INTRODUCTION
Money Laundering is defined as the process of converting money/property, which is derived from
illegal activities to give it a legitimate appearance. Financing of terrorism generally refers to carrying
out transactions involving funds that may or may not be owned by terrorist, or that have been, or
are intended to be used to assist the commission of terrorism. In the financing of terrorism, the
focus is on the determination or use of funds, which may have been derived from legitimate source.
AEON Credit Service (M) Berhad (“AEON Credit” or the “Group”) is at the frontline of the Malaysian
government’s and Bank Negara Malaysia’s aim is to prevent the use of the financial system for
illegal, money laundering, and terrorism financing.
POLICY STATEMENT
The policy serves to establish comprehensive regulations on the provisions of the Anti-Money
Laundering and Countering Financing of Terrorism in accordance to Anti-Money Laundering, AntiTerrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLATFPUAA) and the Financial
Action Task Force (FATF) 40 Recommendations and the Bank Negara Malaysia’s (BNM) Policy
Document which shall be adopted and implemented by AEON Credit and its subsidiaries (“The
Group”).
The policy sets out the:
- Obligations of the Group with respect to the requirements imposed under the AMLATFPUAA.
- Requirements imposed on the Group in implementing a comprehensive Risk-Based Approach (RBA) in managing money laundering/terrorism financing (ML/TF) risks.
- Roles of the Group’s Board of Directors and Senior Management (or its equivalent) in putting in place the relevant Anti-Money Laundering/Countering Financing of Terrorism (AML/CFT) measures.
SCOPE
The policy set out in this document shall be complied with by all staffs based on the responsibilities
identified. Non-compliance with the requirements set out in this document shall be deemed as a
breach of discipline that can lead up to dismissal.
Compliance being the owner of the document is responsible to ensure this policy is updated and
revised accordingly when there is any change in regulations or business process.
The policy covers the following areas:-
- Applicability according to BNM/RH/PD 030-3 – Anti-Money Laundering, Countering Financing of Terrorism and Targeted Financial Sanctions for Financial Institutions (AML/CFT and TFS for FIS).
- Reporting institutions in the First Schedule to the AMLATFPUAA.
- Branches and subsidiaries of reporting institutions.
- All products and services offered by reporting institutions.
- Reporting Requirement – The reporting requirement of AMLATFPUAA is applicable to all staffs based on the related activities listed in AMLATFPUAA First Schedule.
- Serious Offence – The serious offences under AMLATFPUAA are listed in AMLATFPUAA Second Schedule.
KEY GUIDELINES
The key principles of the group Anti-Money Laundering/Countering Financing of Terrorism
(AML/CFT)Policy are:-
Guideline 1
The Group fully committed in identifying and assess risk of customers, especially in determining the type of customers associated with high risk of money laundering and financing of terrorism by documenting risk assessments and findings.
Guideline 2
The Group monitoring on the customers, when establishing business relationship and it has any suspicion of money laundering or financing of terrorism.
Guideline 3
The Group takes reasonable and appropriate measures to establish the source of wealth and funds of such person. The assessment of the ML/TF risks, shall take into account the profile of the customer on Risk Profiling.
Guideline 4
The Group apply appropriate counter measures, proportionate to the risks for higher risks country if ML/TF risk is assessed as higher risks for business relationships with any persons from countries identified by FATF (Financial Action Task Force).
Guideline 5
The Group has in place an adequate process (electronically or manually) that require providing with timely information on a regular basis to enable the Group to investigate any irregularities or suspicious activities.
Guideline 6
The Group keeps the relevant records, business correspondence and documents relating to transactions to identify the customer or beneficial owner, results of any analysis taken and maintain a high degree of
confidentiality on such reports.
Guideline 7
The Group promptly submit a suspicious transaction report to the Money Laundering Reporting Officer (MLRO) whenever the Group suspects or have reasons to suspects the transactions, Involves proceeds from an unlawful activity and appears illegal regardless the amount.
Guideline 8
The Group provides regular training and refresher course in order to instill awareness and remind the staff of their responsibilities under AML/CFT program.
Guideline 9
The Group requires to be updated continually to ensure compliance with local, state, and national regulations along with changes in company culture and avoid non-compliance issues or any offences occur.
Businesses within the Group, regardless of geographic location, are dedicated to maintaining compliance with the Group’s AML/CFT Policy as well as applicable AML/CFT legislations in the jurisdictions whereby, they function by adhering to the highest standards.
In the investigations of money and/or financial crime, the Group fully cooperates with law enforcement agencies and supervisory authorities.
