AMLA Module 2

Anti Money Laundering & Counter Financing of Terrorism (AML/CFT) Policy

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Module 2

Public Mutuals AML/CFT policy

Objective
1 Know Public Mutuals Anti-Money Laundering Policy

Understand The various preventive measures taken by Public Mutual in combating Money Laundering
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Cooperation with Authorities

It is our Companys policy to extend full cooperation with the relevant authorities in the event of investigation pursuant to the reporting of a suspicious transaction made by the Company.

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Customer Identification-Know Your Customer Policy

A financial institution is required to ascertain the true identity of any customer opening an account or performing transactions. This is required:

to obtain satisfactory and reliable evidence or documents

to establish the identity and legal existence

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Customer Identification Know Your Customer Policy

Obtain proper identification Identify and verify the beneficial ownership and control Identify and verify the person conducting the transaction Ascertain some basic background of the customer e.g. occupation and employer

The basic principles to be observed are:

For non-individuals, also establish the nature and size of business as well as countries of its business partners Any other information available to the UTC to know and understand the customer better Obtain copies of relevant documents

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Customer Identification Know Your Customer Policy

The potential investor is required to give us original documents.

Stamp the Originally Sighted template on the photocopied documents

The UTC who sighted the original documents

MUST 3

Have the Original sighted stamp

Fill in the Originally Sighted template

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Original Sighted Sample

Font: Times New Roman 12 Bold Font: Times New Roman 10

ORIGINAL SIGHTED
Name of UTC UTC Code Signature of UTC Date
ORIGINAL SIGHTED
Name of UTC

3cm

3cm

5cm

UTC Code Signature of UTC Date

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Customer Identification Know Your Customer Policy

On-going due diligence and scrutiny should be conducted to ensure the information provided are updated and relevant For politically exposed persons: Individuals who are linked politically

When establishing business relations

to carry out customer due diligence (CDD)

required

All UTCs are

For occasional investment

When in doubt about previously obtained information

For suspicious investments

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Customer Due Diligence

Clubs, Societies and Charities

Obtain the Constitutional documents or other similar documents and ensure that it is properly constituted and registered

Identify at least two signatories and perform a customer due diligence on the two signatories.

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Customer Due Diligence

Application not made in person Any avoidance of face to face contact between UTC and customer inevitably poses difficulties for customer identification and produces a loophole. Such practices should not be entertained.

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Customer Due Diligence

The following information should be obtained (individual new investors) during fact finding:
NRIC/ Passport

Occupation/ Source of income

Individual Investment

Mailing/ Permanent address

Nationality

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CDD: NRIC / Passport

Must be issued by official authority. Must bear a photograph of the customer and should resemble the customer. If in doubt of individual investor s true identify, you may ask for additional documents such as: Driving License Passport Utility Bills Other identification documents issued by official authority.

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CDD: Mailing / Permanent Address

If mailing address is different from the address in NRIC: UTCs should enquire further on the investor s new residence

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Occupation / Source of Income

During fact finding: UTCs should try to establish customers occupation and employer For non-individual, UTCs should try to establish nature and size of business as well as countries of its business partners

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Nationality
During fact finding: UTCs should try to establish proper identification of investors nationality For non-residence investors, UTCs must obtain photocopy of passport to confirm the nationality of the investors

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Customer Due Diligence

Non Individual new investor: The following documents / information should be obtained

Memorandum/ Certificate of incorporation/ Partnership (Form 9)

Identification documents of Directors/ Shareholders/ Partners (Form 49)

Authorisation of any person representing the company (Board Resolution)

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Customer Due Diligence

Conduct basic search to ensure the company is not in the process of being dissolved or liquidated

Verify the authenticity of the information provided by the company with Companies Commission of Malaysia

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Detecting & Monitoring

Personal Initial Investment & Personal Additional Investment from customer Observation by UTC i.e. the application of Know Your Customer policy to identify Investments that are inconsistent with customer s profile

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Looks suspicious

I want to invest RM 1Mil

Bell Boy Monthly Income RM1,000

The obligation to report is on the individual who is suspicious of a transaction that may be a money laundering transaction.
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Public Mutuals AML/CFT policy

Special attention to be given to these categories of customers classified as higher risk which include, but not limited to, the following :

Non-Resident Customers Cash Based Business Travel Agencies Jewel, Gems and Precious Metal Dealers Charitable and Non-Profit Organization

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Public Mutuals AML/CFT policy (con)

Special attention to be given to these categories of customers classified as higher risk which include, but not limited to, the following : Customer from locations known for its high crime rate e.g. drug producing, smuggling, human trafficking Politically-Exposed Person(PEPs) Customers from sanctioned countries listed by UN or sensitive countries/jurisdictions with inadequate AML/CFT laws Corporations that are incorporated/registered outside Malaysia Subsidiaries of corporations located in offshore financial centers Complex legal arrangements e.g. unregistered investment vehicles
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Public Mutuals AML/CFT policy

Punishment under AMLA
Any person who engages in, or attempt to engage in; or abets the commission of money laundering, commits an offence and shall on conviction be liable to a fine not exceeding five million ringgit or imprisonment for a term not exceeding five years or both

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Public Mutuals AML/CFT policy

REPORTING CHANNELS
If there is suspicion : UTCs to report to Branch Manager (Public Mutual )

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Public Mutuals AML/CFT policy

REPORTING CHANNELS

If you become suspicious of any investment, you should approach the Branch Manager personally with details of the customer.

You are NOT ALLOWED to report directly to Bank Negara under any circumstances.

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Public Mutuals AML/CFT policy

REPORTING CHANNELS
After reporting to the Branch Manager:

DO NOT discuss the matter with anyone

DO NOT inform the customer of your actions or suspicion

Do continue to service the customer as usual

The obligation to report is on the individual who becomes suspicious of a money laundering transaction

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Public Mutuals AML/CFT policy

UTCs to be
1. Avoid meeting face to face. 2. Reluctant to provide information required during conversation. 3. Intend to invest huge amount of money. (through physical cash or other means) 4. Have high frequency of switching into multiple accounts. 5. Request to transfer accounts to parties without clear relationship with the investor. 6. Request for full or partial repurchase within a short period of time after investing (eg. 3 months) 7. Request to deposit repurchase amount into overseas / off shore accounts for no apparent reason.
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alert if investors:

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Public Mutuals AML/CFT policy

All rights reserved. The information published may not be reproduced or copied to any person or incorporate into another document or other materials without the prior written consent of Public Mutual Berhad.

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All rights reserved. The information published may not be reproduced or copied to any person or incorporate into another document or other materials without the prior written consent of Public Mutual Berhad.

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