Risk assessment
Platform-specific money laundering and proliferation financing risk.
Capital Markets / AML
Platform AML/CFT and Travel Rule Review
A platform AML/CFT and Travel Rule review is an independent check of a crowdfunding or digital asset platform's anti-money laundering and sanctions programme against the SC guidelines. Online investor onboarding, issuer funds flows and digital asset transfers create money laundering risks that bank-style AML programmes miss. We review your platform's programme against the SC guidelines and the Travel Rule for digital asset transfers.
Overview
Platform AML/CFT and Travel Rule Review
What it is
An independent review of a platform's AML/CFT and targeted financial sanctions programme: risk assessment, customer and issuer due diligence, monitoring, digital asset transfer information, screening and reporting.
Why organisations need it
The SC's AML/CFT/CPF guidelines were revised on 13 June 2024 with specific obligations for digital asset transactions and proliferation financing. Platforms onboard many investors remotely, move issuer funds, and for token offerings handle wallet transfers. These are the areas where platform programmes most often fall short.
Key features
What the engagement covers
Investor due diligence
Remote onboarding and ongoing monitoring.
Issuer due diligence
Issuers, directors and beneficial owners.
Digital asset transfers
Travel Rule information and wallet screening.
Sanctions screening
Investors, issuers and wallets.
Reporting and records
Suspicious transaction reports and record keeping.
Business value
What the business gets out of it
Platform-specific
Built for platforms, not banks.
Travel Rule tested
Digital asset duties covered.
Examination ready
Evidence the SC will ask for.
Clear remediation
Owners and dates.
Independent view
For the board and compliance officer.
How it works
How the engagement runs
01
Scoping
Models and period.
02
Review
Policies, procedures and systems.
03
Testing
Sample onboarding, transfers and alerts.
04
Gap analysis
Against SC guidelines.
05
Report
Findings and remediation.
Deliverables
What you receive
AML review report
Findings ranked by risk.
Risk assessment review
Strengths and gaps.
Sample test results
Onboarding, transfers, alerts.
Remediation plan
Owners and dates.
Board summary
Position for directors.
Who it is for
Who this is built for
Industries
Company sizes
Departments
Why Orbix
Why organisations choose Orbix
A governance approach, not a tool sale
We do not resell products, so nothing here is shaped by a vendor margin. The recommendation is whatever your risk and your budget actually justify, including telling you that you do not need the engagement yet.
Recommendations you can actually implement
Findings come with a sequence, an owner and a realistic effort estimate, sized to the team you have rather than the team a framework assumes. A report that cannot be acted on is an expense, not a control.
Consultants who have sat on your side of the table
Our people have carried the obligation internally, not only audited it. That shows up in what we consider proportionate, and in how much documentation we think you genuinely need.
Built for the Malaysian operating context
Work is grounded in Malaysian law and regulator expectation, from the PDPA and the Cyber Security Act 2024 to Bursa, BNM and SC requirements, rather than translated from a European or American template.
HRD Corp expertise where it applies
Where an engagement includes training, the training component is structured to be HRD Corp SBL-Khas claimable, which changes what the programme costs you in practice.
Questions
Questions we get asked
Is this different from a bank AML review?
Yes. It focuses on the risks that bank-style programmes miss on platforms: remote onboarding of many investors, issuer fund flows, and for token offerings, digital asset transfers to and from wallets. The review tests the controls around those flows rather than a branch-based model.
What is the Travel Rule?
The Travel Rule is the requirement to obtain and pass on originator and beneficiary information with digital asset transfers, reflected in the SC's AML/CFT/CPF guidelines as revised on 13 June 2024. For token platforms, it is often the least mature part of the programme.
Do you test our screening system?
We test how your screening is used and configured within the AML programme, including when screening happens and how alerts are handled. For a deeper test of list currency, matching and alert adjudication, our Sanctions Screening Review covers screening on its own.
How often should we review?
At least annually, and after significant changes to your products, your platform model or the regulation. A new token offering, a new payment route or a guideline revision each changes the risk the programme was designed for.
Can you help with an SC examination?
Yes. We help you prepare the evidence an examiner is likely to ask for, and if findings are raised, we help build and evidence the remediation so your response shows the controls working in practice.