Casino money laundering regulations – Macao and USA

Carlos Siu Lam, Malcolm Greenlees

Research output: Contribution to journalArticlepeer-review

5 Citations (Scopus)


Purpose: Apart from presenting an overview and background on anti-money laundering (AML) rules and procedures for casinos in both Macao and the USA, this paper aims to examine the differences in their regulatory approaches with regard to their existing AML reporting processes and discusses possible weaknesses in their respective regulatory regime. Design/methodology/approach: Given that the regulations and statistics on the AML issues may not all be publicly available, the authors managed to secure some data from the bureaus concerned through published reports and interviews with government officials. Regarding the AML procedures in casinos, the authors attempted to go over the annual reports published by the casinos for submission to the Hong Kong Stock Exchanges and Clearing Limited because all these casinos are listed companies in Hong Kong. Findings: This paper analyzes the trends in reporting numbers and the categorization of the types of suspicious activity reports filed both in Macao and the USA. While the US suspicious activity reporting focuses on efforts to avoid currency reporting, Macao emphasizes improper or inadequate documentation and identification. Originality/value: This paper is one of the few articles comparing the AML rules and procedures between casinos in the USA and Macao. It seeks to highlight the differences in their regulatory approaches and discusses the expected future direction of AML legislation.

Original languageEnglish
Pages (from-to)52-69
Number of pages18
JournalJournal of Money Laundering Control
Issue number1
Publication statusPublished - 3 Jan 2017


  • Anti-Money laundering
  • Casino
  • Reporting procedure
  • Suspicious activity


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