Co-Chairs,
Members of the Assessment Team,
Fellow Members of the APG ,
Executive Secretary and Members of the Secretariat,
Ladies and Gentlemen,
Firstly, Macao, China would like to express
its gratitude to the assessment team for their
effort in preparing this informative report,
as well as their straightforward and constructive
comments and recommendations given. Macao, China
will carry out a thorough and prudent review
on the existing system and place high priority
to follow up with related Government agencies
with the implementation of the recommendations
contained in this report.
We appreciate the great effort of the ME team
who indeed had offered significant contribution
to the MER, in spite of the unexpected difficulties
they happened to encounter during the exercise.
In our point of view, difficulties primarily
fell into three areas:
Firstly, the evaluation exercise would be a
lot more effective if it took place after the
fundamental and recent amendments to our AML/CFT
had been in place.
Secondly, difficulties rose from the fact that
Macao, China is one of the very few jurisdictions
in the APG belonging to the continental law
family (which created further challenge to the
assessment team to a certain extent).
Last but not least, personal difficulties faced
by the members of the assessment team had imposed
additional pressure on themselves, on the APG
Secretariat and Macau, China as the assessed
jurisdiction. This is reflected in the tight
deadlines within the adopted methodology, in
particular the feedback process that demanded
an extra-combined effort of the Macau agencies.
Nevertheless, we are pleased with the recognition
for the latest development of Macao, China in
the AML/CFT areas by the members of the assessment
team and this is encouraging to us for our future
work to fight against money laundering and terrorist
financing.
We will keep adopting a consistent policy that
complies with international standards such as
the FATF 40+9 Recommendations, the Basel Principles
and others relevant standards in order to implement
AML/CFT measures in different areas.
Notwithstanding that we are pleased with the
outcome of this assessment exercise, we are
equally aware as well of the challenges that
we are facing ahead but we are strongly committed
to overcoming them.
Since the new legislation on AML/CFT covers
a wide range of business activities and requires
more sophisticated customer due diligence standards
and reporting obligations, it is expected that
the various business sectors, especially the
DNFBP’ s, will take some time to fully
implement the control measures and allocate
the necessary resources. Therefore, educational
and public awareness programs will be one of
the main priorities.
On the other hand, the MSAR Government is to
allocate adequate resources, including human
resources, IT support and training for all the
supervisory authorities and law enforcement
agencies in order to cope with the new requirements.
In the medium to long term, and taking into
consideration the actual situation of Macao,
China, the MSAR Government will make it a first
priority in our AML/CFT regime to work progressively
on the recommendations of this report, which
laid down the areas identified as our major
shortcomings.
An initial follow-up of the recommendations
includes the following:
- the enactment of the Legal Cooperation on
Criminal Matters Law set out the basis to enhance
international cooperation, in particular to
promote international cooperation agreements
with other countries and territories which we
will actively pursue ;
- a cross border declaration or disclosure
system is under study by the MSAR Government
taking into consideration the competence of
law enforcement agencies, and this study will
lead to the adoption of a proper measure that
meets our needs;
- a further review is to be carried out on
the risks associated with NPO’ s in Macao,
China, and the required actions to implement
the corresponding AML/CFT measures will also
be studied;
In the meantime, this exercise has greatly
improved the fine-tuning of cooperation of all
our domestic agencies involved. Continuous effort
is necessary to review the effectiveness of
the existing legal system and the implementation
measures through the AML/CFT Working Group,
and proposals will be elaborated to the MSAR
Government for revising the AML/CFT policies
and procedures when needed.
Simultaneously, each of the agencies involved
will carry out individual assessment on its
respective needs so as to enact the corrective
measures adequate to overcome its shortcomings.
Furthermore, they will continue to seek opportunities
whereby they can put the plans in practice in
their respective sector for strengthening the
overall AML/CFT system.
We are fully aware that indeed, an effective
AML/CFT system is only as strong as the strength
of its weakest link.
That’s why, for the moment, although
we are pleased with the outcome of the present
report, we do know that there is always room
for improvement as the report says.
We believe that the path for improvement is
just at its beginning in search of an effective
AML/CFT system. It is our duty and challenge
to keep straddling it in the best of our abilities.
Thank you.