You are a member of the anti-money laundering (AML) team of a regulated financial services firm operating in Malaysia: Certification in AML Assignment, ICTA, Malaysia
| University | International Compliance Training Academy (ICTA) |
| Subject | Certification in AML |
You are a member of the anti-money laundering (AML) team of a regulated financial services firm operating in Malaysia. Part of your role involves signing off, at the client onboarding stage, high-risk and complex business relationships that the firm is considering. You have been advised that your firm is becoming more cautious about its risk appetite and wishes to de-risk some of its business activities.
A file on a potential new client has been referred to you for evaluation.
The potential client is Global Metals Trading Sdn. Bhd. (GMT). The client account-opening file contains the following summary:
- GMT’s business activity is as a dealer in precious metals
- the company’s head office is in Kuala Lumpur, Malaysia
- there are two directors, C.K. Lee, and John Ma, both Malaysian nationals; C.K. Lee is a former politician in one of the states of Malaysia
- the company is registered via a company service provider in Labuan
- the ultimate beneficial ownership of the company is difficult to determine owing to a complex corporate ownership structure which makes beneficial ownership difficult to trace
- GMT has been in business for three years and has doubled its turnover annually
- GMT is seeking an investment of RM50 million.
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