I REFER to your editorial on the drug problem (South China Morning Post, September 28) which addresses the crime of money laundering. You rightly point out that our legislation, enacted in 1989, has not resulted in convictions. Nor does it appear that legislation has been fully effective as a deterrent. Money laundering occurs to the extent it does in Hong Kong partly because the standard of proof, which the prosecution is required to meet to secure convictions, is exceedingly difficult to attain. In this respect, Hong Kong lags behind the world's leaders. We are now working on a draft amending legislation to give effect to recommendations of the Financial Action Task Force, the inter-governmental group which co-ordinates action against money laundering worldwide. Detailed consultation will be necessary before we are ready to put our proposals before the Legislative Council, but I can assure you that the lowering of penalties forms no part of our present thinking. We aim to take tough, effective action against those who profit from spreading the misery of drug addiction. A. SINCLAIR Commissioner for Narcotics