Abstract
This paper makes a detailed analysis of the legal mechanisms in place in the Macau Special Administrative Region for the prevention and detection of money laundering through the gaming industry, especially in casinos. The discussion covers the basic pillars which are customer due diligence, record keeping and reporting of transactions to the government. The system in place in the gaming sector has the unique feature that it requires the systematic disclosure of all transactions above a specific amount, a rule that does not exist in the field of banking. The paper analyzes the data available on transactions reported since 2007, when the new financial intelligence unit completed its first full year in operation. The particular challenges presented by the peculiar structure of the Macau gaming market, which is heavily dependent on gaming promoters (known as 'junkets') are discussed.
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