaming sector, while 635 STRs were submitted by the financial sector.

As the Online STR Reporting System has been widely used in gaming and financial industries, it is

expected that the submission of STRs through secured website will continue to grow in the future.


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4.2 Enhancement in Information Security and Management

GIF always improves the service of Online STRs Reporting System. In 2019, a new function

for batch processing was introduced. By using a modal and structural data exchange file format,

data verification was performed via uploading files and multiple new STRs can be automatically

generated, thus the data of STRs can be input in batch, which further enhanced the efficiency of

data input and data accuracy. Referring to this new function, GIF has invited some reporting entities

to conduct trials in the 2nd quarter of 2019. During that period, GIF worked closely with the users

of the respective entities for improving and optimizing the function. The trial results were positive

with some proposals for further improvements, which formed the basis for next stage in functional

development and improve user experience. Those entities had formally used this new function to

submit STRs in the second half of the year, with utilization rate exceeding 90%. GIF will continue

to promote this new function to other reporting entities in the near future.

GIF always stay alert to the importance of information and cybersecurity. With the

implementation of the Cybersecurity Law, GIF continued to strengthen the infrastructure of

information system and ensure that the requirements for cybersecurity are properly in place. In

2019, more resources were allocated to cybersecurity with a series of measures adopted, such as

enhancement of GIF’s Standard of Operation Procedures, employment of the security and audit

system logs, procurement of essential network equipment, upgrading the information systems

and applications, research on various types of hardware and software solutions for security

reinforcement and establishing a more comprehensive cybersecurity management system. From

the perspectives of systems, requirements, procedures and guidelines, the above measurements

were adopted to ensure the reliability of network and operations of information system, as well

as data integrity, confidentiality and reusability, so as to strengthen the defensive capability and

resilience of GIF’s cybersecurity.

APPENDIX – GLOSSARY


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AMCM Monetary Authority of Macao (Autoridade Monetária de Macau)

AML/CFT Anti-Money Laundering/Combating the Financing of Terrorism

APG Asia/Pacific Group on Money Laundering

ATM/CDM Automated Teller Machine/Cash Deposit Machine

BNIs Bearer Negotiable Instruments

CCAC Commission against Corruption (Comissariado contra a Corrupção)

CAMLMAC China Anti-Money Laundering Monitoring and Analysis Center

CDD Customer Due Diligence

CFJJ Legal and Juridical Training Centre (Centro de Formação Jurídica e Judiciária)

CIEPDSS Independent Committee for the Exercise of Disciplinary Power over Solicitors

(Comissão Independente para o Exercício do Poder Disciplinar sobre

os Solicitadores)

CPSP Public Security Force (Corpo de Polícia de Segurança Pública)

DICJ Gaming Inspection and Coordination Bureau (Direcção de Inspecção e

Coordenação de Jogos)

DNFBPs Designated Non-financial Businesses and Professions

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)

EU European Union



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FATF Financial Action Task Force

Fintech Financial Technologies

FIU Financial Intelligence Unit

FSRBs FATF Style Regional Bodies

GPDP Office for Personal Data Protection (Gabinete para a Protecção de

Dados Pessoais)

GIF Financial Intelligence Office (Gabinete de Informação Financeira)

GIFCS Group of International Finance Centre Supervisors

IFS Institute of Financial Services

IH Housing Bureau (Instituto de Habitação)

IMF International Monetary Fund

IPIM Macao Trade and Investment Promotion Institute (Instituto de Promoção do

Comércio e do Investimento de Macau)

IT Information Technology

LEAs Law Enforcement Agencies

Macao SAR Macao Special Administrative Region

ME Mutual Evaluation

MER Mutual Evaluation Report

MEWG Mutual Evaluation Working Group

ML/TF Money Laundering / Terrorist Financing

MOU Memorandum of Understanding

MP Public Prosecutions Office (Ministério Público)

MUST Macau University of Science and Technology



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NPO Non-profit Organization

PBOC People’s Bank of China

PF Proliferation Financing

PJ Judiciary Police (Polícia Judiciária)

SA Macao Customs Services (Serviços de Alfândega)

SPU Unitary Police Services (Serviços de Polícia Unitários)

STR Suspicious Transaction Report

USJ University of Saint Joseph

UNSCR United Nations Security Council Resolution

VAs Virtual Assets

VASPs Virtual Assets Service Providers

financial intelligence office 2019 - moneylaundering.com

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