“Behind every great
fortune there is a crime”
Honore de Balzac
Compliance Department
AmanahRaya Investment Management Sdn Bhd
2
&TERRORISM FINANCING
WHAT IS MONEY LAUNDERING?!
Compliance Department
AmanahRaya Investment Management Sdn Bhd 3
Disguised illegally
obtained money from
unlawful activity
Compliance Department
AmanahRaya Investment Management Sdn Bhd 4
WHAT IS FINANCING TERRORISM?!
Process of financing
terrorist activity either
through legitimate or
illegitimate source
5
PUNISHMENT?!
Compliance Department
AmanahRaya Investment Management Sdn Bhd
Fine; 500,000.00 or to
imprisonment not exceeding five
(5) years or both.
Compliance Department
AmanahRaya Investment Management Sdn Bhd 6
OVERVIEW OF AML/CFT REGIME IN MALAYSIA
KEY LEGISLATION:
Anti-Money Laundering and
Anti-Terrorist Financing Act
(AMLATFA) 2001
Compliance Department
AmanahRaya Investment Management Sdn Bhd 7
OVERVIEW OF AML/CFT REGIME IN MALAYSIA
COMPETENT AUTHORITY:
Bank Negara Malaysia
Compliance Department
AmanahRaya Investment Management Sdn Bhd 8
OVERVIEW OF AML/CFT REGIME IN MALAYSIA
LAW ENFORCEMENT AGENCIES:
Jabatan Kastam Diraja
Malaysia
BNM
KPDNKK
MITI
SSM
SC
LHDN
SPRM
PDRM
Money Laundering Process
Compliance Department
AmanahRaya Investment Management Sdn Bhd 9
MONEY LAUNDERING PROCESS
First Stage : Placement
Cash movement.
Examples:
financial institutions, casinos, shops, bureau de
and other businesses, both local and abroad
Compliance Department
AmanahRaya Investment Management Sdn Bhd 10
MONEY LAUNDERING PROCESS
‘Without a trace’.
Examples:
Buy assets then sold assets previously
Second Stage : Layering
Compliance Department
AmanahRaya Investment Management Sdn Bhd 11
MONEY LAUNDERING PROCESS
Integrating illegal
money into the normal
legitimate economy.
Examples:
Buying share in a
company.
Third Stage : Integration
12
HOW ARIM IMPLEMENTS
AMLA/TF?
Compliance Department
AmanahRaya Investment Management Sdn Bhd 13
KNOW YOUR CUSTOMER STANDARD
PROCEDURE
Compliance Department
AmanahRaya Investment Management Sdn Bhd 14
Compliance Department
AmanahRaya Investment Management Sdn Bhd 15
DUE DILIGENCE PROCESS
Compliance Department
AmanahRaya Investment Management Sdn Bhd 16
Note # 2- Customer Due Diligence (“CDD”)
Examples of High Risk Clients
Politically exposed persons (PEPs)
as well as persons or companies
clearly related to them
Compliance Department
AmanahRaya Investment Management Sdn Bhd 17
Note # 2- Customer Due Diligence (“CDD”)
Examples of High Risk
Clients
Customers from locations known
for its high crime rate
Compliance Department
AmanahRaya Investment Management Sdn Bhd 18
Note # 2- Customer Due Diligence (“CDD”)
Examples of High Risk
Clients
Non-resident customers
Compliance Department
AmanahRaya Investment Management Sdn Bhd 19
Note # 2- Customer Due Diligence (“CDD”)
Examples of High Risk
Clients
customers from countries or jurisdictions
without or with inadequate AML/CTF laws and
..regulations as highlighted by the FATF
Compliance Department
AmanahRaya Investment Management Sdn Bhd 20
Note # 2- Customer Due Diligence (“CDD”)
Examples of Low Risk
Clients
Compliance Department
AmanahRaya Investment Management Sdn Bhd 21
Note # 2- Customer Due Diligence (“CDD”)
Examples of Low Risk
Clients
Public companies
Compliance Department
AmanahRaya Investment Management Sdn Bhd 22
Note # 2- Customer Due Diligence (“CDD”)
Examples of Low Risk
Clients
Public companies
Financial Institutions
23
Note # 3- Suspicious Transactions
Compliance Department
AmanahRaya Investment Management Sdn Bhd
Examples of Suspicious
Transaction
Irregular Account Movement
24
Note # 3- Suspicious Transactions
Compliance Department
AmanahRaya Investment Management Sdn Bhd
Examples of Suspicious
Transaction
Transactions Incompatible
vs Customer’s Financial
Standing
Compliance Department
AmanahRaya Investment Management Sdn Bhd 25
Note # 4- Record Keeping
Maintain records
Questions?

Amla traning (2014) 180714

Editor's Notes

  • #17 We will have to ascertain whether the client is
  • #20 Red flag countries
  • #24 How to detect this? What compliance do daily. We monitor