On 31 March 2018, the Macao Trade and Investment Promotion Institute (IPIM) has issued the revised guidelines on Preventive Measures on Anti-Money Laundering and Combating the Financing of Terrorism based on the amendments made by Law No. 3/2017 and the Administrative Regulation No. 17/2017 to assist commercial and auxiliary offshore services institutions, to fulfil their obligations preventing money-laundering and combating terrorist financing.
There are six obligations that these services institutions have to fulfil:
- take appropriate steps to identify and verify the identity of a customer(s);
- detect any suspicious activities of money laundering or financing terrorism;
- when the required information to assist the services institutions in complying (1) and (2) is not provided, they should refuse carry out operations;
- retain supporting documents in relation to (1) and (2) for a least 5 years;
- report operations or attempts to carry out operations combating money laundering or terrorist financing to the Office of Financial Intelligence, regardless of the amount of money involved;
- co-operate with the responsible authorities for the prevention and repression of crimes relating to money laundering and terrorist financing.
How can institutions mitigate potential risks:
- Effective Internal control: the IMPI has suggested a list of internal control guidance for services institutions, some of these guidelines are:
- establish ongoing employee training;
- introduce an independent internal control mechanism; and
- appoint an officer at the management level to oversee the control mechanism.
- Due diligence: obtain adequate information for a thorough background check of a customer and the beneficial owner (i.e. who ultimately owns or controls the customer) when there is an indication of crime of money-laundering and financing terrorism.
- Enhanced monitoring: when dealing with “politically exposed persons”, the institutions should take reasonable steps to verify if the customer is linked to high risk operations, and confirm the source of funds for the business activities.
How can JLA assist?
Our forensic accounting team comprises of a diverse group of experienced professionals from various backgrounds with experience in casino and junket operations. We can assist you to:
- identify and detect suspicious transactions and activities that may involve in money laundering;
- funds tracing and assets search; and
- assess and provide opinion on corporate governance / internal controls review.