Managing AML Compliance Malaysia

Anti-money laundering (AML) ‘best practice’ in any firm starts with understanding the risk money launderers pose to your business. The inter-governmental Financial Action Task Force (FATF) and Bank Negara Malaysia provide guidance in undertaking preventive measures to prevent firms from being used as a conduit for money laundering or terrorism financing activities.

Risked Based Approach

These measures should be tailored to the specific risks faced by the organisation, both to ensure the risk is adequately addressed and to ensure appropriate allocation of resources are directed to Customer Due Diligence.  The Risk Based Assessment and the AML Program set the scene for how to manage risk but embedding the program into the firm will move towards protecting the firm from organisational, reputational and financial risk.

The organisation should assign an anti-money laundering compliance officer (AMLCO), a designated staff member with accountability and responsibility for complying with the requirements of the Act. The AMLCO will complete a risk assessment, develop the anti-money laundering program based upon the outcomes of the Risk Assessment, implement and embed the program and communicate the findings and anti-money laundering programme to the board.

The AML/CFT Program

The program will be in writing and include policies, procedures and controls that are specific to your organisation, sector and geography. These are designed to prevent, detect and deter your organisation being used to facilitate money laundering and terrorist financing.

This will include:

Utilising the Risked Based Assessment, identify high-risk areas within the organisation by reviewing the:

• products, services, delivery channels, customers; and geographic locations specific to your organisation and the industry sector.
• This AML/CFT Program should include reviewing high-risk areas and regularly updating to manage risks.

Develop the AML/CFT Program including Know Your Customer (KYC) obligations and will require an appropriate Customer Due Diligence processes including:

• Obtaining and/or verifying the identification documents of customers;

• Customer risk profiling;

• Completing Enhanced Due Diligence for High Risk customers including Politically Exposed Persons, Sanctions and Adverse Media & obtain the Source of Wealth or Funds.

• Ensure the Firm actions Ongoing Due Diligence

• Completing Transaction Monitoring & periodic customer reviews.

Record keeping and reporting is a must. Records should be sufficient to reconstruct the identity of the client or the transaction. This will includes appropriate escalation processes including lodgement of required;

• Suspicious Activity Reporting
• Prescribed Transactions Reporting

Complete Staff vetting and training with a focus on continual professional development.

Remember, the AML/CFT is a 'living' document and the firm should regularly assess the AML/CFT control measures and procedures and keep the AML/CFT Program up to date.

Using Efficient Technology

FATF guidelines encourage firms to consider using reputable technology-driven solutions to minimise the risk of error, find efficiencies in their AML/CFT processes and foster a culture of compliance. Avid AML has focused on providing a more affordable anti-money laundering software solution for not for profit, professional services and microfinance organisations. This is particularly important for small firms with less resources available to managing AML compliance.

Reducing the touch-points for customers improves speed to service.

This is a great place to start but introducing technology and automation importantly reduces risk and the cost of client onboarding. Empowering the firm's first line of defense by giving them access to on-boarding tools embeds the right culture of compliance from the start.

We believe every firm should have access to easy and affordable technology to take the pain away from Anti-Money Laundering (AML) compliance. We thought about Anti-Money Laundering software in a new way. We took what we knew from large global banks and streamlined the process to create an affordable, modern and uncomplicated user experience.

A Culture of Compliance

It’s not just well thought out policies, procedures and controls that protect against money laundering and terrorist financing. It’s the human element that counts too. An effective compliance culture needs to be enterprise wide with the buy-in from organisations at all levels. The more people aware of the risk, the harder it will be for money launderers or terrorist organisations to identify and utilise the firm's products or services.

Simplification and automation can remove these obstacles to reduce the burden of compliance on staff. A compliance culture is adopted more readily when changes to processes and technology can be implemented with ease. Technology should automate much of the repetitive work where it’s easy to miss a beat but also where the human eye is not as adept as technology in finding the anomalies.

A culture of compliance should simplify and streamline the process so, in the money launderers eyes, the whole firm is alert and aware.

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