AMLA (Chap 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. 1Module 2

Anti Money Laundering &

Counter Financing of Terrorism (AML/CFT)

Policy

AMLA Module 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


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.


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


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



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

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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 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


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.



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.



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

IndividualInvestment

Mailing/Permanent

address

Occupation/Source of income

NRIC/Passport

Nationality


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.


CDD: Mailing / Permanent Address

If mailing address is different from the address in NRIC:

UTCs should enquire further on the investors new residence


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


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



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:



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


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


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.


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


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 :



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



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

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.

REPORTING CHANNELS


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



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:

Documents

AMLA (Chap 2)