{"id":3254,"date":"2025-09-12T16:06:25","date_gmt":"2025-09-12T13:06:25","guid":{"rendered":"https:\/\/gcfxdemo.etriplesoft.com\/?page_id=3254"},"modified":"2025-09-12T16:06:25","modified_gmt":"2025-09-12T13:06:25","slug":"aml-kyc-due-diligence-policy","status":"publish","type":"page","link":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/legal\/aml-kyc-due-diligence-policy\/","title":{"rendered":"AML, KYC & Due Diligence Policy"},"content":{"rendered":"
[vc_row full_width=”stretch_row” customize_bg_mobile=”1″ css=”.vc_custom_1757679529418{padding-top: 180px !important;padding-bottom: 210px !important;}” custom_styles_mobile=”.vc_custom_1757679529421{padding-top: 100px !important;padding-bottom: 100px !important;}” custom_styles_landscape=”.vc_custom_1757679529419{padding-top: 100px !important;padding-bottom: 100px !important;}”][vc_column][vc_btn title=”Download in PDF” color=”black” align=”right” i_icon_fontawesome=”fa fa-solid fa-download” css=”” add_icon=”true” link=”url:https%3A%2F%2Fgcfxdemo.etriplesoft.com%2Fwp-content%2Fuploads%2F2025%2F08%2FAML-KYC-Due-Diligence-v3-11.6.2025.pdf|target:_blank”][vc_column_text css=””]ANTI MONEY LAUNDERING, KNOW YOUR CUSTOMER
\n& DUE DILIGENCE POLICY<\/p>\n

POLICY\u2019S OBJECTIVES
\nThe Anti Money Laundering, Know Your Customer & Due Diligence Policy of GLOBAL CAPITAL MARKET LIMITED
\n(\u201cthe Company\u201d) is formulated in accordance with the provisions of the Anti-Money Laundering, Anti-Terrorism
\nFinancing and Proceeds of Unlawful Activities Act 2001 (AMLATFA) and the Financial Action Task Force 40
\nRecommendations and is intended to ensure that reporting institutions at Labuan International Business
\nFinancial Centre (Labuan IBFC) understand and comply with the requirements and obligations imposed on them.
\na. Since the formation of the National Coordination Committee to Counter Money Laundering (NCC), efforts
\nhave been undertaken to effectively enhance the Anti Money Laundering, Counter Financing of Terrorism &
\nCountering Proliferation Financing (AML\/CFT\/CPF) compliance framework in the introduction of the Standard
\nGuidelines on AML\/CFT\/CPF.
\nBesides bringing the recommendation up to date in addressing new and emerging threats, the 2012 revision
\nof the International Standards on Combating Money Laundering and the Financing of Terrorism &
\nProliferation (FATF 40 Recommendations), sought to clarify and strengthen many of its existing obligations as
\nwell as to reduce duplication of the Recommendations. One of the new Recommendations introduced is on
\nthe obligation of countries to adopt a risk-based approach in identifying, assessing and understanding the
\nMoney Laundering and Terrorism Financing (ML\/TF) risks, which places further expectation to assess and mitigate
\nML\/TF risks. Labuan Financial Services Authority has issued necessary directives via circulars from time to
\ntime, covering issues related to Know your Client (KYC norms), Anti- Money Laundering (AML), Client Due
\nDiligence (CDD) and Counter Financing of Terrorism (CFT) in pursuant to Section 13, 14, 15, 16, 17, 18, 19,
\n20, 66E and 83 of the AMLATFA and Section 4B of the Labuan Financial Services Authority Act 1996 (LFSAA).
\nb. The purposes of creation of this policy are as listed below:
\ni. To look at the origins of the clients and will not deal with clients from countries that are listed by the
\nFinancial Action Task Force (FATF) and\/or the Government of Malaysia with either on-going or
\nsubstantial ML\/TF risks or strategic AML\/CFT\/CPF deficiencies that pose a risk to the international
\nfinancial system.
\nii. Not to conduct business with shell banks, risk-based assessment of customer base and all transactions,
\nprohibition of anonymous customer accounts, implementation of KYC policy etc.
\niii. Not to enter into business relationships with any criminals and\/or terrorists.
\niv. Not to process transactions which result from criminal and\/or terrorist activity and not to facilitate any
\ntransactions involving criminal and\/or terrorist activity including the financing of terrorism.
\nc. The Company undertakes to implement all policies and procedures necessary to prevent the money
\nlaundering and to comply with all applicable legislation in this regard.
\ni. The directors, officers and employees of the Company shall at all times make every effort to maintain the
\nhighest standards of ethics, integrity, and prudence in the Company\u2019s operation and administration so as
\nto ensure that the Company creates and maintains a good reputation and standing.
\nii. The directors, officers and employees shall at all times act in such a manner as to preserve the reputation
\nof Labuan is a major international financial center and to prevent the use of the jurisdiction for illegal,
\ncriminal and terrorist purposes.<\/p>\n

iii. The anti-money laundering policies and proceduresto be adhered to by the Company are partly contained in this
\npolicy and any amendments thereto.
\niv. Where any issue or matter is not addressed by this policy, guidance is to be sought from the anti-money
\nlaundering legislation referred above (together with Labuan Financial Services Authority and\/or Bank Negara
\nMalaysia requirements, where applicable).
\nANTI-MONEY LAUNDERING REQUIREMENTS
\nThere are five key anti-money laundering requirements that are specific to \u201cregulated activity\u201d. These provides a useful
\napproach for the Company to consider when looking at how to manage the money laundering risk.
\ni. Customer identification procedures (KYC).
\nii. Record keeping procedures in relation to customer\u2019s identity and their transactions.
\niii. Procedures of internal reporting to the Compliance Department (and Designated Compliance Officer (DCO) appointed)
\nto receive and consider information that give rise to knowledge or suspicion that a customer is engaged in money
\nlaundering activities.
\niv. Other internal control and communication procedures for the purpose of forestalling and preventing money
\nlaundering.
\nv. Measures for making employees aware of the above procedures to prevent money laundering and of the legislation
\nrelating to money laundering and provision of training to their employees in the recognition and handling of
\ntransactions suspected to be associated with money laundering and suspicioustransactions.
\nCOMPLIANCE TO ANTI MONEY LAUNDERING, KNOW YOUR CUSTOMER & DUE DILIGENCE POLICY
\nCompliance with the Company\u2019s Anti Money Laundering, Know Your Customer & Due Diligence Policy is the utmost
\nimportance. Not only it is important to maintain the Company\u2019s integrity, but failure to comply may constitute a criminal
\noffence and call into question whether or not the Company and the employee concerned is fit and proper to conduct the
\nbusiness for which the Company has been licensed. Failures by individuals to comply with the anti money laundering
\nprocedures set forth in this policy can therefore result in dismissal.
\nTARGETED FINANCIAL SANCTIONS ON TERRORISM FINANCING, PROLIFERATION FINANCING AND UNDER
\nOTHER UN-SANCTIONS REGIMES
\ni. The Company is required to keep abreast of the relevant United Nations Security Council Resolutions (UNSCR) list
\nrelating to combating the financing of terrorism, which includes:
\na) UNSCR 1267 (1999), 1373 (2001), 1988 (2011), 1989 (2011) and 2253 (2015) which require sanctions against individuals
\nand entities belonging or related to Taliban, ISIL (Da\u2019esh) and Al-Qaida; and
\nb) new UNSCR list which is published by the UNSC or its relevant Sanctions Committee as published in the United Nations
\n(UN) website.
\nii. The Company must maintain a sanctions database which comprised, at the minimum, the following:
\na) UNSCR list: Company shall refer to the Consolidated UNSCR List published in the following UN website:
\nhttps:\/\/www.un.org and\/or http:\/\/unscr.com. The UNSCR List shall remain in the sanctions database until delisting
\nof the specified entities and designated country or person by the UNSC or its relevant Sanctions Committee is
\npublished in the UN website.<\/p>\n

b) Domestic List: A Labuan KRI may refer to the Domestic List published in the following website:
\nhttps:\/\/moha.gov.my. The Domestic List shall remain in the sanctions database until such specified entities are
\ndelisted from theGazette.
\nc) A Labuan KRI may monitor and consolidate other countries\u2019 unilateral sanctions lists in their sanctions database.
\niii. Sanctions Screening Customers: Company shall conduct sanctions screening on existing, potential or new customers
\nagainst the Domestic List and UNSCR List. Where applicable, screening shall be conducted as part of the CDD process
\nand ongoing due diligence.
\niv. Dealing with False Positives:
\na) To ensure that any matches to Domestic List or UNSCR List are true matches in order to eliminate false positives.
\nb) Conducting further inquiries for additional information and identification documents from the customer (e.g
\nrequest of Bank Statements, Curriculum Vitae\/Resume, Reference Letter, Certificate of Good Conduct, Certificate
\nof Good Standing (for Corporate entity) & ors), counter-party or credible sources to assist in determining whether
\nthe potential match is a truematch.
\nc) In the case of similar or common names, the Company may direct any query to the relevant authorities to ascertain
\nwhether or not the customer is a specified entity.
\nv. Upon determination and confirmation of a customer\u2019s identity as a specified entity, designated person and\/or related
\nparties, a Labuan KRI is required to immediately conduct the following:
\na) freeze the customer\u2019s funds, properties, other financial assets and economic resources, upon received of the
\nAuthority(ies) approval (where applicable); or
\nb) to block transactions in order to prevent dissipation of the funds, other financial assets and economic resources.
\nvi. The Company will reject a potential customer, when there is a positive name match generated during the screening
\nprocess.
\nCLIENT DUE DILIGENCE (CDD)<\/p>\n

The Company must ensure as soon as reasonably practical after the first contact has been made, and in any event before
\ntransferring or paying any money out to a third party, that satisfactory evidence is produced or such other measures are taken
\nas will produce satisfactory evidence of the identity of any customer or counterparty (an \u201capplicant\u201d). If a client appears to be
\nacting on behalf of another person, identification obligations extend to obtaining sufficient evidence of that third party\u2019s identity.
\nWhere satisfactory evidence is not supplied, the firm will not proceed with any further business and bring to an end any
\nunderstanding it has reached with the client unless in either case the firm has informed Labuan Financial Services Authority. If
\nthere is knowledge or a suspicion of money laundering, it will be reported without delay as provided under these procedures to
\nthe DCO.
\nFurther described identification requirements should be carried out using documents checklist.<\/p>\n

METHODS OF IDENTIFICATION<\/p>\n

The Company will make sure that it is dealing with a real person or legal entity and obtain sufficient evidence to establish that
\nthe applicant is that person or organization. When reliance is being placed on any third party to identify or confirm the identity
\nof any applicant, the overall legal responsibility to ensure that the procedures and evidence obtained are satisfactory rests with
\nthe Company.<\/p>\n

As no single form of identification can be fully guaranteed as genuine, or representing correct identity, the identification process
\nwill need to be cumulative, and no single document or source of data (except for a database constructed from a number of other
\nreliable data sources) must therefore be used to verify both name and permanent address.
\nThe Company will take all required measures, according to applicable law and regulations issued by regulatory authorities, to
\nestablish the identity of its clients and, where applicable, their respective beneficial owners in accordance to our KYC policy.<\/p>\n

DUE DILIGENCE<\/p>\n

In addition to identification information (as described below), it is essential to collect and record information covering the
\nfollowing for all categories of clients:
\ni. Source of wealth (description of the economic activity which has generated the net worth);
\nii. Estimated net worth;
\niii. Source of funds to be invested;
\niv. References or other documentation to corroborate reputation information where available;
\nv. Independent background checks through a reputable screening system;
\nvi. Whether the individual (or director and\/or shareholder of a Corporate entity) is a Politically Exposed Person (PEP). If yes,
\nadditional information and documentation will be requested for verification purpose.<\/p>\n

INDIVIDUAL CUSTOMERS<\/p>\n

The identity will be established to the Company\u2019s satisfaction by reference to official identity papers or such other evidence as
\nmay be appropriate under the circumstances. Information on identity will include, without limitation: full name; date of birth;
\nnationality; complete residential address. Identification documents must be current at the time of the opening.
\nDocuments used for client identification purposes will typically include:
\ni. A passport, a national identity card or an equivalent in the relevant jurisdiction;
\nii. A separate document confirming the residential address (utility bill, bank statement, acknowledgement of address issued by
\na relevant official).<\/p>\n

CORPORATE CUSTOMERS<\/p>\n

Where the applicant company is listed on a recognized or approved stock exchange or where there is independent evidence to
\nshow that the applicant is a wholly owned subsidiary or subsidiary under the control of such a company, no further steps to verify
\nidentity over and above the usual commercial checks and due diligence will normally be required.
\nWhere the applicant is an unquoted company, it will be subject to a procedure aimed to identify it, confirm its existence, good
\nstanding and authority of persons acting on its behalf. Documentation required for such purposes may change depending on each
\nparticular jurisdiction and will typically include:
\ni. Certificate of incorporation\/certificate of trade or the equivalent, evidencing the company is indeed incorporated in a
\nparticular jurisdiction under the respective legislation;
\nii. Certificate of Incumbency or an equivalent document, listing current directors of the company.<\/p>\n

CORPORATE CUSTOMERS (CONT\u2019D)
\niii. Statutes, Memorandum and Articles of Association or equivalent documents confirming the authority of the respective
\nofficers of the company to legally bind it and the manner in which this may be done.
\niv. Extract from the Commercial Register of the country of incorporation may also be used to confirm the aforementioned
\ninformation, if such information is provided in the extract.
\nREVIEW OF ANTI MONEY LAUNDERING, KNOW YOUR CUSTOMER & DUE DILIGENCE POLICY<\/p>\n

GLOBAL CAPITAL MARKET LIMITED is committed to continuously improve this policy and it will be reviewed regularly (at least
\nevery six months) for effectiveness and updated.
\nThis Anti Money Laundering, Know Your Customer & Due Diligence Policy is supported by management. GLOBAL CAPITAL MARKET
\nLIMITED commits to providing this policy to all employee and displaying it in its business with clients.<\/p>\n[\/vc_column_text][\/vc_column][\/vc_row]\n<\/div>","protected":false},"excerpt":{"rendered":"

[vc_row full_width=”stretch_row” customize_bg_mobile=”1″ css=”.vc_custom_1757679529418{padding-top: 180px !important;padding-bottom: 210px !important;}” custom_styles_mobile=”.vc_custom_1757679529421{padding-top: 100px !important;padding-bottom: 100px !important;}” custom_styles_landscape=”.vc_custom_1757679529419{padding-top: 100px !important;padding-bottom: 100px !important;}”][vc_column][vc_btn title=”Download in PDF” color=”black” align=”right” i_icon_fontawesome=”fa fa-solid fa-download” css=”” add_icon=”true” link=”url:https%3A%2F%2Fgcfxdemo.etriplesoft.com%2Fwp-content%2Fuploads%2F2025%2F08%2FAML-KYC-Due-Diligence-v3-11.6.2025.pdf|target:_blank”][vc_column_text css=””]ANTI MONEY LAUNDERING, KNOW YOUR CUSTOMER & DUE DILIGENCE POLICY POLICY\u2019S OBJECTIVES The Anti Money Laundering, Know Your Customer & Due Diligence Policy of GLOBAL CAPITAL MARKET LIMITED (\u201cthe Company\u201d) is formulated in accordance with the provisions of the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLATFA) and the Financial Action Task Force 40 Recommendations and is intended to ensure that reporting institutions at Labuan International Business Financial Centre (Labuan IBFC) understand and comply with the requirements and obligations imposed on them. a. Since the formation of the National Coordination Committee to Counter Money Laundering (NCC), efforts have been undertaken to effectively enhance the Anti Money Laundering, Counter Financing of Terrorism & Countering Proliferation Financing (AML\/CFT\/CPF) compliance framework in the introduction of the Standard Guidelines on AML\/CFT\/CPF. Besides bringing the recommendation up to date in addressing new and emerging threats, the 2012 revision of the International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation (FATF 40 Recommendations), sought to clarify and strengthen many of its existing obligations as well as to reduce duplication of the Recommendations. One of the new Recommendations introduced is on the obligation of countries to adopt a risk-based approach in identifying, assessing and understanding the Money Laundering and Terrorism Financing (ML\/TF) risks, which places further expectation to assess and mitigate ML\/TF risks. Labuan Financial Services Authority has issued necessary directives via circulars from time to time, covering issues related to Know your Client (KYC norms), Anti- Money Laundering (AML), Client Due Diligence (CDD) and Counter Financing of Terrorism (CFT) in pursuant to Section 13, 14, 15, 16, 17, 18, 19, 20, 66E and 83 of the AMLATFA and Section 4B of the Labuan Financial Services Authority Act 1996 (LFSAA). b. The purposes of creation of this policy are as listed below: i. To look at the origins of the clients and will not deal with clients from countries that are listed by the Financial Action Task Force (FATF) and\/or the Government of Malaysia with either on-going or substantial ML\/TF risks or strategic AML\/CFT\/CPF deficiencies that pose a risk to the international financial system. ii. Not to conduct business with shell banks, risk-based assessment of customer base and all transactions, prohibition of anonymous customer accounts, implementation of KYC policy etc. iii. Not to enter into business relationships with any criminals and\/or terrorists. iv. Not to process transactions which result from criminal and\/or terrorist activity and not to facilitate any transactions involving criminal and\/or terrorist activity including the financing of terrorism. c. The Company undertakes to implement all policies and procedures necessary to prevent the money laundering and to comply with all applicable legislation in this regard. i. The directors, officers and employees of the Company shall at all times make every effort to maintain the highest standards of ethics, integrity, and prudence in the Company\u2019s operation and administration so as to ensure that the Company creates and maintains a good reputation and standing. ii. The directors, officers and employees shall at all times act in such a manner as to preserve the reputation of Labuan is a major international financial center and to prevent the use of the jurisdiction for illegal, criminal and terrorist purposes. iii. The anti-money laundering policies and proceduresto be adhered to by the Company are partly contained in this policy and any amendments thereto. iv. Where any issue or matter is not addressed by this policy, guidance is to be sought from the anti-money laundering legislation referred above (together with Labuan Financial Services Authority and\/or Bank Negara Malaysia requirements, where applicable). ANTI-MONEY LAUNDERING REQUIREMENTS There are five key anti-money laundering requirements that are specific to \u201cregulated activity\u201d. These provides a useful approach for the Company to consider when looking at how to manage the money laundering risk. i. Customer identification procedures (KYC). ii. Record keeping procedures in relation to customer\u2019s identity and their transactions. iii. Procedures of internal reporting to the Compliance Department (and Designated Compliance Officer (DCO) appointed) to receive and consider information that give rise to knowledge or suspicion that a customer is engaged in money laundering activities. iv. Other internal control and communication procedures for the purpose of forestalling and preventing money laundering. v. Measures for making employees aware of the above procedures to prevent money laundering and of the legislation relating to money laundering and provision of training to their employees in the recognition and handling of transactions suspected to be associated with money laundering and suspicioustransactions. COMPLIANCE TO ANTI MONEY LAUNDERING, KNOW YOUR CUSTOMER & DUE DILIGENCE POLICY Compliance with the Company\u2019s Anti Money Laundering, Know Your Customer & Due Diligence Policy is the utmost importance. Not only it is important to maintain the Company\u2019s integrity, but failure to comply may constitute a criminal offence and call into question whether or not the Company and the employee concerned is fit and proper to conduct the business for which the Company has been licensed. Failures by individuals to comply with the anti money laundering procedures set forth in this policy can therefore result in dismissal. TARGETED FINANCIAL SANCTIONS ON TERRORISM FINANCING, PROLIFERATION FINANCING AND UNDER OTHER UN-SANCTIONS REGIMES i. The Company is required to keep abreast of the relevant United Nations Security Council Resolutions (UNSCR) list relating to combating the financing of terrorism, which includes: a) UNSCR 1267 (1999), 1373 (2001), 1988 (2011), 1989 (2011) and 2253 (2015) which require sanctions against individuals and entities belonging or related to Taliban, ISIL (Da\u2019esh) and Al-Qaida; and b) new UNSCR list which is published by the UNSC or its relevant Sanctions Committee as published in the United Nations (UN) website. ii. The Company must maintain a sanctions database which comprised, at the minimum, the following: a) UNSCR list: Company shall refer to the Consolidated UNSCR List published in the following UN website: https:\/\/www.un.org and\/or http:\/\/unscr.com. The UNSCR List shall remain in the sanctions database until delisting of the specified entities and designated country or person by the UNSC or its relevant Sanctions Committee is published in the UN website. b) Domestic List: A Labuan KRI may refer to the Domestic List published in the following website: https:\/\/moha.gov.my. The Domestic List shall remain in the sanctions database until such specified entities are delisted from theGazette. c) A Labuan KRI may monitor and consolidate other countries\u2019 unilateral sanctions lists in their sanctions database. iii. Sanctions Screening Customers: Company shall conduct sanctions screening on existing, potential or new customers against the Domestic List and UNSCR List. Where applicable, screening shall be conducted as part of the CDD process and ongoing due diligence. iv. Dealing with False Positives: a) To ensure that any matches to Domestic List or UNSCR List are true matches in order to eliminate false positives. b) Conducting further inquiries for additional information and identification documents from the customer (e.g request of Bank Statements, Curriculum Vitae\/Resume, Reference Letter, Certificate of Good Conduct, Certificate of Good Standing (for Corporate entity) & ors), counter-party or credible sources to assist in determining whether the potential match is a truematch. c) In the case of similar or common names, the Company may direct any query to the relevant authorities to ascertain whether or not the customer is a specified entity. v. Upon determination and confirmation of a customer\u2019s identity as a specified entity, designated person and\/or related parties, a Labuan KRI is required to immediately conduct the following: a) freeze the customer\u2019s funds, properties, other financial assets and economic resources, upon received of the Authority(ies) approval (where applicable); or b) to block transactions in order to prevent dissipation of the funds, other financial assets and economic resources. vi. The Company will reject a potential customer, when there is a positive name match generated during the screening process. CLIENT DUE DILIGENCE (CDD) The Company must ensure as soon as reasonably practical after the first contact has been made, and in any event before transferring or paying any money out to a third party, that satisfactory evidence is produced or such other measures are taken as will produce satisfactory evidence of the identity of any customer or counterparty (an \u201capplicant\u201d). If a client appears to be acting on behalf of another person, identification obligations extend to obtaining sufficient evidence of that […]<\/p>\n","protected":false},"author":1,"featured_media":0,"parent":3200,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"footnotes":""},"class_list":["post-3254","page","type-page","status-publish","hentry"],"_links":{"self":[{"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/pages\/3254","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/comments?post=3254"}],"version-history":[{"count":1,"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/pages\/3254\/revisions"}],"predecessor-version":[{"id":3255,"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/pages\/3254\/revisions\/3255"}],"up":[{"embeddable":true,"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/pages\/3200"}],"wp:attachment":[{"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/media?parent=3254"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}