The Monetary Authority of Macao (AMCM) has introduced a new regulatory framework to help Macau expand its economy beyond gambling. On June 10, they published Circular No. 003/2026-AMCM, outlining guidelines for fund-of-funds (FOF) products under the Investment Funds Law (Law 11/2025). This development follows decades of economic dependence on casino revenue, which exposed the region to instability during global disruptions like the pandemic and trade policy shifts.
The new rules impose strict conditions on FOF structures. At least 80% of its assets must be invested in units of public investment funds. The circular also requires transparent fee disclosure across multiple fund layers and bans investments in other FOFs, simplifying the market for individual investors.
A notable provision allows feeder funds to invest in overseas master funds, creating a streamlined entry point for international asset managers. This follows closely after E Fund became the first entity to receive Macau’s inaugural fund management authorization under the updated law, suggesting regulators are coordinating with early market participants to establish clear operating standards.
The circular resolves ambiguities in the broader Investment Funds Law, which had not specified operational details on risk management or disclosure standards. Without these clarifications, fund operators would have faced uncertainty about concentration limits, fee structures, and how layered fund arrangements would be supervised. The AMCM’s intervention ensures investor protections while preventing premature launches of high-risk or poorly transparent products.
Legal expert Calvin Chui, a co-managing partner at a Macau law firm, explained that the new measures focus on investor safeguards, structured market growth, and positioning Macau as a reliable distribution center. The limits on fund concentration, mandatory fee transparency, and ban on nested FOF structures protect retail investors from compounded risks. Meanwhile, the feeder-fund provisions and criteria for foreign master funds are designed to support international investment rather than restrict it.
Non-adherence to the rules carries substantial consequences. Fund managers failing to comply within six months of a fund’s launch face penalties ranging from MOP 100,000 ($12,370) to MOP 2 million ($247,000), along with potential supervisory actions and reputational harm. Chui anticipates further regulatory updates from the AMCM as the market develops, advising early participants to view current guidelines as foundational rather than definitive.
