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Anti-Money Laundering and the Countering of Terrorism Financing (AML/CFT) Policy


What is Money Laundering?

Money laundering is defined as the process intended to mask benefits derived from serious criminal offenses or criminal conduct as described under the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA) to make it appear that such benefits originated from a legitimate source.


1.1 The Three Stages of Money Laundering.

Generally, money laundering is composed of three (3) stages involving several transactions which could alert an intermediary such as the Company to the money laundering activity:

  1. Placement – the physical act of disposing of the cash proceeds drawn from illegal activities
  2. Layering – the act of separating illicit proceeds from their source by creating complex tiers of financial transactions in order to disguise the audit trail and to provide anonymity
  3. Integration – the act of providing an appearance of legitimacy to criminally- derived wealth. If the layering process is successful, the integration step places the laundered proceeds back into the economy in a manner that their re-entry into the financial system has the appearance of being normal business funds


1.2 Basic Principles to Combat Money Laundering and the Financing of Terrorism.

As per Malaysia’s Anti-Money Laundering & Counter Financing of Terrorism Regime, endeavors to apply the following principles in order to detect, prevent and oppose the use of the Company’s services for money laundering and the financing of terrorism:

  • Established and Duly Appointed Compliance Officer
  • Application of Know-Your-Customer (CDD and EDD)
  • Reporting Obligations
  • Ongoing Employee Training
  • Ongoing Monitoring and Compliance Testing
  • Record Keeping and Data Retention in Accordance With AMLA Laws and other relevant  Regulations pertaining to the prevention of ML/FT and data protection
  • Internal Audit Function


1.2.1 Compliance with Laws. ensures that its business is conducted in conformity with the height of ethical standards, that laws and regulations are respected and complied with whenever possible, and that service is not provided where there is good reason to believe that transactions are associated with activities deriving from illegal activities.


1.2.2 Cooperation with Law Enforcement Agencies.

Within the legal constraints relative to client confidentiality, cooperates with law enforcement agencies. This includes taking appropriate measures within the law if there are reasonable grounds reasonable grounds for suspecting money laundering. Any disclosure made in conjunction with the Act shall be made to the Financial Intelligence and Enforcement Department (FIED) of Bank Negara Malaysia (BNM).