--- title: "Macau SAR (CN-MO) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/macau-sar/ source_html: /jurisdictions/macau-sar/index.html description: "Financial integrity intelligence for CN-MO (CN-MO): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 5fa1d8636ceb71bcf64250be807e17a5e5e1e6ea07ce374012ae95a11c40e329 generator: "fe-fleet/md-twin@1.0" --- # Macau SAR (CN-MO) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Macau SAR CN-MO Domains covered 8 of 8 Sources 179 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Stable Enablement vs enforcement: Mixed Macau's AML/CFT regime (Laws 2/2006, 3/2006, 13/2023 gaming reform, DICJ/AMCM instructions) covers banks, casinos and junket promoters, with the Gabinete de Informação Financeira (GIF) as an autonomous FIU. More Post-2021 gaming-law overhaul cut licensed junket operators sharply and tightened concessionaire oversight, but no central beneficial-ownership registry or virtual-asset licensing regime exists. Key deficiencies - No public central beneficial-ownership registry; reliance on company-registry filings and DNFBP CDD - Historically low money-laundering conviction rate versus STR/case volume (APG MER finding, structurally unresolved) - No virtual-asset service provider (VASP) licensing framework, unlike neighbouring Hong Kong - Junket-successor underground banking and credit-card offsetting channels continue to be exploited for cross-border laundering - Political vetting of electoral candidates and press self-censorship narrow independent civil-society scrutiny of AML enforcement (F1 state-capture signal) Recent developments (18m) - September 2025: 12 opposition candidates disqualified from Legislative Assembly elections on vetting grounds, resulting in an all pro-Beijing legislature - 2026: Taiwan prosecutors indicted 10 individuals in a NT$33bn (~US$1.03bn) laundering ring exploiting Macau casino credit-card loopholes - Continuing post-2023 DICJ clampdown on junket operations and enhanced concessionaire supervision under the 2022 Gaming Reform Bill - March 2025: Labour Union Law entered into force, part of a wider post-pandemic governance and diversification push - Gaming revenue recovery through 2025 (July/August 2025 GGR beating estimates) increasing cash-intensive transaction volumes exposed to ML risk Brief ## Lead signal #### Lead Signal A court-adjacent ruling has newly reinforced the Monetary Authority of Macau's 2017 prohibition on banks and payment institutions participating, directly or indirectly, in cryptocurrency-related services. Secondary coverage of the case indicates that the finding treats the 2017 ban as integrated into what Macau's legal order describes as its economic public order, a framing that elevates the prohibition from supervisory instruction to a structural feature of how the territory organises its financial perimeter. The prohibition itself is not new; what has changed is the degree to which it now appears anchored in a higher-order legal concept rather than resting solely on regulatory notice. This is assessed at the probable level, reflecting secondary-source confirmation rather than a primary judicial text. Read full brief #### Lead Signal A court-adjacent ruling has newly reinforced the Monetary Authority of Macau's 2017 prohibition on banks and payment institutions participating, directly or indirectly, in cryptocurrency-related services. Secondary coverage of the case indicates that the finding treats the 2017 ban as integrated into what Macau's legal order describes as its economic public order, a framing that elevates the prohibition from supervisory instruction to a structural feature of how the territory organises its financial perimeter. The prohibition itself is not new; what has changed is the degree to which it now appears anchored in a higher-order legal concept rather than resting solely on regulatory notice. This is assessed at the probable level, reflecting secondary-source confirmation rather than a primary judicial text. The significance of this development lies less in any single enforcement outcome than in what it says about the durability of Macau's crypto-services posture. A prohibition framed as part of economic public order is markedly harder to unwind or narrow through ordinary regulatory amendment than one resting on a circular, and firms operating around Macau's banking and payment rails should read this as confirmation that the restriction is structural rather than transitional. #### Other Developments Draft AML law overhaul tracked again at consultation stage. The proposed replacement for Law No. 2/2006, which would introduce licensing requirements for virtual asset operators together with administrative fines for unlicensed operation, remains at the consultation and drafting stage, with no primary legislative or gazette text located confirming submission to, or passage by, the Legislative Assembly. No change in legislative posture is recorded this cycle beyond the continued pendency of the draft. No sanctions, enabler-jurisdiction, conflict-finance, compliance-technology, or commercial-activity signal located. No Macau-nexus development meeting the bar for inclusion was identified in these areas this cycle; the absence is recorded as a stable baseline rather than as a finding in itself. #### Cross-Monitor Connections The reinforcement of the crypto-services ban through an economic-public-order framing has a natural connection to monitors tracking digital-asset architecture and state-level capital controls more broadly, since a jurisdiction that treats exclusion of bank-channel crypto activity as a matter of public order is signalling a degree of regulatory intent that goes beyond routine financial supervision. It also bears on monitors tracking correspondent-banking and cross-border payment exposure, given that Macau's banks and payment institutions sit at the intersection of the prohibition and any attempt by counterparties to route crypto-linked value through conventional channels. #### Outlook The near-term picture for Macau's financial-integrity posture is one of structural continuity punctuated by a single reinforcing judicial-adjacent development. The draft AML law overhaul, which would for the first time give Macau a legal definition of virtual assets and VASPs together with a licensing and fines regime, remains unconfirmed as to timing; as scheduled, impact is not expected before 2027. Firms with any crypto-adjacent exposure through Macau-domiciled banks or payment institutions should treat the existing prohibition as entrenched rather than as a position likely to soften, irrespective of how the licensing framework under the draft law eventually resolves. Earlier periodic briefs (6) 4 Nov 2026 · fim-2026-11-01 #### Lead Signal A court-adjacent ruling has newly reinforced the Monetary Authority of Macau's 2017 prohibition on banks and payment institutions participating, directly or indirectly, in cryptocurrency-related services. Secondary coverage of the case indicates that the finding treats the 2017 ban as integrated into what Macau's legal order describes as its economic public order, a framing that elevates the prohibition from supervisory instruction to a structural feature of how the territory organises its financial perimeter. The prohibition itself is not new; what has changed is the degree to which it now appears anchored in a higher-order legal concept rather than resting solely on regulatory notice. This is assessed at the probable level, reflecting secondary-source confirmation rather than a primary judicial text. The significance of this development lies less in any single enforcement outcome than in what it says about the durability of Macau's crypto-services posture. A prohibition framed as part of economic public order is markedly harder to unwind or narrow through ordinary regulatory amendment than one resting on a circular, and firms operating around Macau's banking and payment rails should read this as confirmation that the restriction is structural rather than transitional. #### Other Developments Draft AML law overhaul tracked again at consultation stage. The proposed replacement for Law No. 2/2006, which would introduce licensing requirements for virtual asset operators together with administrative fines for unlicensed operation, remains at the consultation and drafting stage, with no primary legislative or gazette text located confirming submission to, or passage by, the Legislative Assembly. No change in legislative posture is recorded beyond the continued pendency of the draft. No sanctions, enabler-jurisdiction, conflict-finance, compliance-technology, or commercial-activity signal located. No Macau-nexus development meeting the bar for inclusion was identified in these areas; the absence is recorded as a stable baseline rather than as a finding in itself. #### Cross-Monitor Connections The reinforcement of the crypto-services ban through an economic-public-order framing has a natural connection to monitors tracking digital-asset architecture and state-level capital controls more broadly, since a jurisdiction that treats exclusion of bank-channel crypto activity as a matter of public order is signalling a degree of regulatory intent that goes beyond routine financial supervision. It also bears on monitors tracking correspondent-banking and cross-border payment exposure, given that Macau's banks and payment institutions sit at the intersection of the prohibition and any attempt by counterparties to route crypto-linked value through conventional channels. #### Outlook The near-term picture for Macau's financial-integrity posture is one of structural continuity punctuated by a single reinforcing judicial-adjacent development. The draft AML law overhaul, which would for the first time give Macau a legal definition of virtual assets and VASPs together with a licensing and fines regime, remains unconfirmed as to timing; as scheduled, impact is not expected before 2027. Firms with any crypto-adjacent exposure through Macau-domiciled banks or payment institutions should treat the existing prohibition as entrenched rather than as a position likely to soften, irrespective of how the licensing framework under the draft law eventually resolves. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Macau's financial-integrity posture is structurally stable as at 25 October 2026, with the one development of substance being judicial rather than legislative. Macau's Court of Final Appeal, in a ruling reported on 4 October 2026, upheld a refusal to register a trademark for cryptocurrency-related services on grounds tied to economic public order, reinforcing the territory's existing prohibition on virtual-currency services through the judiciary rather than through new statute. The ruling does not itself change the law; it confirms that the courts will sustain the existing administrative line against commercialising crypto-branded services under the current framework. #### Other Developments A pending overhaul of the anti-money-laundering framework remains under consultation. A bill addressing virtual-asset-service-provider licensing, a beneficial-ownership register, and judicial asset-freeze powers has been under sectoral consultation since June 2026, with no confirmed tabling before the Legislative Assembly and no procedural movement identified in this window. The current regime, anchored in Law 2/2006 as amended by Law 3/2017, has no statutory definition of virtual assets or virtual-asset service providers; the prevailing industry practice is a blanket prohibition on banks and payment institutions dealing in virtual currencies rather than a licensing gateway. The proposed overhaul would introduce formal legal definitions, an authorisation requirement for virtual-asset-service-provider operation, administrative fines for unlicensed activity, and asset-freezing powers over crime-linked virtual assets. Macau's standing AML/CFT architecture continues unchanged. The regime remains anchored in Law 2/2006 as amended by Law 3/2017, Administrative Regulation 7/2006 as amended by 17/2017, and DICJ Instruction 1/2016 as amended and republished by Instruction 1/2019, with the Gabinete de Informação Financeira (GIF) functioning as the financial intelligence unit and the Asia/Pacific Group on Money Laundering (APG) as the relevant mutual-evaluation body, Macau being an APG rather than a FATF member in its own right. GIF has itself noted the inherent AML risks of the concession sector and the reliance of concessionaires on that sector, framing continued sectoral risk rather than a new finding. Separately, Macau, China co-chaired the APG's Mutual Evaluation Committee per the APG's 2024-25 annual report, a standing governance fact rather than a new development. #### Cross-Monitor Connections The pending beneficial-ownership register proposal and the crypto-services judicial reinforcement both carry relevance beyond financial-integrity analysis narrowly defined. The gambling-sector monitor tracks the same concession structure that GIF has flagged as an inherent AML risk driver, given concessionaire reliance within that sector. The crypto and digital-assets monitor would be the natural home for deeper tracking of how the Court of Final Appeal's economic-public-order reasoning might be invoked in future rulings affecting virtual-asset commercialisation in Macau, a question this brief does not resolve further here. #### Outlook The principal watch item remains whether the AML-overhaul bill is formally tabled at the Legislative Assembly, with current estimates pointing to the first quarter of 2027 as scheduled, though this has not been confirmed from a primary legislative source. Until tabling occurs, the virtual-asset provisions and beneficial-ownership register remain proposals under consultation rather than binding obligations. On the judicial side, the Court of Final Appeal ruling raises the question of whether its economic-public-order reasoning will be applied again in future cases touching crypto-adjacent commercial activity in Macau; no further litigation on this point has been identified in this window. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Macau SAR's Court of Final Appeal (TUI) has, in a trademark-registration case reported on 17 October 2026, folded the Monetary Authority of Macao's longstanding institutional prohibition on virtual-currency dealing into the territory's concept of economic public order. The case did not arise as a direct regulatory challenge; it concerned an attempt to register a trademark for cryptocurrency-related services. But the reasoning the court applied reaches further: by treating AMCM's bar on licensed financial institutions directly or indirectly participating in or providing financial services related to virtual currencies as integral to Macau's public economic order, the court has given that restriction a constitutional-adjacent weight it did not previously carry as a mere supervisory notice. A dissenting judge took the narrower view that the matter was properly one of trademark and intellectual-property law and should not have been used to pronounce on the scope of the crypto restriction. This is the first appellate-level characterisation found of how far Macau's de facto digital-asset restriction extends, and it raises the practical bar for any future party seeking to contest or narrow that restriction through the courts. The ruling lands against a backdrop of a parallel legislative process already under way. A draft Law to Combat Money Laundering and Illicit Financing, in sectoral consultation since mid-2026, would for the first time give Macau statutory definitions of virtual assets and virtual asset service providers, impose a prior-authorisation requirement, establish a beneficial-ownership register, ban anonymous accounts and shell banks, and grant judges real-time powers to suspend transactions across bank, gaming, payment and virtual-asset accounts. No tabling date before the Legislative Assembly has been identified, and this remains a standing consultation position rather than a dated development this cycle. #### Other Developments Junket-linked asset recovery continues its multi-year tail. Macau's Court of First Instance has listed seven properties, with combined reserve prices exceeding MOP137 million, belonging to Levo Chan, the jailed former chairman of junket operator Tak Chun Group, for sale by sealed bid. The listing follows enforcement proceedings brought by ICBC (Macau) to recover approximately MOP198.91 million. The action illustrates the continuing asset-recovery consequences flowing from Macau's junket and VIP-room enabler network years after the underlying conduct, a structural feature of the territory's financial-integrity landscape rather than an isolated incident. The Prosecutor General has flagged an evidentiary design gap. At the opening of the 2026/2027 judicial year, Prosecutor General Tong Hio Fong said that establishing the offence of illegal currency exchange requires proving not merely that an exchange was unauthorised but that it constituted an ongoing, profit-making business. That evidentiary burden, he said, hampers enforcement against gambling-linked illegal money exchange, a channel long associated with Macau's junket ecosystem. No bill or gazette text addressing this gap yet exists; the remarks stand as a public acknowledgement of a structural weakness in the current offence as drafted. #### Cross-Monitor Connections The TUI ruling and the pending AML/virtual-asset bill both sit squarely at the intersection of financial integrity and digital-asset regulation, a connection relevant to crypto-sector monitoring of Macau given the territory's unusual posture of maintaining a blanket institutional crypto restriction while simultaneously moving toward a statutory VASP authorisation regime. The junket-linked asset recovery and prosecutorial evidentiary-gap remarks both connect to the gambling-sector money-movement channels that have historically been a primary enabler vector out of Macau, a theme that continues to warrant attention wherever gaming-adjacent capital flows intersect with cross-border payment monitoring. #### Outlook The near-term picture for Macau combines judicial reinforcement of the status quo crypto restriction with a slow-moving legislative overhaul still in consultation. As scheduled, the draft AML/virtual-asset law remains without a confirmed tabling date, and its eventual effect on Macau's enabler-jurisdiction profile will depend heavily on whether the beneficial-ownership register and VASP authorisation provisions survive into the enacted text. The evidentiary gap flagged by the Prosecutor General suggests that even if the legislative overhaul proceeds, practical enforcement against gambling-linked money exchange may continue to lag the letter of the law. Readers should watch for any dated legislative milestone on the draft law, and for any further judicial engagement with the scope of the AMCM crypto restriction following the TUI's economic-public-order characterisation. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Macau's financial-integrity posture this cycle is defined by two converging threads inside its crypto and beneficial-ownership architecture rather than by any enforcement event. The Macau Court of Final Appeal (TUI) has affirmed, via an 'economic public order' doctrine, that the Monetary Authority of Macau's (AMCM) 2017 prohibition on licensed financial institutions dealing in cryptocurrencies is integrated into the structural economic order of the Macau Special Administrative Region. Separately, and on a different statutory track, the Macau SAR Executive Council has put forward a draft AML overhaul that would, for the first time, create a formal licensing or authorisation gateway for virtual-asset service providers, a central corporate beneficial-ownership register, and real-time court-ordered account-freeze powers. #### Other Developments The TUI ruling reframes, rather than replaces, Macau's existing crypto posture. AMCM's prohibition on crypto-dealing by banks and payment institutions has stood since a September 2017 notice; what the TUI decision adds is a constitutional-style anchoring of that prohibition as part of the jurisdiction's economic public order, a doctrine ordinarily reserved for foundational features of the economic system. This is reported via a single Tier-2 press account, and the underlying judgment itself has not been independently retrieved, so the finding is carried at Probable confidence. The AML-overhaul draft , reported via two independent press sources citing Tribuna de Macau, would amend Law No. 2/2006 (money laundering) and Law No. 3/2006 (terrorism financing) to end corporate anonymity through a central companies register and grant judges power to suspend financial transactions in real time. No Tier-1 primary instrument has been retrieved, and there is no evidence the draft has progressed beyond sectoral consultation to the Legislative Assembly. Macau's payment-sector architecture remains structurally informal by comparison: as of 26 May 2026 four entities hold 'other financial institution' payment licences on the AMCM register, authorised not under a dedicated payment-services statute but via a discretionary Chief Executive despacho under Article 3º(1)(13) of Lei n.º 13/2023, with no published fee schedule or statutory decision period. This single-source finding is carried at Uncertain confidence. Macau's FATF-adjacent standing is unchanged: Macao, China is assessed by the Asia/Pacific Group on Money Laundering rather than by FATF directly, and is not on the FATF grey list. A Macau delegation attended the 2026 APG Annual Meeting, with no new mutual-evaluation report or follow-up outcome located this cycle. #### Cross-Monitor Connections The VASP-licensing strand of the AML-overhaul draft is directly relevant to the crypto monitor's coverage of Macau's licensing vacuum, and the TUI's economic-public-order doctrine deserves attention there as a judicial reinforcement of the existing prohibition rather than a new rule. The payment-institution despacho-authorisation finding connects to the world-payments monitor's market-access tracking for Macau, where the same structural gap -- authorisation without a dedicated statute -- is independently surfaced. #### Outlook The draft AML overhaul is the development to watch: if it progresses to the Legislative Assembly, it would be Macau's first legislative creation of a VASP gateway and its first central beneficial-ownership register, materially closing two long-standing gaps simultaneously. Until formal legislative text is tabled, both the beneficial-ownership and VASP-licensing elements remain consultation-stage proposals rather than confirmed reforms, and the TUI's economic-public-order reasoning stands as the operative judicial basis for the existing crypto-dealing prohibition in the meantime. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Macau's draft replacement of its 2006 AML/CFT framework (Laws 2/2006 and 3/2006) has moved into active sectoral consultation, and for the first time proposes a central beneficial-ownership register that would end corporate anonymity in the jurisdiction's company-formation architecture. The Financial Intelligence Office (GIF) met the Macau Lawyers Association in April 2026 to exchange views on the revision, a Tier-1 confirmation that the revision process is genuinely underway, though the draft's granular provisions - virtual-asset-service-provider licensing with administrative fines, real-time judicial transaction-suspension powers, tiered administrative sanctions, and fifteen-year document retention - are corroborated only through secondary and tertiary press rather than the draft text itself. The status remains consultation, not enactment; no submission to the Legislative Assembly has been located. This is architecture-over-incident: a jurisdiction long criticised for permitting anonymous corporate vehicles behind gaming-sector capital flows is for the first time building the register that would close that gap, and the significance lies in the structural shift being proposed, not in any single enforcement action. #### Other Developments A judicial ruling has clarified the legal basis for Macau's long-standing informal crypto-services prohibition. The Court of Second Instance (TSI) held that the Monetary Authority of Macao's prohibition on licensed financial institutions handling crypto-asset-related transactions is integrated into the Macau Special Administrative Region's "economic public order" doctrine, treating it as a fundamental principle of the Macau economic system rather than a mere administrative circular. A dissenting judge questioned the scope of treating a general prohibition as settled doctrine, suggesting the boundary between a general ban and a narrower, targeted prohibition remains judicially contested. This ruling matters because Macau has no dedicated statutory virtual-asset-service-provider framework; enforceability of the crypto prohibition has rested until now on regulatory practice rather than codified law, and the TSI's reasoning gives that practice a firmer judicial foundation pending the AML overhaul's proposed VASP licensing regime. The IMF concluded its 2026 Article IV Consultation with Macao SAR on 24 September 2026 , with the Staff Report published 29 September 2026. The Fund stated that ongoing efforts to strengthen AML/CFT are welcome and should be sustained, and linked the contraction in the VIP and junket segment partly to the stricter licensing, gaming-credit limits, and strengthened AML/CFT enforcement introduced under the 2022 gaming-law reforms. The specific wording of the Board Assessment was corroborated through a tertiary aggregator rather than the IMF's own site directly this pass, a gap that affects source-tier confidence on the precise phrasing without undermining the underlying fact that the consultation concluded and that this was its substantive message. Macau's sanctions-implementation architecture remains structurally unchanged. The jurisdiction continues to implement United Nations Security Council measures - covering counter-terrorism, the Democratic People's Republic of Korea, and Afghanistan - through its Asset Freezing Coordination Commission. Former Iran-related restrictions were removed in 2024. Macau does not operate an autonomous EU, US or UK-style listing regime that diverges from the UN baseline; no new designation activity was identified this period. #### Cross-Monitor Connections The beneficial-ownership register proposal connects directly to the gambling-sector concession architecture that the advennt monitor tracks: Macau's gaming concessionaires sit at the centre of the corporate-anonymity gap the draft law targets, and the statutory Article 22 concession-performance review reportedly now in its assessment phase explicitly includes AML controls within scope, meaning the two reform tracks - gaming-concession oversight and AML/CFT-law revision - are running in parallel against the same underlying vulnerability. The TSI's crypto ruling similarly intersects with the crypto monitor's coverage of Macau's informal prohibition on licensed financial institutions processing crypto-exchange transfers; the judicial reinforcement of that prohibition, absent a dedicated VASP statute, is the same underlying fact the crypto domain sub-brief below addresses from a digital-asset-architecture angle rather than a financial-integrity angle. #### Outlook The near-term marker to watch is whether Macau's draft AML/CFT law overhaul advances from sectoral consultation to a Legislative Assembly submission; GIF's engagement with the Macau Lawyers Association in April 2026 indicates the process is live, but no enactment timeline has surfaced. A second marker is whether the TSI's economic-public-order reasoning is tested further, given the recorded dissent on the scope of the ruling, which leaves room for a narrower reading of the crypto prohibition to be argued in a subsequent case. Separately, in Cambodia the IMF's 2026 Article IV finding that the Law on the Management of Commercial Gambling requires only a 'good reputation' test for major shareholders and senior managers, with no source-of-funds verification, flags a structural beneficial-ownership vetting gap ahead of an approximately 2027 mass casino-licence-renewal window - a comparator worth tracking against Macau's own BO-register proposal as two enabler-adjacent gaming jurisdictions move at different speeds on the same underlying vulnerability. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Macau has opened a sectoral consultation on a draft law that would replace the AML/CFT regime it has operated under since Law 2/2006, introducing a central beneficial-ownership register, virtual-asset operator licensing, a ban on anonymous accounts and shell banks, fifteen-year record retention, and judicial power to suspend transactions in real time. The reform is described as expected around 2027 and would be implemented in phases. Two independent secondary sources describe the consultation's content, though no primary consultation instrument was retrieved this cycle, and the Financial Intelligence Office of the Public Security Police has itself signalled that the measures still need refinement before finalisation. This reform sits against a standing baseline of technical strength: Macau's own Financial Intelligence Office reports that Macau became the first APG-assessed member to achieve largely-compliant-or-better ratings across all 40 FATF Recommendations on technical compliance, following a 2017 mutual evaluation and 2019 follow-up submission. Macau is not a FATF member and is instead assessed by the Asia/Pacific Group on Money Laundering (APG); as of the FATF publication dated 13 February 2026, Macau does not appear on the FATF grey list or high-risk list. The consultation therefore represents an architecture-level upgrade attempt layered on top of an already technically strong compliance record, rather than a remediation of an identified deficiency. #### Other Developments Virtual-asset posture remains cautionary-only pending the consultation's outcome. No comprehensive VASP licensing regime is currently in force in Macau; the Monetary Authority of Macau (AMCM) has issued cautionary guidance only, without a structural licensing or supervisory framework specific to virtual-asset service providers. The draft AML law under sectoral consultation would introduce licensing requirements for virtual-asset operators with administrative fines attached to unauthorized operation, closing a gap that currently leaves virtual-asset activity governed only by general financial-services prohibitions rather than a dedicated licensing and supervisory regime. Beneficial-ownership transparency would be a first for Macau. The proposed central register of beneficial ownership, if enacted, would establish Macau's first formal record of the individuals who ultimately control companies operating in or through the jurisdiction. This would align Macau's corporate-transparency architecture more closely with FATF Recommendations 24 and 25 on beneficial ownership of legal persons and arrangements, recommendations against which Macau's current framework does not yet have a dedicated register-based mechanism. #### Cross-Monitor Connections The AML-law consultation's virtual-asset licensing proposal connects directly to the crypto monitor's tracking of Macau's crypto_licensing posture, where the same consultation is read as a prospective end to the current prohibition-by-extension regime administered by AMCM. It also connects to the advennt gambling-regulatory monitor's tracking of Macau's own sectoral AML consultation, since Macau's gaming sector is a significant financial-flow channel that any beneficial-ownership or virtual-asset licensing reform would ultimately need to reach. No world-payments-monitor connection beyond the general payments-licensing environment was identified this cycle; the consultation's payment-institution touchpoints are noted but not elaborated here. #### Outlook The consultation's own acknowledged need for refinement, combined with an expected implementation date around 2027 and a phased rollout design, suggests a multi-year path to enactment rather than an imminent legal change. The key watch items are: whether a primary consultation document or Boletim Oficial notice becomes available to confirm the reform's precise scope; whether the virtual-asset licensing and beneficial-ownership provisions survive refinement intact; and whether Macau's strong technical-compliance baseline is maintained or tested as the new regime, if enacted, moves toward implementation. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion The defining D1 development this cycle is a concurrent OFAC sanctions action and FinCEN supplemental alert targeting a fuel-smuggling and tax-evasion network tied to CJNG, designating two Mexican nationals and nine entities and building directly on the May 2025 Cartel Oil Smuggling Alert covering stolen Pemex crude (fim-2026-W32-006). Read architecturally, this is not an isolated designation but the newest layer in a widening unilateral United States sanctions architecture toward Mexico that already includes FinCEN Section 2313a special measures against three named Mexican financial institutions, in force since 21 July 2025, a proposed Section 311 measure against Mexico-based gambling establishments pending since November 2025, and OFAC sanctions against casinos linked to Cartel del Noreste imposed in April 2026 (fim-2026-W32-007). Four distinct instruments, two statutory authorities, and multiple target classes, financial institutions, gambling establishments, and named individuals and entities, are being deployed against a single national sanctions-evasion ecosystem inside a twelve-month window, a tempo that itself is the architectural signal. Continue reading A second sanctions-architecture thread runs through the FATF grey-list risk facing Cambodia. The active crackdown against scam-linked casinos, which has closed or revoked licences for between 72 and 91 operators and culminated in the extradition to China of Prince Group chairman Chen Zhi following prior United States sanctions action and asset confiscation, is being conducted explicitly under the shadow of a possible third grey-list placement, as the Governor of the National Bank of Cambodia has warned (fim-2026-W32-004). This is a sanctions-adjacent architecture in a different register from Mexico: rather than a bilateral designation regime, it is the multilateral FATF listing mechanism functioning as the disciplining force behind a sovereign enforcement pivot. The prior US sanctions action against Prince Group is the proximate trigger; the FATF process is the structural constraint sustaining the crackdown beyond the initial designation. The draft AML/CFT law of Macau intersects with this same architecture from a third angle. The reform is understood, per this cycle assessment, as framed partly as pre-emptive FATF alignment ahead of the forthcoming Mutual Evaluation of China, expected around the third quarter of 2026 and carrying downstream implications for Macau and Hong Kong AML/CFT posture, though confidence in that evaluation timing is low, resting on a single lower-tier source. Read together, three jurisdictions, Mexico, Cambodia, and Macau, are each responding to a different node of the same FATF-anchored global sanctions and listing architecture: one through unilateral United States designation pressure, one through direct grey-list exposure, and one through anticipatory legislative reform. What is structurally notable by absence this cycle is the lack of a matched European Union or United Kingdom divergent-listing action against any of the Mexican targets sanctioned or special-measured by the United States this cycle, and the lack of any fresh-cycle movement on the standing Russian sanctions-evasion architecture tracker. In the FIM analytical register, non-enforcement and non-listing in otherwise well-regulated jurisdictions is itself a signal: an escalating unilateral United States architecture against Mexico-linked terrorist-organisation finance, unaccompanied by parallel EU or UK listing action, is the foundation of a measurable sanctions-divergence pattern rather than a settled cross-bloc consensus. #### Outlook The pending Section 311 special measure against Mexico-based gambling establishments is the near-term checkpoint for this domain; its disposition will indicate whether the current unilateral escalation broadens into a formal financial-access restriction or is allowed to lapse. Whether Cambodia sustains its enforcement tempo through the next FATF plenary will determine whether the grey-list risk currently flagged by the National Bank Governor converts into an actual third placement, a result that would in turn sharpen the pre-emptive-alignment reading of the Macau reform. The FATF Mutual Evaluation of China, if it proceeds on the expected third-quarter 2026 timeline, is the structural event most likely to test whether Macau reform commitments translate into supervisory practice, though this remains a low-confidence horizon item pending stronger sourcing. Judgment: No Macau-nexus sanctions signal located this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency Macau has no central beneficial-ownership register in force as at 25 October 2026. The directly relevant development is the pending AML-overhaul bill, under sectoral consultation since June 2026, which proposes a beneficial-ownership register for the first time alongside virtual-asset-service-provider licensing and judicial asset-freeze powers. No confirmed tabling of the bill before the Legislative Assembly has been identified, and current estimates point to the first quarter of 2027 as scheduled for a finalised framework, though this timing has not been confirmed from a primary legislative source. Macau's AML/CFT regime in its current form, anchored in Law 2/2006 as amended by Law 3/2017 and Administrative Regulation 7/2006 as amended by 17/2017, does not itself establish a beneficial-ownership register; the register proposal is a gap-filling response rather than an amendment to an existing mechanism. Continue reading Globally, the EU AML Package sets the structural direction for beneficial-ownership transparency: the AML Regulation (Reg (EU) 2024/1624, directly applicable across Member States), the sixth AML Directive (6AMLD, transposed per Member State), and the AMLA Regulation (Reg (EU) 2024/1620) establishing the Anti-Money Laundering Authority together move supervision of cross-border obliged entities from a purely national basis toward a hybrid EU-level regime with direct and indirect supervisory tiers. Macau sits entirely outside this perimeter; the AMLR, 6AMLD and AMLA Regulation have no direct application to Macau's own beneficial-ownership framework. This structural fact is useful backdrop for comparing the shape of Macau's own proposed register against a jurisdiction that has already moved toward supranational supervision, but it does not alter or accelerate Macau's own timeline. Macau's financial intelligence unit, the Gabinete de Informação Financeira (GIF), and the territory's mutual-evaluation body, the Asia/Pacific Group on Money Laundering (APG), continue to operate under the standing framework described above; Macau, China co-chaired the APG's Mutual Evaluation Committee per the APG's 2024-25 annual report. Neither GIF nor APG has published a beneficial-ownership-specific finding within this window beyond the general sectoral-risk statement GIF has made about concession-sector reliance. #### Outlook The principal watch item for beneficial ownership is whether the AML-overhaul bill is formally tabled at the Legislative Assembly, with current estimates pointing to the first quarter of 2027 as scheduled. Until tabling occurs, the beneficial-ownership register and the broader virtual-asset provisions remain proposals under consultation rather than binding obligations. A confirmed tabling, or a published bill text, would be the next concrete marker of progress toward a register actually coming into force. Judgment: Draft AML law targeting a first central BO register remains at consultation/drafting stage. Probable #### Enabler Jurisdictions and Professional Facilitators This cycle documents three enabler-jurisdiction postures moving in different directions, and the contrast between them is the analytical product. Cambodia is pivoting sharply from tolerance to active enforcement: the National Bank and the Commercial Gambling Management Commission have closed or revoked licences for between 72 and 91 casinos, and the extradition to China of Prince Group chairman Chen Zhi, following prior United States sanctions action and asset confiscation, marks the removal of a central node in the scam-casino enabler ecosystem (fim-2026-W32-004). The Governor of the National Bank has framed this enforcement drive explicitly around avoiding a third FATF grey-list placement, meaning the crackdown is disciplined by an external multilateral mechanism rather than purely domestic policy choice, an important distinction when assessing whether the pivot represents capacity newly acquired or compliance newly compelled. Continue reading Laos presents the opposite trajectory. The Golden Triangle Special Economic Zone remains a standing, largely extraterritorial enabler architecture, anchored by Kings Romans Casino under US-sanctioned Zhao Wei, and no new-cycle enforcement event was identified against it (fim-2026-W32-005). The zone continues to function with limited jurisdictional access for the Lao state itself, a structural rather than episodic condition: this is not a jurisdiction failing to enforce against a discrete violation but a jurisdiction whose sovereign reach over a specific territorial enclave is itself constrained. In the FIM analytical register this is precisely the case where absence of enforcement action is the signal, and where the relevant question is one of capacity deficit rather than policy choice. Macau occupies a third position: an enabler-adjacent jurisdiction with functioning, if imperfect, professional-facilitator controls. The dual reporting obligation to DICJ and the Financial Services Bureau, applying to accountants serving gaming companies, continues to operate as a designated-enabler control point, and DICJ has opened 22 administrative infraction proceedings against concessionaires since the 2022 reform, with five sanctioned and ten closed for insufficient evidence (fim-2026-W32-003). The draft AML/CFT law under consultation, proposing a shell-bank and anonymous-account ban alongside its other provisions, would extend this control architecture further into precisely the corporate-layering channels that professional facilitators have historically used (fim-2026-W32-001). Rising suspicious-transaction-report volume, up 8.7 percent year on year in the first half of 2026, indicates that the existing reporting architecture is at minimum generating volume, whatever the ultimate conviction rate (fim-2026-W32-002). Read together, these three cases illustrate that enabler-jurisdiction status is not a fixed category but a spectrum along which jurisdictions move, and move at different speeds and for different reasons: Cambodia under external multilateral pressure, Laos constrained by a structural sovereignty carve-out over a specific enclave, and Macau incrementally extending an already-functioning reporting and administrative-sanctions architecture. #### Outlook Whether the Cambodia enforcement pivot is sustained through the next FATF plenary, rather than relaxing once the immediate grey-list threat recedes, is the central test of whether this represents durable capacity change or temporary compliance. The Golden Triangle Special Economic Zone in Laos has no scheduled remedy on the horizon and should be tracked as a persistent structural risk rather than an emerging one. The Macau draft law, if enacted, would represent the most concrete near-term movement of the three, extending professional-facilitator and corporate-transparency controls ahead of the forthcoming FATF Mutual Evaluation of China. Judgment: No change to Macau's wide DNFBP AML supervision perimeter; AMCM-PBoC AML MoU confirmed via T1 source. Probable #### Conflict Finance and Extractive-Industry Integrity The single but structurally significant D4 development this cycle concerns an oil-revenue-corruption financing channel now the direct subject of primary regulatory action. FinCEN issued a supplemental alert on fuel-smuggling and tax-evasion schemes affecting the southern border, concurrent with an OFAC sanctions action designating two Mexican nationals and nine entities, tied to a scheme in which stolen Pemex crude is smuggled and falsely documented through customs channels to evade Mexican fuel taxation, with the resulting proceeds funding cartel operations linked to CJNG (fim-2026-W32-006). This is a Tier-1, directly confirmed primary-regulator finding, and it sits squarely within the extractive-industry-integrity remit of this domain: it is not simply a sanctions-evasion case but a documented mechanism by which control over an extractive commodity, refined fuel derived from state-owned petroleum production, is converted into non-state armed-group financing through customs-documentation fraud and tax evasion. Continue reading The architectural significance of this finding lies in its structure rather than its scale alone. Falsified customs documentation is the specific enabling mechanism identified, meaning the vulnerability sits at the trade-documentation and customs-verification layer rather than purely at the point of physical smuggling. That this scheme builds directly on a prior May 2025 Cartel Oil Smuggling Alert covering stolen Pemex crude indicates a persistent, rather than one-off, exploitation of the same documentation-integrity gap over at least a thirteen-month window, and that FinCEN found it necessary to issue a second, supplemental alert on the same underlying commodity-theft architecture is itself evidence that the first alert did not close the exploited gap. This finding also connects directly to the broader sanctions architecture tracked under D1: the same OFAC action that designates the fuel-smuggling network sits alongside FinCEN Section 2313a special measures against Mexican financial institutions and a pending Section 311 casino measure, indicating that the conflict-finance and sanctions-evasion dimensions of the current Mexico-focused enforcement effort are being pursued as a single integrated architecture rather than as separate regulatory tracks. For extractive-industry-integrity purposes specifically, the case illustrates a financing channel structurally distinct from the more commonly tracked conflict-mineral or artisanal-extraction typologies: here the extractive asset is a refined petroleum product from state-owned production, and the integrity failure occurs downstream, at the point of customs documentation and tax administration, rather than upstream at the point of extraction itself. No other D4-relevant development, in conflict-mineral financing, extractive-sector corruption, or armed-group resource control, was surfaced elsewhere in the jurisdictions covered this cycle; this domain therefore stands on a single, well-corroborated Tier-1 finding rather than a broader cross-jurisdictional pattern this cycle. #### Outlook The direct cross-reference of this finding to ERM for its commodity-flow dimension is the most immediate next step for cross-monitor synthesis, given the direct relevance of cross-border fuel-smuggling volumes to broader commodity-market integrity tracking. Whether FinCEN or OFAC issues further supplemental guidance on the same documentation-fraud mechanism, indicating whether the underlying customs-verification gap has been narrowed since the May 2025 alert, is the concrete marker to track in coming cycles. Judgment: No conflict-finance signal located for Macau this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Macau's position on digital assets has, for several cycles, rested on a comparatively simple architecture: the Monetary Authority of Macau issued a notice in September 2017 explicitly prohibiting banks and payment institutions from directly or indirectly participating in cryptocurrency-related services. That instrument has now received reinforcement from a different direction. Secondary coverage of a court-adjacent ruling arising from an intellectual-property trademark dispute indicates that the 2017 prohibition has been treated as integrated into Macau's economic public order, a legal concept that sits above ordinary regulatory notice in the hierarchy of what a jurisdiction treats as foundational to its functioning. This is recorded at the probable confidence level, since the finding reaches this brief through secondary reporting rather than through a retrieved primary judicial text. Continue reading The practical effect, if the framing holds, is to make the existing ban considerably more durable than a typical supervisory notice. A rule anchored in public order is not readily displaced by routine regulatory revision; it would ordinarily require a more deliberate legal process to narrow or remove. For banks, payment institutions, and any crypto-asset operator contemplating a Macau nexus through conventional financial rails, this is best read as confirmation that the prohibition on bank-channel crypto services is structural rather than a position likely to be revisited in the near term. This sits alongside, but is distinct from, the separate and still-pending draft AML law overhaul, which would for the first time give Macau a legal definition of virtual assets and virtual-asset service providers, introduce licensing requirements for virtual asset operators, and impose administrative fines for unlicensed operation. That draft remains at the consultation and drafting stage; no primary legislative or gazette text has been located confirming a change in its legislative posture since the consultation launch. The draft, if enacted, would run alongside rather than displace the existing AMCM prohibition on bank and payment-institution participation in crypto-services: licensing of virtual asset operators under a future law would not, on current indications, extend to permitting banks or payment institutions to resume the activity the 2017 notice forecloses. The two instruments therefore address different layers of the same posture, one defining and licensing non-bank virtual-asset activity, the other continuing to wall off the banking and payments sector from it. The current state of play is thus a jurisdiction that is simultaneously building a licensing architecture for virtual-asset operators outside the banking sector while reinforcing, through an unrelated legal proceeding, the separateness of banks and payment institutions from that same activity. Firms assessing Macau exposure should treat these as two distinct and only loosely coupled developments rather than as stages of a single reform. #### Outlook As scheduled, the draft AML law overhaul is not expected to reach enactment before 2027, and no primary source has yet confirmed submission to the Legislative Assembly, so its eventual shape and timing remain genuinely uncertain. The reinforced bank-channel prohibition, by contrast, should be treated as settled for planning purposes: nothing in the available material suggests Macau authorities are reconsidering the separation of banks and payment institutions from cryptocurrency-related services, and the public-order framing noted this cycle points toward greater rather than lesser durability. Any future licensing regime for virtual-asset operators is likely to be read by Macau authorities as a parallel non-bank channel rather than as a route back into bank participation. Judgment: A court-adjacent ruling newly reinforces AMCM's 2017 crypto-services ban as part of Macau's economic public order. Probable Judgment: No material RegTech/AI-transaction-monitoring guidance update located for Macau this cycle. Uncertain #### AML/CTF Regime Macau's draft Law to Combat Money Laundering and Illicit Financing remains in sectoral consultation, a status unchanged since mid-2026 and carrying no newer dated development within this cycle's window. The draft would replace the territory's existing AML framework under Law 2/2006 with a considerably more extensive regime: statutory definitions of virtual assets and virtual asset service providers, a requirement for prior authorisation before operating as a VASP, a central beneficial-ownership register, a ban on anonymous accounts and shell banks, and real-time judicial powers to suspend transactions across bank, gaming, payment and virtual-asset accounts. No tabling date before the Legislative Assembly has been identified, so the standing consultation position continues without a confirmed legislative timetable. Continue reading Two developments this cycle illustrate the gap between the AML regime as it currently stands and the regime the draft law would create. First, the Court of Final Appeal's reasoning treating AMCM's institutional crypto restriction as part of economic public order, while framed as a digital-asset question, underscores how much of Macau's current AML-adjacent architecture for virtual assets rests on administrative notice and now judicial interpretation rather than primary statute, precisely the gap the draft law is designed to close through formal VASP definitions and authorisation. Second, and separately, the Prosecutor General's remarks at the opening of the 2026/2027 judicial year identified a concrete evidentiary weakness in the existing illegal-currency-exchange offence: prosecutors must prove not only that an exchange was unauthorised but that it amounted to an ongoing, profit-making business, a standard that has hampered enforcement against gambling-linked illegal money exchange. This remark, together with the continuing court-ordered sale of jailed junket boss Levo Chan's property portfolio exceeding MOP137 million following ICBC (Macau) enforcement proceedings to recover roughly MOP198.91 million, illustrates that Macau's AML enforcement is still substantially occupied with the multi-year tail of its junket-era enabler network even as the legislature contemplates a forward-looking overhaul. #### Outlook The draft AML law continues to sit in consultation without a confirmed tabling date, as scheduled, and the gap it is designed to close, around virtual-asset definitions, beneficial ownership, and evidentiary thresholds for currency-exchange offences, remains open in the interim. The Prosecutor General's public acknowledgement of a design gap in the illegal-currency-exchange offence suggests that legislative attention may eventually extend beyond the virtual-asset provisions already drafted to address enforcement mechanics more broadly. Readers should watch for a confirmed tabling date and for whether the beneficial-ownership register and VASP authorisation provisions are carried through to enactment in substantially their consulted form. Judgment: Governing instrument and supervisory architecture (Law 2/2006, DICJ, AMCM; APG member) unchanged this cycle. Probable Judgment: No financial-integrity-sector commercial transaction located for Macau this cycle. Uncertain Regulatory horizon No dated horizon items this cycle. 3 items tracked without a confirmed date. 3 pending date · baseline fim-2026-07-05 Role action cards MLRO ### Macau bank-channel crypto-services prohibition gains reinforcement from a public-order framing in a court-adjacent ruling. The existing exclusion of banks and payment institutions from cryptocurrency-related services is now reported as anchored in economic public order rather than resting solely on regulatory notice, indicating lower likelihood of near-term softening of this restriction for reporting entities with Macau exposure. 1 evidence refs Compliance ### Macau draft AML law remains at consultation stage; no confirmed legislative progression this cycle. The proposed replacement for Law No. 2/2006, which would introduce VASP licensing and administrative fines, has not been confirmed as submitted to or passed by the Legislative Assembly, so no new compliance obligation has yet crystallised from this draft. 1 evidence refs Legal ### A ruling in an unrelated trademark matter has reportedly treated Macau's 2017 crypto-services ban as part of economic public order. Elevation of a regulatory notice to public-order status in secondary legal commentary suggests greater resistance to future legal challenge or narrowing of the prohibition, relevant to any client-instruction analysis touching Macau banking or payment relationships and crypto activity. 1 evidence refs Board ### Macau's separation of banks from crypto-services activity appears structurally entrenched rather than transitional. For institutions with Macau banking exposure, the reinforced prohibition signals that strategic planning should not anticipate near-term regulatory opening of bank-channel participation in digital-asset services. 1 evidence refs CTO ### Macau continues to exclude banks and payment institutions from direct or indirect participation in crypto-related services, now reinforced in a public-order ruling. Any technical architecture routing digital-asset activity through Macau-domiciled banking or payment rails remains foreclosed, and this cycle's development suggests that exclusion is unlikely to be relaxed through ordinary regulatory channels even as a separate non-bank licensing regime for virtual-asset operators remains in draft. 2 evidence refs Risk ### Macau crypto-services exclusion for banks is reinforced; draft licensing regime for non-bank virtual-asset operators remains pending. The risk picture bifurcates: bank-channel exposure to crypto-services risk in Macau is now assessed as more structurally durable, while the exposure profile for any future licensed non-bank virtual-asset sector remains undefined pending legislative progress. 2 evidence refs Operations ### No new operational screening or monitoring threshold change identified for Macau this cycle. The reinforced prohibition on bank-channel crypto-services participation does not itself introduce a new operational control requirement beyond the existing exclusion already in place. 1 evidence refs Audit ### No change identified to the evidentiary basis supporting Macau's crypto-services exclusion controls this cycle. The reinforcement reported this cycle is a legal-framing development rather than a change to the underlying control or its documentation, and does not itself alter audit scope for existing controls addressing the exclusion. 1 evidence refs Scenario sketches ### Divergent tracks for bank-channel exclusion and non-bank licensing One illustrative path sees Macau's eventual virtual-asset licensing regime come into force for non-bank operators while the public-order-anchored exclusion of banks and payment institutions from crypto-services remains wholly untouched, producing a bifurcated market in which licensed non-bank operators handle digital-asset activity entirely outside the conventional banking and payments system. Under this path, firms seeking banking relationships for crypto-adjacent activity in Macau would continue to find none available through regulated banks, regardless of their licensing status under the new regime. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change T2 · EU AML Package / AMLA no_change Not applicable to MO — autonomous, not an EEA member. T3 · FATF Grey List no_change Macau is an APG member ('Macao, China'), not a FATF member; no plenary outcome this cycle. T4 · Beneficial-Ownership Register Status watch Draft AML law would create Macau's first central BO register; still consultation/drafting. T5 · Crypto & Digital-Asset Integrity watch Court-adjacent ruling reinforces AMCM's 2017 crypto-services ban as part of Macau's economic public order. T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 24 Mar 2026 - UK FCDO Overseas Business Risk guidance for Macao summarizing gaming-sector economic context (country-risk overview rather than a dated DICJ enforcement action). 15 Oct 2025 - UK FCDO Overseas Business Risk guidance for Macao summarizing Legislative Assembly election disqualification numbers in 2021 and 2025 (country-risk overview rather than a financial-integrity enforcement action). 1 Sep 2025 - 30 Jun 2026 - 16 Mar 2026 - Taiwanese prosecutors indicted 10 individuals for laundering more than NT$33 billion (~US$1.03bn) in illegal gambling profits by exploiting credit-card loopholes on Macau casino gaming floors, part of a wider crackdown on Taiwan-linked underworld financial networks operating through Macau. 24 Mar 2026 - Continuing implementation of the January 2023 gaming regulations and the 2022 Gaming Reform Bill, with DICJ maintaining tightened licensing, oversight and reporting obligations on gaming concessionaires and the sharply reduced pool of licensed junket operators. 15 Oct 2025 - Ahead of the September 2025 Legislative Assembly elections, 12 opposition candidates were disqualified from standing on vetting-criteria grounds, resulting in an all pro-Beijing legislature and narrowing independent political oversight of the territory's gaming/financial governance apparatus. 1 Sep 2025 ### Sanctions changes - 4 Dec 2025 - 22 Jan 2024 - 30 Jun 2026 - The European Commission's December 2025 Delegated Regulations (EU) 2026/46 and (EU) 2026/83 updated the EU high-risk third-country AML/CFT list (adding Bolivia, the British Virgin Islands and, separately, Russia; delisting Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania). Macao was not added, leaving it outside the EU's enhanced-vigilance perimeter despite its cash-intensive casino sector. 4 Dec 2025 - The UK's Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) Regulations 2024 removed the static Schedule 3ZA list and redefined a 'high-risk third country' by direct reference to the FATF's live Increased Monitoring and Call for Action lists, meaning Macao's HRTC status now moves automatically (and only) with FATF plenary decisions. 22 Jan 2024 - FinCEN's 9 October 2025 notice reiterated the FATF's identification of high-risk jurisdictions (Iran, DPRK, Myanmar under Call for Action) and jurisdictions under increased monitoring following the FATF's October 2025 plenary; Macao was not included in either category, meaning no FinCEN advisory currently applies enhanced due diligence specifically to Macao's casino sector. 9 Oct 2025 ### Regulatory horizon (register) - UK ECCTA 2023 failure-to-prevent-fraud offence — implementation and enforcement posture - Draft law replacing Macau's 2006 AML regime - Draft law replacing Macau's 2006 AML/CFT regime - Macau AML/CFT overhaul: virtual-asset licensing, beneficial-ownership register, real-time account-freeze powers - Draft Law to Combat Money Laundering and Illicit Financing (virtual-asset definitions, VASP authorisation) - Macau AML/CFT overhaul: VASP licensing, beneficial-ownership register, asset-freeze powers - AML/CFT Law Overhaul - Macau AML/CFT Law Overhaul (replacing Law 2/2006) - Macau AML/CFT overhaul: virtual-asset licensing, beneficial-ownership register, real-time account-freeze powers - Next APG/FATF mutual evaluation of Macao under 5th-round methodology - Expiry of 10-year gaming concession licences issued November 2022 - Continued absence of a Macao virtual-asset licensing framework ### Active schemes - [HIGH] Macau casino credit-card laundering corridor - [HIGH] Triad junket-to-crypto underground banking migration - Nominee junket-promoter corporate layering Sources - [Overseas business risk: Macao - GOV.UK](https://www.gov.uk/government/publications/overseas-business-risk-macao/overseas-business-risk-macao) - [Macau Business](https://macaubusiness.com/macau-moves-to-tighten-anti-money-laundering-rules-targets-virtual-assets-media/) - [Eastern Herald](https://easternherald.com/2026/07/10/macau-casino-suspicious-transactions-first-half-2026/) - [Macao News](https://macaonews.org/features/macau-cryptocurrency-blockchain/) - [SCCG Management](https://sccgmanagement.com/sccg-news/2026/3/16/macau-regulator-opens-22-cases-against-casino-concessionaires/) - [AGB](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/) - [SiGMA](https://sigma.world/news/cambodia-anti-gambling-drive-fatf-grey-list/) - [AlienWP](https://alienwp.com/cambodia-orders-casino-inspections-and-targets-500-fraud-sites-in-2026-crackdown/) - [New Lines Institute](https://newlinesinstitute.org/global-security-mil-priorities/cybercrimes-human-trafficking-and-cryptocurrency-in-southeast-asias-special-economic-zones/) - [Radio Free Asia](https://www.rfa.org/english/news/laos/golden-triangle-11252022131629.html) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern) - [Crowell & Moring](https://www.crowell.com/en/insights/client-alerts/focus-on-transnational-cartels-continues-fincen-targets-three-mexican-financial-institutions-with-special-measures-restricting-their-access-to-us-financial-system) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-Colombia-2023.html) - [Stevens & Bolton LLP](https://www.stevens-bolton.com/insights/102jnnd/guidance-on-the-new-offence-of-failure-to-prevent-fraud-under-the-eccta-2023/) - [Practical Law (Thomson Reuters)](https://uk.practicallaw.thomsonreuters.com/w-039-9590) - [https://news.worldcasinodirectory.com/macau-advances-new-anti-money-laundering-framework-123005](https://news.worldcasinodirectory.com/macau-advances-new-anti-money-laundering-framework-123005) - [https://macaubusiness.com/macau-moves-to-tighten-anti-money-laundering-rules-targets-virtual-assets-media/](https://macaubusiness.com/macau-moves-to-tighten-anti-money-laundering-rules-targets-virtual-assets-media/) - [https://www.gif.gov.mo/en/standard/reports.html](https://www.gif.gov.mo/en/standard/reports.html) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofmacaochina.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofmacaochina.html) - [https://www.mondaq.com/corporatecommercial-law/1518954/capital-markets-comparative-guide](https://www.mondaq.com/corporatecommercial-law/1518954/capital-markets-comparative-guide) - [https://igamingbrazil.com/en/legislation-en/2026/02/16/macau-authorizes-29-operators-for-2026-and-consolidates-new-control-scenario/](https://igamingbrazil.com/en/legislation-en/2026/02/16/macau-authorizes-29-operators-for-2026-and-consolidates-new-control-scenario/) - [Macau Financial Intelligence Office (GIF)](https://www.gif.gov.mo/en/standard/published_news_details/article/kww1nji3.html) - [World Casino Directory](https://news.worldcasinodirectory.com/macau-advances-new-anti-money-laundering-framework-123005) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [Macao SAR Government](https://www.gov.mo/en/news/409918/) - [Mirage News](https://www.miragenews.com/imf-concludes-2026-consultation-with-macao-sar-1752649/) - [Macau Business (MNA)](https://macaubusiness.com/macau-moves-to-tighten-anti-money-laundering-rules-targets-virtual-assets-media/) - [GIF, Unitary Police Service, Macau SAR](https://www.gif.gov.mo/en/standard/news_events_details/article/mob8yndk.html) - [Macau Business](https://macaubusiness.com/cryptocurrencies-and-economic-public-order-how-far-does-macaus-ban-go/) - [GGRAsia](https://www.ggrasia.com/cambodias-legal-framework-for-barring-criminals-from-owning-casinos-is-deficient-says-imf) - [KnowYourCountry](https://www.knowyourcountry.com/macau) - [https://macaubusiness.com/cryptocurrencies-and-economic-public-order-how-far-does-macaus-ban-go/](https://macaubusiness.com/cryptocurrencies-and-economic-public-order-how-far-does-macaus-ban-go/) - [https://www.asiapacificnewstoday.com/article/932373304-macao-china-delegation-participated-in-the-2026-annual-meeting-of-the-asia-pacific-group-on-money-laundering](https://www.asiapacificnewstoday.com/article/932373304-macao-china-delegation-participated-in-the-2026-annual-meeting-of-the-asia-pacific-group-on-money-laundering) - [https://prifinance.com/en/payments/macau-payment-license/](https://prifinance.com/en/payments/macau-payment-license/) - [https://jtm.com.mo/local/nova-lei-de-combate-ao-branqueamento-endurece-regras-para-activos-virtuais/](https://jtm.com.mo/local/nova-lei-de-combate-ao-branqueamento-endurece-regras-para-activos-virtuais/) - [https://macaudailytimes.com.mo/court-lists-jailed-junket-bosss-properties-for-sale.html](https://macaudailytimes.com.mo/court-lists-jailed-junket-bosss-properties-for-sale.html) - [https://agbrief.com/news/macau/15/10/2026/macau-prosecutor-urges-legal-changes-over-hurdles-in-proving-illegal-money-exchange-business/](https://agbrief.com/news/macau/15/10/2026/macau-prosecutor-urges-legal-changes-over-hurdles-in-proving-illegal-money-exchange-business/) - [https://igaming-times.com/countries/macau](https://igaming-times.com/countries/macau) - [https://www.gif.gov.mo/en/standard/published_news_details/article/kww1nemy.html](https://www.gif.gov.mo/en/standard/published_news_details/article/kww1nemy.html) - [https://www.gif.gov.mo/en/standard/news_events_details/article/kytx5hff.html](https://www.gif.gov.mo/en/standard/news_events_details/article/kytx5hff.html) - [https://www.apgml.org/sites/default/files/2026-01/APG%20Annual%20Report%202024-25%20Published%20Version.pdf](https://www.apgml.org/sites/default/files/2026-01/APG%20Annual%20Report%202024-25%20Published%20Version.pdf) - [https://casinos.org/news/macau-aml-overhaul/](https://casinos.org/news/macau-aml-overhaul/) - [https://sentinel.gi/roundup/2026-09-20/](https://sentinel.gi/roundup/2026-09-20/) - [Casinos.org](https://casinos.org/news/macau-aml-overhaul/) - [GGRAsia](https://www.ggrasia.com/macau-plans-changes-to-expand-reach-of-aml-law/) - [U.S. Department of State](https://www.state.gov/reports/2026-investment-climate-statements/macau/) - [https://www.ggrasia.com/macau-plans-changes-to-expand-reach-of-aml-law/](https://www.ggrasia.com/macau-plans-changes-to-expand-reach-of-aml-law/) - [https://www.state.gov/reports/2026-investment-climate-statements/macau/](https://www.state.gov/reports/2026-investment-climate-statements/macau/) - [Mutual Evaluation of Macao, China](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofmacaochina.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html) - [Macao's measures to combat money laundering and the financing of terrorism and proliferation](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-macao-2017.html) - [Macao (China)](https://www.fatf-gafi.org/en/countries/detail/Macao-China.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Follow-up report to Macao, China's assessment of anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-macao-china-2019.html) - [Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up Universal Procedures](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Universal-procedures.html) - [Overseas business risk: Macao - GOV.UK](https://www.gov.uk/government/publications/overseas-business-risk-macao/overseas-business-risk-macao) - [The Asia/Pacific Group on Money Laundering Financial Action Task Force](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Vulnerabilities%20of%20Casinos%20and%20Gaming%20Sector.pdf.coredownload.pdf) - [Macau Arrests Second Junket Boss on Money Laundering Charges - Bloomberg](https://www.bloomberg.com/news/articles/2022-01-30/macau-arrests-second-junket-boss-on-money-laundering-charges) - [Casinos, Money Laundering, Underground Banking, and ...](https://www.unodc.org/roseap/uploads/documents/Publications/2024/Casino_Underground_Banking_Report_2024.pdf) - [Shadow Bankers – Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/shadow-bankers) - [` Anti‐money laundering and counter‐terrorist financing measures Macao, China](https://www.fatf-gafi.org/media/fatf/content/images/APG-Mutual-Evaluation-Report-Macao-China-2017.pdf) - [Macau Introduces ATM Facial Recognition to Deter Chinese Money Laundering - Bloomberg](https://www.bloomberg.com/news/articles/2017-05-08/macau-introduces-new-atm-rules-to-deter-chinese-money-laundering) - [Macau Moves Step Closer to Digital Currency in Threat to Casinos - Bloomberg](https://www.bloomberg.com/news/articles/2021-04-14/macau-moves-step-closer-to-digital-currency-in-threat-to-casinos) - [` Anti‐money laundering and counter‐terrorist financing measures Macao, China](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/APG-Mutual-Evaluation-Report-Macao-China-2017.pdf.coredownload.inline.pdf) - [Macau Plans Punishments on Gaming Violations, Regulator Says - Bloomberg](https://www.bloomberg.com/news/articles/2016-06-17/macau-plans-punishments-on-gaming-violations-regulator-says) - [Some Macau Casinos to Shut Junket-Operated VIP Rooms ...](https://www.bloomberg.com/news/articles/2021-12-07/some-macau-casinos-said-to-shut-junket-operated-vip-rooms) - [Macau New Gaming Law Approved, Casino Relicensing to Start - Bloomberg](https://www.bloomberg.com/news/articles/2022-06-21/macau-gaming-overhaul-law-approved-casino-relicensing-to-start) - [Macau’s Suncity Said to Have Ceased Its Junket Operations - Bloomberg](https://www.bloomberg.com/news/articles/2021-12-11/macau-s-suncity-said-to-have-ceased-its-junket-operations) - [Macau Casino Stocks Sink After Police Arrest City’s Junket King - Bloomberg](https://www.bloomberg.com/news/articles/2021-11-29/macau-casino-stocks-sink-after-police-arrest-city-s-junket-king) - [Watch Macau Casino Revenue Plunges on Junket Woes](https://www.bloomberg.com/news/videos/2015-10-02/macau-s-casino-revenue-plunges-on-junket-woes) - [Hong Kong Says its Crypto Regulations Will Shun Any ‘Light Touch’ Approach - Bloomberg](https://www.bloomberg.com/news/articles/2023-05-09/hong-kong-says-its-crypto-regulations-will-shun-any-light-touch-approach) - [Hong Kong gears up for new regulatory regime for crypto exchanges](https://www.elliptic.co/blog/analysis/hong-kong-gears-up-for-new-regulatory-regime-for-crypto-exchanges) - [Hong Kong Country Guide | Elliptic](https://www.elliptic.co/country-guides/hong-kong) - [Crypto regulatory affairs: Hong Kong regulator lays out cryptoasset roadmap](https://www.elliptic.co/blog/crypto-regulatory-affairs-hong-kong-regulator-lays-out-cryptoasset-roadmap) - [Crypto Regulatory Affairs: Hong Kong updates guidance for intermediaries on virtual asset-related activities](https://www.elliptic.co/blog/crypto-regulatory-affairs-hong-kong-updates-guidance-for-intermediaries-on-virtual-asset-related-activities) - [Global Crypto Policy Review & Outlook 2023/2024 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2023-24) - [Crypto regulatory affairs: Hong Kong doubles down on innovation push with new policy statement on digital assets, and launch of consultation on dealers and custodians](https://www.elliptic.co/blog/crypto-regulatory-affairs-hong-kong-doubles-down-on-innovation-push-with-new-policy-statement-on-digital-assets) - [Crypto regulatory affairs: Hong Kong introduces Stablecoin Bill in further boost to crypto hub status](https://www.elliptic.co/blog/crypto-regulatory-affairs-hong-kong-introduces-stablecoin-bill-in-further-boost-to-crypto-hub-status) - [Crypto regulatory affairs: Hong Kong plans to create panel for licensed crypto exchanges to facilitate regulatory consultation](https://www.elliptic.co/blog/crypto-regulatory-affairs-hong-kong-plans-to-create-panel-for-licensed-crypto-exchanges-to-facilitate-regulatory-consultation) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [Hong Kong's Law for Lawless Crypto Is Worth Embracing - Bloomberg](https://www.bloomberg.com/opinion/articles/2025-03-25/hong-kong-s-law-for-lawless-crypto-is-worth-embracing) - [Virtual Assets](https://www.fatf-gafi.org/en/publications/Virtualassets/Virtual-assets.html) - [Introduction to Cryptocurrency Exchange Compliance - Chainalysis](https://www.chainalysis.com/blog/introduction-to-cryptocurrency-exchange-compliance-crypto-businesses-2024/) - [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/glossary/virtual-asset-service-provider-vasp) - [Virtual Currencies: Key Definitions and Potential AML/CFT Risks](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Virtual-currency-definitions-aml-cft-risk.html) - [Crypto regulatory affairs: Hong Kong kicks off tokenization sandbox with major institutional players](https://www.elliptic.co/blog/hong-kong-kicks-off-tokenization-sandbox-with-major-institutional-players) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [North Korea Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/north-korea-sanctions) - [North Korea Administrative Designations Updates | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20200513) - [Beyond IT Worker Fraud: OFAC's Latest DPRK Designations Show Broader Sanctions and National Security Risk | TRM Blog](https://www.trmlabs.com/resources/blog/beyond-it-worker-fraud-ofacs-latest-dprk-designations-show-broader-sanctions-and-national-security-risk) - [OFAC sanctions a fraud network for assisting the North Korean (DPRK) regime](https://www.elliptic.co/blog/ofac-sanctions-a-fraud-network-for-assisting-the-north-korean-dprk-regime) - [OFAC lists 53 crypto addresses of sanctioned North Korean Cheil Credit Bank](https://www.elliptic.co/blog/ofac-lists-53-crypto-addresses-of-sanctioned-north-korean-cheil-credit-bank) - [What are OFAC crypto sanctions?](https://www.elliptic.co/blockchain-basics/what-are-ofac-crypto-sanctions) - [Crypto Regulatory Affairs: OFAC sanctions North Korea’s crypto laundering networks](https://www.elliptic.co/blog/analysis/crypto-regulatory-affairs-ofac-sanctions-north-korea-s-crypto-laundering-networks) - [Non-Proliferation Designations; North Korea Designations and Designation Removal | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20240327_33) - [Hong Kong-Related Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/hong-kong-related-sanctions) - [Mutual Evaluation of Hong Kong, China](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofhongkongchina.html) - [Asia/Pacific Group on Money Laundering (APG)](https://www.fatf-gafi.org/en/countries/global-network/asia-pacific-group-on-money-laundering--apg-.html) - [FinCEN Year in Review for FY 2024](https://www.fincen.gov/system/files/2025-08/FinCEN-Infographic-Public-2025-508.pdf) - [Mutual Evaluation of Singapore](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofsingapore.html) - [Transnational Organized Crime and the Convergence of Cyber-Enabled Fraud,](https://www.unodc.org/roseap/uploads/documents/Publications/2024/TOC_Convergence_Report_2024.pdf) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html) - [High-Risk Jurisdictions subject to a Call for Action - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-june-2026.html) - [Macau Ex-Junket King Alvin Chau Sentenced to 18 Years in Prison](https://www.bloomberg.com/news/articles/2023-01-18/macau-ex-junket-king-alvin-chau-sentenced-to-18-years-in-prison) - [Canadian Case Exposes Hong Kong Developer’s Corporate Ties to Chinese Criminal Underworld | OCCRP](https://www.occrp.org/en/investigation/canadian-case-exposes-hong-kong-developers-corporate-ties-to-chinese-criminal-underworld) - [How Cambodia Became A Haven For Criminals | OCCRP](https://www.occrp.org/en/feature/how-cambodia-became-a-haven-for-criminals) - [Macau Detains Man After Arrest Warrant for Suncity Junket Head - Bloomberg](https://www.bloomberg.com/news/articles/2021-11-27/macau-detains-man-after-arrest-warrant-for-suncity-junket-head) - [Junket King Alvin Chau's Arrest in Macau Signals End of $2.2 Billion Market - Bloomberg](https://www.bloomberg.com/news/articles/2021-11-29/junket-king-s-arrest-in-macau-signals-end-of-2-2-billion-market) - [How Suspects Spent Billions in Singapore's Biggest Money Laundering Case - Bloomberg](https://www.bloomberg.com/news/articles/2023-12-04/how-suspects-spent-billions-in-singapore-s-biggest-money-laundering-case) - [Alvin Chau, Suncity Group Holdings Ltd: Profile and Biography - Bloomberg Markets](https://www.bloomberg.com/profile/person/16504496) - [Macau Junket Giant Suncity Halts Operations After CEO Arrest](https://www.bloomberg.com/news/articles/2021-11-30/macau-junket-operator-suncity-to-suspend-operations-from-dec-1) - [Suncity CEO Admits to Illicit Betting Activity, Macau Police Say - Bloomberg](https://www.bloomberg.com/news/articles/2021-11-28/suncity-ceo-admits-to-illicit-betting-activity-macau-police-say) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html) - [GUIDANCE FOR A RISK-BASED APPROACH BENEFICIAL OWNERSHIP AND](https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.pdf.coredownload.inline.pdf) - [BENEFICIAL OWNERSHIP OF LEGAL PERSONS MARCH 2023 MARCH 2023](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Guidance-Beneficial-Ownership-Legal-Persons.pdf.coredownload.pdf) - [FATF Guidance on Beneficial Ownership Recommendation 24 - Public Consultation](https://www.fatf-gafi.org/en/publications/fatfrecommendations/documents/r24-public-consultation-oct-2022.html) - [Guidance on Beneficial Ownership and Transparency of Legal Arrangements](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html) - [Revisions to Recommendation 24 and its Interpretive Note - Public Consultation](https://www.fatf-gafi.org/en/publications/fatfrecommendations/documents/public-consultation-r24.html) - [Beneficial Ownership](https://www.fatf-gafi.org/en/topics/beneficial-ownership.html) - [A Billion-Dollar Casino Scheme and a Murder in Cambodia Expose Taiwan’s Underworld | OCCRP](https://www.occrp.org/en/news/a-billion-dollar-casino-scheme-and-a-murder-in-cambodia-expose-taiwans-underworld) - [Casinos and cryptocurrency: major drivers of money laundering, underground banking, and cyberfraud in East and Southeast Asia](https://www.unodc.org/roseap/en/2024/casinos-casinos-cryptocurrency-underground-banking/story.html) - [These Charts Show Impact of China’s Casino Crackdown on Macau - Bloomberg](https://www.bloomberg.com/news/articles/2021-09-16/these-charts-show-impact-of-china-s-casino-crackdown-on-macau) - [Golden Triangle: How Crypto Scammers Found A Criminal Paradise in Laos](https://www.bloomberg.com/features/2024-golden-triangle-special-economic-zone/) - [Casinos and Crypto Major Drivers of Money Laundering in East and Southeast Asia | OCCRP](https://www.occrp.org/en/news/casinos-and-crypto-major-drivers-of-money-laundering-in-east-and-southeast-asia) - [Important Information for Casinos | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/casinos) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [Protecting the EU’s financial system - Finance - European Commission](https://finance.ec.europa.eu/news/protecting-eus-financial-system-2025-07-16_en) - [Anti-Money Laundering and Terrorist Financing Directive 4 - Finance](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en) - [Anti-money laundering: the Commission updates its list of high-risk third-country jurisdictions to strengthen the international fight against financial crime - Finance](https://finance.ec.europa.eu/news/anti-money-laundering-commission-updates-its-list-high-risk-third-country-jurisdictions-strengthen-2022-12-20_en) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [ECSH31555 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh31555) - [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [HM Treasury Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/hm-treasury-advisory-notice-high-risk-third-countries) - [ECSH64830 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh64830) - [ECSH33336 - High-risk third countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh33336) - [High-risk third countries](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries) - [HM Treasury publish updated list of high risk third jurisdictions](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasury-publish-updated-list-of-high-risk-third-jurisdictions) - [Enhanced due diligence: designation of high-risk countries](https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1165484/Updated_Impact_Assessment_-_HRTC_Measure_amendement_2_ECCTB_21.06.23_MIN_CLEARED.pdf) - [Macau Cuts Casino License Tenure, Caps Public Float in New Law](https://www.bloomberg.com/news/articles/2022-01-14/macau-plans-maximum-six-casino-licenses-of-up-to-13-years) - [Macau’s Casino Operators Get New Licenses; Genting Loses Out - Bloomberg](https://www.bloomberg.com/news/articles/2022-11-26/macau-gives-existing-casinos-new-licenses-as-genting-loses-out) - [Macau Casino (WYNN, LVS, MGM) Crackdown Wipes Out $18 Billion in Value - Bloomberg](https://www.bloomberg.com/news/articles/2021-09-14/macau-casinos-downgraded-by-jpmorgan-as-relicensing-begins) - [Macau Says Open to Opinions on Proposed Gambling Law Changes - Bloomberg](https://www.bloomberg.com/news/articles/2021-09-20/macau-says-open-to-opinions-on-proposed-gambling-law-changes) - [Macau Police Arrest Macau Legend CEO For Illegal Gambling Operations - Bloomberg](https://www.bloomberg.com/news/articles/2022-01-31/macau-legend-plunges-30-after-ceo-arrested-in-junket-clampdown) - [Singapore Recovers Billions of Dollars in Money Laundering Case | OCCRP](https://www.occrp.org/en/news/singapore-recovers-billions-of-dollars-in-money-laundering-case) - [Australia Charges 7 for Laundering Millions Through Foreign Exchange Company | OCCRP](https://www.occrp.org/en/news/australia-charges-7-for-laundering-millions-through-foreign-exchange-company) - [EXCLUSIVE: Singapore Money Laundering Suspects Spent Lavishly on Dubai Real Estate | OCCRP](https://www.occrp.org/en/news/singapore-money-laundering-suspects-spent-lavishly-on-dubai-real-estate) - [Singapore Money Laundering Suspects Invested Huge Sums in Dubai Property | OCCRP](https://www.occrp.org/en/project/dubai-unlocked/singapore-money-laundering-suspects-invested-huge-sums-in-dubai-property) - [As Singapore Police Probe Money Laundering Ring, a Private Equity Entrepreneur Disappears | OCCRP](https://www.occrp.org/en/investigation/as-singapore-police-probe-money-laundering-ring-a-private-equity-entrepreneur-disappears) - [Collier Shannon Scott Coller Shannon Scott PLLC Washington Harbour, Suite 400](https://www.fincen.gov/system/files/shared/cletter_delta_asia_james_barnette2.pdf) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-4) - [Tuesday, September 20, 2005 Part II Department of the Treasury 31 CFR Part 103](https://www.fincen.gov/system/files/shared/finding_banco.pdf) - [Macau Gaming Revenue Meets Estimate on Summer Holiday Boost - Bloomberg](https://www.bloomberg.com/news/articles/2025-09-01/macau-gaming-revenue-meets-estimate-on-summer-holiday-boost) - [Macau’s Gaming Revenue Boom Heightens With Another Estimate Beat - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-01/macau-s-gaming-revenue-boom-roars-on-with-another-estimate-beat) - [Macau’s Casino Recovery Fizzles in June as Tourism Boom Fades - Bloomberg](https://www.bloomberg.com/news/articles/2023-07-01/macau-s-casino-recovery-fizzles-in-june-as-tourism-boom-fades) - [Macau Gaming Revenue Misses Estimate in Further Sign of Slowdown - Bloomberg](https://www.bloomberg.com/news/articles/2025-02-01/macau-gaming-revenue-misses-estimate-in-further-sign-of-slowdown) - [Macau Casino Bulls See Stock Rally Extending as Revenue Grows - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-27/macau-casino-bulls-see-stock-rally-extending-as-revenue-grows) - [FATF/APG (joint with GIFCS)](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/APG-Mutual-Evaluation-Report-Macao-China-2017.pdf.coredownload.inline.pdf) - [FATF/APG](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-macao-china-2019.html) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [UK Government (FCDO)](https://www.gov.uk/government/publications/overseas-business-risk-macao/overseas-business-risk-macao) - [European Commission (DG FISMA)](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [UNODC Regional Office for Southeast Asia and the Pacific](https://www.unodc.org/roseap/uploads/documents/Publications/2024/Casino_Underground_Banking_Report_2024.pdf) - [OCCRP](https://www.occrp.org/en/news/a-billion-dollar-casino-scheme-and-a-murder-in-cambodia-expose-taiwans-underworld) - [TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/shadow-bankers) - [Bloomberg](https://www.bloomberg.com/news/articles/2023-01-18/macau-ex-junket-king-alvin-chau-sentenced-to-18-years-in-prison) Coverage gaps fim-int-2026-07-07-G001: Direct primary reporting from the M… fim-int-2026-07-07-G001: Direct primary reporting from the Macau Financial Intelligence Office (GIF) and DICJ, including national risk assessment and STR statistics, is not available in English-language open sources, limiting independent verification of post-2021 junket-reform effectiveness. [resolved] fim-int-2026-07-07-G002: No confirmed evidence exists on whe… fim-int-2026-07-07-G002: No confirmed evidence exists on whether APG has scheduled a 5th-round mutual evaluation on-site date for Macau, leaving the timing and scope of the next effectiveness assessment unknown. [resolved] fim-int-2026-07-07-G003: Quantified data on the scale of cry… fim-int-2026-07-07-G003: Quantified data on the scale of crypto-based settlement by Macau and Hong Kong rooted triad networks is limited to TRM Labs analytical reporting, with no primary blockchain-forensics disclosure specific to Macau-linked wallets or exchanges. [resolved] fim-int-2026-07-07-G004: No documented evidentiary basis est… fim-int-2026-07-07-G004: No documented evidentiary basis establishes a causal link between the September 2025 candidate disqualifications and specific AML enforcement outcomes, leaving the F1 state-capture judgment as analytical inference rather than corroborated fact. [resolved] fim-int-2026-07-07-G005: Macau company-registry filing data … fim-int-2026-07-07-G005: Macau company-registry filing data underlying beneficial-ownership identification under Law 2/2006 is not independently accessible to verify whether the 25 percent threshold identification obligation is consistently enforced in practice. [resolved] fim-int-2026-08-05-G001: Primary Macau government text (Bole… fim-int-2026-08-05-G001: Primary Macau government text (Boletim Oficial) of the draft AML/CFT law has not been retrieved; only secondary press reporting is available. [resolved] fim-int-2026-08-05-G002: Colombia coverage this cycle is thi… fim-int-2026-08-05-G002: Colombia coverage this cycle is thin; no 2026-cycle development beyond the 2023 FATF follow-up re-rating of Recommendations 10 and 12 was located. [resolved] fim-int-2026-08-05-G003: T1 standing tracker (Russian sancti… fim-int-2026-08-05-G003: T1 standing tracker (Russian sanctions-evasion architecture) had no Yemen/Houthi-specific UN Panel of Experts, OFAC, or OFSI designation update surfaced this cycle. [resolved] fim-int-2026-08-05-G004: T2 EU AML Package tracker had no fr… fim-int-2026-08-05-G004: T2 EU AML Package tracker had no fresh-cycle AMLR application-date, 6AMLD transposition, or AMLA supervisory-perimeter development surfaced this cycle. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No primary Macau government (GIF/AMCM) consultation page reached directly this cycle for the AML-law reform; sourcing remains Tier-3 secondary press citing the same Tribuna de Macau document. [resolved] fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): No T1 or T2 signal identified for D1 (sanctions) or D4 (conflict finance) specific to Macau this cycle; D6 (compliance technology) carries no MO-specific development. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No primary consultation-document text or Boletim Oficial notice retrieved for the AML-law reform this cycle; only secondary trade-press accounts. [resolved] fim-int-2026-09-28-G002: D1 (sanctions/evasion), D3 (enabler… fim-int-2026-09-28-G002: D1 (sanctions/evasion), D3 (enabler jurisdiction), D4 (conflict finance) and D6 (compliance technology) returned no Macau-specific material this cycle. [resolved] fim-int-2026-09-28-G003: Tier D (KH/LA/MX/CO) coverage was n… fim-int-2026-09-28-G003: Tier D (KH/LA/MX/CO) coverage was not run this cycle because the pooled research budget was allocated to the MO-bound union dispatch. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No MO-specific D3 (enabler-jurisdiction) finding was located this cycle. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No MO-specific D4 (conflict-finance) finding was located this cycle. [resolved] fim-int-2026-10-04-G003: Laos, Mexico and Colombia Tier D ma… fim-int-2026-10-04-G003: Laos, Mexico and Colombia Tier D mandatory sweep carried no fresh finding this cycle; recorded as awaiting_primary_source rather than no_source since retrieval budget was concentrated on MO. [resolved] fim-int-2026-10-04-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G004 ({'scheme': 'financial_integrity', 'value': 'D7'}): The precise wording of the IMF Board Assessment's AML/CFT language was corroborated only via a T4 aggregator; retrieving the imf.org Staff Report directly would upgrade source-tier confidence on fim-2026-W40-001. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No DICJ or AMCM primary-source URL was located for direct retrieval this cycle; all DICJ/AMCM positions are sourced via secondary/aggregator commentary. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Tier-1 primary text of the AML-overhaul draft bill was retrieved; no evidence found of the bill reaching the Legislative Assembly. [resolved] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): The underlying TUI 'economic public order' judgment was not independently retrieved; reporting is press-sourced only. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): The TUI appellate judgment text itself was not directly retrieved; only secondary (Macau Business) reporting of its reasoning was available this cycle. [resolved] fim-int-2026-10-18-G002: Tier D jurisdiction watch (Cambodia… fim-int-2026-10-18-G002: Tier D jurisdiction watch (Cambodia, Laos, Mexico, Colombia) was not re-swept this cycle; this dispatch was bound to Macau SAR only. [resolved] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No MO-specific Russian sanctions-evasion, UN Panel/OFAC/OFSI signal was searched this cycle; this JID-bound pass did not re-run the global T1 sweep. [resolved] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): Whether the AML-overhaul bill (virtual assets/VASPs) has been formally tabled at the Legislative Assembly since June 2026 could not be confirmed this cycle. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Legislative Assembly or Boletim Oficial primary text located confirming a change in the AML draft law's legislative stage since the June 2026 consultation launch. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No dedicated Tier-D sweep (KH/LA/MX/CO) was run this cycle beyond general background knowledge given the single-JID budget lock. [open] fim-int-2026-11-01-G003: D1 Sanctions, D3 Enabler Jurisdicti… fim-int-2026-11-01-G003: D1 Sanctions, D3 Enabler Jurisdictions, D4 Conflict Finance and D6 Compliance Technology domains returned thin/no sourced material this cycle. [open] FIM-GAP-001 (D3): APG's mutual evaluation found a persistent… FIM-GAP-001 (D3): APG's mutual evaluation found a persistently low ML conviction rate relative to case volume, attributed to prosecutorial resource shortages, heavy evidentiary requirements for third-party ML and difficulty obtaining foreign-predicate-offence evidence; this structural capacity gap remains unresolved and unassessed under the newer FATF methodology. FIM-GAP-002 (D5): Macao has no virtual-asset service provide… FIM-GAP-002 (D5): Macao has no virtual-asset service provider licensing or supervisory regime, unlike Hong Kong's SFC/HKMA framework, leaving crypto-to-fiat conversion, OTC brokering and stablecoin activity involving Macau residents or visitors effectively outside dedicated AML/CFT supervision. FIM-GAP-003 (D3): Candidate vetting that disqualified 12 opp… FIM-GAP-003 (D3): Candidate vetting that disqualified 12 opposition Legislative Assembly candidates ahead of the September 2025 election, combined with documented media self-censorship, narrows independent political and civil-society channels capable of scrutinising AML enforcement, gaming-sector governance and beneficial-ownership reform in Macau. FIM-GAP-004 (D3): Independent Macau-specific AML/CFT reporti… FIM-GAP-004 (D3): Independent Macau-specific AML/CFT reporting is comparatively thin: most recent English-language coverage of Macau's financial-crime architecture arrives via UNODC/OCCRP/TRM Labs analysis of the broader East/Southeast Asian casino-underground-banking nexus rather than direct primary Macau FIU (GIF) or DICJ public disclosures, and Macau's own NRA and STR statistics are not readily available in English-language open sources. ## Evidence #### Confidence-tiered claims Concluded 2026 Article IV Consultation with Macao SAR on 24 Sep 2026 (Staff Report published 29 Sep 2026); stated ongoing AML/CFT strengthening efforts are welcome and should be sustained, linking VIP/junket contraction partly to 2022 gaming-law reforms. [[Source 1]](#sec-sources) Probable · 1 source Draft replacement of Laws 2/2006 and 3/2006 proposes a central beneficial-ownership register ending corporate anonymity, VASP licensing with administrative fines, real-time judicial transaction-suspension powers, tiered administrative sanctions, and 15-year document retention. GIF met the Macau Lawyers Association in April 2026; status remains consultation, not enacted. [[Source 1]](#sec-sources) Probable · 1 source TSI ruling held AMCM's prohibition on licensed FIs handling crypto-asset transactions is integrated into MSAR's 'economic public order' doctrine; a dissenting judge questioned the scope of a general ban versus a targeted prohibition. [[Source 1]](#sec-sources) Probable · 1 source Macau continues to implement UN Security Council sanctions regimes (counter-terrorism, DPRK, Afghanistan) via its Asset Freezing Coordination Commission; former Iran-related restrictions removed in 2024; no autonomous EU/US/UK-style listing divergence applies directly to MO. [[Source 1]](#sec-sources) Probable · 1 source IMF 2026 Article IV found LMCG requires only 'good reputation... honesty and integrity' tests for major shareholders (>=10%) and senior managers, via criminal-record certificates only, with no source-of-funds verification; amendment recommended ahead of ~2027 mass licence-renewal window. [[Source 1]](#sec-sources) Probable · 1 source AMCM's 2017 crypto-dealing prohibition for licensed financial institutions is part of Macau's 'economic public order' [[Source 1]](#sec-sources) Probable · 1 source Draft AML-overhaul creating formal VASP licensing/authorisation gateway, central corporate beneficial-ownership register, and real-time court-ordered account-freeze powers [[Source 1]](#sec-sources) Probable · 1 source Four 'other financial institution' payment licences on the AMCM register as of 26 May 2026, authorised via discretionary Chief Executive despacho under Article 3º(1)(13) of Lei n.º 13/2023, with no published fee or statutory decision period [[Source 1]](#sec-sources) Uncertain · 1 source Macao, China is assessed by the Asia/Pacific Group on Money Laundering (APG), not by FATF directly; not on the FATF grey list [[Source 1]](#sec-sources) Probable · 1 source No dedicated payment-services or electronic-money statute exists in Macau [[Source 1]](#sec-sources) Uncertain · 1 source AMCM's prohibition on licensed financial institutions dealing in virtual currencies is integrated into Macau's 'economic public order', per TUI reasoning in a trademark case reported 17 October 2026; a dissenting judge argued the case was properly a trademark/IP matter. [[Source 1]](#sec-sources) Probable · 1 source Prosecutor General Tong Hio Fong said establishing the illegal-currency-exchange offence requires proof not only that the exchange was unauthorised but that it constituted an ongoing, profit-making business, hampering enforcement against gambling-linked illegal money exchange. [[Source 1]](#sec-sources) Probable · 1 source Macau's Court of First Instance listed seven properties (combined reserve prices exceeding MOP137 million) belonging to jailed former Tak Chun junket boss Levo Chan for sale, following ICBC (Macau) enforcement proceedings to recover about MOP198.91 million. [[Source 1]](#sec-sources) Probable · 1 source Sectoral consultation since mid-2026, proposing virtual-asset/VASP definitions, authorisation requirement, beneficial-ownership register, real-time judicial transaction-suspension powers, and a ban on anonymous accounts/shell banks; no tabling date before the Legislative Assembly identified. [[Source 1]](#sec-sources) Probable · 1 source Since a notice of 20 September 2017, AMCM prohibits banks and payment institutions from directly or indirectly participating in or providing financial services related to virtual/digital currencies. [[Source 1]](#sec-sources) Probable · 1 source Under sectoral consultation since June 2026; proposes VASP licensing, beneficial-ownership register, and judicial asset-freeze powers. [[Source 1]](#sec-sources) Probable · 1 source Upheld refusal of trademark registration for cryptocurrency-related services on 'economic public order' grounds (reported 4 October 2026). [[Source 1]](#sec-sources) Probable · 1 source Anchored in Law 2/2006 as amended by Law 3/2017, Administrative Regulation 7/2006 as amended by 17/2017, DICJ Instruction 1/2016/1/2019; GIF is FIU; APG is assessment body. [[Source 1]](#sec-sources) Probable · 1 source AMCM reinforces concession sector's AML risk given reliance of concessionaires; GIF statement on inherent sectoral risks. [[Source 1]](#sec-sources) Probable · 1 source Macao, China co-chaired APG's Mutual Evaluation Committee per its 2024-25 annual report; standing fact, not new. [[Source 1]](#sec-sources) Probable · 1 source Draft AML law remains at consultation/drafting stage; no confirmed submission to or passage by Legislative Assembly this cycle [[Source 1]](#sec-sources) Probable · 1 source Court of Final Appeal-adjacent ruling held that AMCM's 2017 prohibition on bank/payment-institution crypto services is integrated into Macau's economic public order [[Source 1]](#sec-sources) Probable · 1 source consultation/drafting, unchanged since June-July 2026; no confirmation of submission to or passage by the Legislative Assembly [[Source 1]](#sec-sources) Probable · 1 source Court of Final Appeal/TSI-adjacent ruling (IP trademark case) holds AMCM's 2017 ban on bank/payment-institution crypto services is integrated into Macau's 'economic public order' [[Source 1]](#sec-sources) Probable · 1 source No current central beneficial-ownership register exists; draft AML law targets creation of first such register [[Source 1]](#sec-sources) Probable · 1 source Law No. 2/2006 remains the governing instrument, supervised for gaming by DICJ (Instruction 1/2016 as amended by 1/2019) and for finance by AMCM; Macau assessed by APG as 'Macao, China', not a FATF member [[Source 1]](#sec-sources) Probable · 1 source A Memorandum of Understanding on AML actions exists between the Macau Monetary Authority and the PBoC [[Source 1]](#sec-sources) Probable · 1 source