Macau's Prosecutor Calls for Law Change as Illegal Money Exchange Inquiries Rise 20.2% to 493

Macau's Prosecutor General says the offence created in 2024 to drive money changers from the casinos is hard to prove, because police often catch a suspect on what can be shown only as a first exchange. He wants objective criteria or a legal presumption, a fix that would make convictions easier and the defence harder.

• Macau's Prosecutor General Tong Hio Fong has asked the authorities to consider revising the offence of operating illegal currency exchange for gambling, by setting objective criteria for what counts as a business or by creating a legal presumption, in his speech opening the 2026/2027 judicial year on 15 October
• He said the offence requires proof of a continuing, profit-making business, while suspects detained near casinos can often be shown only to have made a first exchange
• The Public Prosecutions Office opened 493 inquiries for the offence in the judicial year to 31 August, up 20.2% from 410, making it the eighth most common crime by inquiries opened while total inquiries fell 8.3% to 13,923
• Gaming-related inquiries rose 17.4% to 892, and inquiries into illegal online gambling rose 150% to 160 from 64
• The figures follow police statistics showing gaming-related crime up 12.3% in the first nine months of 2026, with 404 illegal money exchange cases

Macau's Top Prosecutor Says the Money-Changing Offence Is Too Hard to Prove

Tong Hio Fong, Macau's Prosecutor General, used his speech at the opening of the 2026/2027 judicial year on 15 October to propose a change to the offence of operating illegal currency exchange for gambling, according to the full text published by the Public Prosecutions Office. The ceremony, at the Macao Cultural Centre, was chaired by Chief Executive Sam Hou Fai, according to the Government Information Bureau.

The offence was created by Law No. 20/2024 on combating illegal gambling crimes, which took effect at the end of October 2024, according to the Macao government. Article 11 targets currency exchange carried on as a stable, profit-making business for the purpose of gambling, in casinos and in the areas of integrated resorts open to the public, and carries up to five years in prison, according to an analysis of the law by the firm MdME reported by Asia Gaming Brief.

Tong said it is not enough to prove that a suspect changed money without authorisation: prosecutors must also prove a business, meaning a continuing commercial activity carried on for profit. When police detain suspected money changers near the casinos, he said, the evidence often shows only a first exchange, and without objective proof the business element is hard to establish, which considerably reduces the effectiveness of enforcement. He suggested the competent authorities consider revising the elements of the crime, for example by setting objective criteria for when conduct counts as a business, or by creating a legal presumption.

The Offence Is Now Among the Ten Most Common Crimes Prosecutors Handle

The Public Prosecutions Office opened 13,923 criminal inquiries in the judicial year, down 8.3% from 15,176, according to the speech. Among them, 493 were for operating illegal currency exchange for gambling, up 20.2% from 410. That placed the offence eighth among all crimes by inquiries opened, behind fraud, with 2,085, and ahead of aggravated theft and computer crime. Of the ten most common offences, only illegal currency exchange and aggravated theft, up 7.7% to 463, rose.

Gaming-related inquiries rose 17.4% to 892 from 760. Inquiries into illegal online games of chance or online mutual betting rose 150% to 160 from 64, which Tong said showed offenders exploiting the secrecy, cross-border reach and fast movement of money that online gambling allows. He said the exchange figures showed money-changing remained active, and urged the government to keep up enforcement and step up campaigns telling residents, and tourists in particular, to use only authorised channels.

The speech does not say how many exchange inquiries led to an indictment, were archived or ended in conviction. The overall conviction rate of 89.9% at the Primary Court is not broken down by offence.

Police figures point the same way. The Office of the Secretary for Security recorded 89 illegal money exchange cases in the rest of 2024 after the law took effect, 471 in 2025 and 404 in the first nine months of 2026, up 11.9% on a year earlier. The two counts cover different periods and are not directly comparable.

A Presumption Would Move the Burden Onto the Money Changer

Lawmakers criminalised the business of money changing for gambling, not a single unauthorised exchange, so a one-off swap falls outside the offence. Tong's complaint is that the line works too well: a changer who can be shown to have made only one deal escapes it. He did not say what the objective criteria would be, but markers such as the amount exchanged, the place or the cash found on a suspect would let courts infer a business from facts police can establish on arrest. A legal presumption would go further, asking the suspect to rebut the inference. That is the harder choice under a Basic Law whose Article 29 says residents charged with a crime are presumed innocent until convicted, and the speech does not say which option Tong prefers.

The 20.2% Rise Flatters the Trend

Macau's judicial year runs to 31 August, so the year that produced 410 inquiries began in September 2024, before the offence took effect at the end of October. The 493 figure is the first full judicial year under Law No. 20/2024, and some of the rise may reflect 12 months of enforcement against about 10, rather than more money changing. Even so, Tong's own reading is that the trade has not been driven out, and the police count is still rising in 2026. His complaint implies that some inquiries fail on the business element, but the published figures do not show how many.

Enforcement Does Not Touch the Demand

Every change Tong proposes acts on the supply of exchange. Money changers around the casinos survive because visitors use them, and criminalisation raises the cost of supplying the service without reducing the demand for it. The awareness campaigns are the only part of the speech aimed at the customer, and they rely on persuasion. The concessionaires have a stake: the offence reaches their casinos and the public areas of their resorts, and the changers' customers are their customers, in a market where September GGR fell 1.2% to its weakest month of the year. The same speech showed illegal online gambling inquiries up 150%, a reminder that money pushed from one informal channel can find another.

Macau's top prosecutor has said plainly that the law built to remove money changers from the casinos is not reaching the business it was aimed at. Whether the government answers with objective criteria or a presumption will decide how far the fix shifts the balance between conviction and the defence.