Sanctions Screening and Targeted Financial Sanctions (TFS) Compliance
Sanctions screening has become one of the most consistent themes in Bank Negara Malaysia's published enforcement actions. Across 2025 and 2026, BNM has penalised banks, insurers and takaful operators, e-money issuers, money services businesses and a corporate services provider for failures such as not keeping sanctions databases current, not screening customers in time, and not rejecting, freezing or reporting when a match was found. On 10 June 2026, Standard Chartered Bank Malaysia Berhad and Standard Chartered Saadiq Berhad were each penalised RM132,000 for failing to keep up with updates to the Domestic List. The failures are rarely about the law being unclear. They are about data, systems, timing and evidence.
This two-day course is a specialist deep dive for the people who run screening: compliance, operations, onboarding, payments and trade finance teams at banks, insurers, e-money issuers, money services businesses, capital market intermediaries and DNFBPs such as company secretaries, lawyers and accountants. It covers the Malaysian sanctions architecture, the United Nations Security Council lists, the Ministry of Home Affairs Domestic List and the proliferation financing regime under the Strategic Trade Act 2010, and then spends most of its time on operations. It assumes AML basics. Participants new to AML should attend AML/CFT Compliance Officer first, and platform operators will find wallet screening covered in AML for Crowdfunding & Digital Asset Platforms.
HRD Corp SBL-Khas Claimable
Programme Agenda
Day 1, 9:00 AM - 9:15 AM
Welcome and Programme Overview
Introduction to the session, objectives, and housekeeping.
Day 1, 9:15 AM - 10:15 AM
Why Screening Keeps Failing: Reading BNM's Enforcement Record
What BNM's published enforcement actions for 2025 and 2026 show about where screening programmes break: database updates, timing of screening, missed rejections and freezes, and late reports. Turning each failure into a control test for your own programme.
Day 1, 10:15 AM - 10:30 AM
Break
Day 1, 10:30 AM - 11:30 AM
The Sanctions Architecture in Malaysia
Targeted financial sanctions on terrorism financing and proliferation financing, the United Nations Security Council lists, the Domestic List declared by the Minister of Home Affairs, the Strategic Trade Act 2010, and the obligations on reporting institutions to freeze without delay, reject and report. How foreign regimes such as OFAC, EU and UK sanctions fit in as a matter of risk appetite and correspondent relationships rather than Malaysian law.
Day 1, 11:30 AM - 12:30 PM
Who and What to Screen
Customers, beneficial owners, directors and authorised signatories, beneficiaries and counterparties of payments, trade finance parties, vessels and goods, and existing customers when lists change. Screening at onboarding, on list updates and at transaction time, and the gaps that open between them.
Day 1, 12:30 PM - 1:30 PM
Lunch
Day 1, 1:30 PM - 3:15 PM
List Management and Database Currency
Sourcing lists, the timing of updates, confirming each update was loaded and applied, change control, and the evidence trail an examiner will ask for. The exact failure behind the June 2026 penalties, and how to prove it cannot happen to you.
Day 1, 3:15 PM - 3:30 PM
Break
Day 1, 3:30 PM - 4:45 PM
Name Matching in Practice
Fuzzy matching, transliteration of Malay, Arabic, Chinese and Tamil names, name order, aliases, dates of birth and other identifiers, and setting thresholds that balance missed matches against unworkable alert volumes.
Day 1, 4:45 PM - 5:00 PM
Day 1 Close
Recap and what to review before day two.
Day 2, 9:00 AM - 9:15 AM
Day 1 Review
Recap of day one and the questions it left open.
Day 2, 9:15 AM - 10:15 AM
Alert Handling and Adjudication
Triage, discounting false positives with documented reasons, escalation, four-eyes review, service levels, and quality assurance on closed alerts. Workshop: adjudicate a batch of realistic alerts.
Day 2, 10:15 AM - 10:30 AM
Break
Day 2, 10:30 AM - 11:30 AM
True Matches: Freeze, Reject and Report
What to do the moment a true or possible match is confirmed: freezing funds and assets, rejecting the customer or transaction, reporting to the authorities, handling the customer, and record keeping.
Day 2, 11:30 AM - 12:30 PM
Proliferation Financing and Trade
Proliferation financing risk, dual-use goods, trade finance and shipping red flags, and screening in trade and correspondent banking flows.
Day 2, 12:30 PM - 1:30 PM
Lunch
Day 2, 1:30 PM - 3:15 PM
Testing, Tuning and Governance
Model validation of screening systems, above- and below-the-line testing, tuning without weakening coverage, independent review, and the management information a board and senior management should receive.
Day 2, 3:15 PM - 3:30 PM
Break
Day 2, 3:30 PM - 4:45 PM
Case Workshop: From List Update to Board Report
Teams run a full scenario, a new Domestic List designation that matches an existing customer and an incoming payment, from list load through adjudication, freeze, reporting and the board update.
Day 2, 4:45 PM - 5:00 PM
Wrap-Up and Q&A
Key takeaways, next steps, and close.
Key Outcomes
- Explain the Malaysian targeted financial sanctions regime and the obligations it places on reporting institutions
- Decide who and what to screen, and when, across onboarding, list updates and transactions
- Keep sanctions lists current and evidence every update
- Tune name matching and adjudicate alerts with documented, defensible reasons
- Freeze, reject and report correctly when a match is confirmed
- Test and govern a screening programme and report on it to the board
Training Mode Physical / Online / Hybrid / e-learning
HRD Corp SBL-Khas Claimable
Level Intermediate. For compliance, AML, operations, onboarding, payments and trade finance staff in banks, insurers and takaful operators, e-money issuers, money services businesses, capital market intermediaries and DNFBPs. Assumes AML basics.
Duration 2 Days (16 Hours) | 9:00 AM to 5:00 PM daily
Venue In-house at the client's premises, or delivered via the client's preferred platform (Microsoft Teams, Zoom, or equivalent)
Assessment An alert adjudication exercise and a full case scenario from list update to board report, plus a written knowledge check
Certificate Certificate of Completion issued to all participants upon full attendance