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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. 1Module 2
Anti Money Laundering &
Counter Financing of Terrorism (AML/CFT)
Policy
AMLA Module 2
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. 2Module 2
Know Public Mutuals Anti-Money Laundering
Policy
ObjectivePublic Mutuals AML/CFT policy
UnderstandThe various preventive measures taken
by Public Mutual in combating Money Laundering
1
2
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. 3Module 2
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.
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. 4Module 2
Customer Identification-Know Your Customer PolicyA 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
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. 5Module 2
Customer Identification Know Your Customer Policy
The basic principles to be observed are:
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
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
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. 6Module 2
Customer Identification Know Your Customer Policy
The potential investor is required to give us original documents.
The UTC who sighted the
original documents
MUST
Have the Originalsighted stamp
Stamp the Originally Sighted template on the photocopied documents
Fill in the Originally Sighted template
12
3
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. 7Module 2
Original Sighted Sample
ORIGINAL SIGHTEDName of UTC
UTC Code
Signature of UTC
Date
ORIGINAL SIGHTEDName of UTCUTC CodeSignature of UTC Date
Font: Times New Roman 12 Bold
Font
: Tim
es N
ew
Rom
an 1
0
3cm 5cm
3cm
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. 8Module 2
Customer Identification Know Your Customer Policy
All UTCs are
requiredto carry out customer due
diligence (CDD)
When establishing
business relations
For occasional investment
For suspicious
investments
When in doubt about previously obtained
information
For politically exposed persons:
Individuals who are linked politically
On-going due diligence and
scrutiny should be conducted to ensure
the information provided are updated
and relevant
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. 9Module 2
Customer Due Diligence
Clubs, Societies and Charities
Obtain the Constitutional documents or othersimilar documents and ensure that it is properlyconstituted 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.
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. 11Module 2
Customer Due Diligence
The following information should be obtained (individual new investors) during fact finding:
IndividualInvestment
Mailing/Permanent
address
Occupation/Source of income
NRIC/Passport
Nationality
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. 12Module 2
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 investors true identify, you may ask for additional documents such as:
Driving License Passport Utility Bills
Other identification documents issued by official authority.
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. 13Module 2
CDD: Mailing / Permanent Address
If mailing address is different from the address in NRIC:
UTCs should enquire further on the investors new residence
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. 14Module 2
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
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. 15Module 2
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
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. 16Module 2
Customer Due Diligence
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)
Non Individual new investor:
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. 17Module 2
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 Customerpolicy to identify Investments that are inconsistent with customers profile
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. 19Module 2
I want to invest
RM 1Mil
Bell BoyMonthly Income RM1,000
Looks suspicious
The obligation to report is on the individual who is
suspicious of a transaction that may be a money
laundering transaction.
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. 20Module 2
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
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. 21Module 2
Public Mutuals AML/CFT policy (con)
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
Special attention to be given to these categories of customers classified as higher risk which include, but not limited to, the following :
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. 22Module 2
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
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. 23Module 2
Public Mutuals AML/CFT policy
If there is suspicion : UTCs to report to Branch Manager(Public Mutual )
REPORTING CHANNELS
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. 24Module 2
Public Mutuals AML/CFT policy
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.
REPORTING CHANNELS
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. 25Module 2
Public Mutuals AML/CFT policy REPORTING CHANNELSAfter reporting to the Branch Manager:
DO NOT discuss the matter with anyone
DO NOT discuss the matter with anyone
DO NOT inform the customer of your
actions or suspicion
DO NOT inform the customer of your
actions or suspicion
Do continue to service the customer as usualDo continue to service the customer as usual
The obligation to report is on the individual who becomes suspicious of
a money laundering transaction
The obligation to report is on the individual who becomes suspicious of
a money laundering transaction
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. 26Module 2
Public Mutuals AML/CFT policy
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.
UTCs to be alert if investors:
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. 27Module 2
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. 28Module 2
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