Creating Compliance Programs for Casino "Anti-Money Laundering" Regulations


Effective November 13, 2006, the Macao .Administrative Regulation no. 7/2006 became enforceable. This law, entitled, “Anti-Money Laundering (A.ML) and Combating Financing of Terrorism (CFT) Guideline for Financial Institutions,” provides specific guidelines specifically for creating procedures that must be in place to prevent money laundering activities. It also provides guidelines for testing for compliance of suspicious activities. While these guidelines are designed specifically for financial Institutions, casinos will fall into this classification as well. It is anticipated that more specific guidelines will be developed for casinos. This paper provides an overview of that law and discusses approaches that need to be developed to provide assurance that this regulation is taken seriously and properties are in compliance.


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