GLOBAL CAPITAL MARKET LIMITED
SUSPICIOUS TRANSACTION REPORTING POLICY AND PROCEDURES
POLICY OBJECTIVE
Based on the guidelines issued by the Labuan Financial Services Authority (“Labuan FSA”) on Anti-Money Laundering and Counter
Financing of Terrorism (AML/CFT) for Banking Sector, GLOBAL CAPITAL MARKET LIMITED (“the Company”) has implemented the
following internal Suspicious Transaction Report (“STR”) policy and procedures to monitor suspicious transaction and to address
its reporting obligation.
The following policy and procedures are developed for identifying, evaluating and investigating, reporting as well as record
keeping of potential suspicious situation/transactions (including attempted or proposed).
IDENTIFYING
The Company’s employees need to ensure that all potential/existing customers do not engage in criminal activity, money
laundering or terrorist financing. They must monitor carefully at all unusual transactions to see if there is anything suspicious
about the customer.
There are many reasons why an employee might become suspicious about a transaction/activity. Often it is just because of
something unusual for a business, maybe a customer behaved strangely, or perhaps customer made unusual requests that did
not seem to make sense.
The Company’s employees may be guided by the examples provided in the Company’s internal measures for “Mechanism or Red
Flag to indicate occurrence of suspicious transaction”, to assist them in identifying any attempted or proposed suspicious
transaction.
EVALUATING AND INVESTIGATING
Whenever a Company’s employee detects any “red flag” that fits the list indicated above or senses any unusual
activity/transaction, he/she must directly inform the AML Designated Compliance Officer (“DCO”) without delay.
Upon receiving any internal STR from the Company’s employees, the DCO will first evaluate the grounds for suspicion and he will
make an initial decision of whether a customer/transaction is potentially suspicious.
The employee may be required to investigate the Customer/transaction further under the direction of the DCO. This may include
gathering additional information from the customer or from third party sources to assist in determining whether the
customer/transaction is indeed suspicious and to eliminate “false positive”.
These procedures should reflect the principle of confidentiality, where employees are to ensure that investigation is conducted
swiftly and that reports contain relevant information and are produced and submitted to the DCO in a secured and confidential
manner, within five (5) working days from the commencement of investigation.
REPORTING
Internal Suspicious Transaction Report (“STR”) prepared by the Company’s employee must be reviewed by the DCO within three
(3) working days from receiving such report.
The DCO is to complete his/her review within five (5) working days. Under the circumstances where a report requires further
investigation, the timeframe can be exceeded up to a month.
Once the DCO has finished review of the details, he/she should determine if that particular event rendered an attempted or
proposed suspicious transaction.
GLOBAL CAPITAL MARKET LIMITED
The DCO will consult with the Company’s Board of Directors to make the decision as to whether the customer/transaction is
suspicious and whether a filing to the Authority(ies) is necessary.
DCO shall submit the STR using the specified reporting template, to both of the following authorities:
Director
Financial Intelligence and Enforcement Department
Bank Negara Malaysia
Jalan Dato’ Onn
50480 Kuala Lumpur, Malaysia
(To be opened by addressee only) Fax: +603-2691 6108
E-mail: str@bnm.gov.my; AND
Head, AML Policy Unit
Policy and Digital Technology Department Labuan Financial Services Authority
Level 17, Main Office Tower
Financial Park Complex, Jalan Merdeka
87000 Federal Territory of Labuan, Malaysia
(To be opened by addressee only)
Fax: +603-8873 2209
E-mail: aml@labuanfsa.gov.my
The DCO will inform the Company’s Board of Directors of any report submitted. The fact that a report has been made is
confidential. The DCO, as well as the Company’s employees shall ensure that in the course of submitting the STR, such reports
are treated with the highest level of confidentiality. No one, other than those involved in the investigation and reporting should
be told about a STR, except for the law enforcement or other competent authorities.
Where applicable and upon the advice of the Financial Intelligence and Enforcement Department, Bank Negara Malaysia and/or
Anti-Money Laundering Compliance Unit, Labuan FSA, the DCO will submit his/her STR online at:
Website: https://bnmapp.bnm.gov.my/fins2/faces/pages/authc/Login.jsp
However, under the circumstances where the DCO decides that there are no reasonable grounds for suspicion and no STR is
necessary to be submitted to the relevant authorities, the DCO must document and file the decision, supported by the relevant
supporting documentary evidence, which will be made available to the relevant supervisory authorities upon request.
REPORTING
The DCO shall maintain a complete file on all internally generated reports and any supporting documentary evidence, regardless
of whether such report has been submitted. In the case of a filed report, a backup documentation is necessary.
The following are some of the information maintained for record keeping, which includes but is not limited to:
i.
ii.
iii.
Maintain a record of identifying information provided by the Customer.
Where the Company relies upon a document to verify identity, the Company must maintain a copy of the document with
clear evidence that the Company relied on and any identifying information it may contain.
Record the methods and result of any additional measures undertaken to verify the identity of the Customer.
iv. Record the resolution of any discrepancy in the identifying information obtained.
v. The nature or circumstances surrounding the transaction; and
vi. Business background of the person conducting the transaction that is connected to the unlawful activity.
All transaction and identification records are to be retained for a minimum period of 6 years, following the completion of
transaction.
GLOBAL CAPITAL MARKET LIMITED
REVIEW OF SUSPICIOUS TRANSACTION REPORTING POLICY AND PROCEDURES
GLOBAL CAPITAL MARKET LIMITED is committed to continuously improve this policy and it will be reviewed regularly (at least
every six months) for effectiveness and updated.
This Suspicious Transaction Reporting Policy and Procedures is supported by management. GLOBAL CAPITAL MARKET LIMITED
commits to providing this policy to all employee and displaying it in its business with clients.