Anti-Money Laundering for Capital Market Intermediaries (SC Guidelines)
Capital market intermediaries are reporting institutions under AMLA, but their rulebook is the Securities Commission's, not Bank Negara's. The SC's Guidelines on Prevention of Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing and Targeted Financial Sanctions for Reporting Institutions in the Capital Market were first issued on 15 January 2014, and the third revision took effect on 13 June 2024. It aligned the guidelines with the latest FATF standards: stronger roles for the board and senior management, integration of National Risk Assessment findings, customer income information as part of due diligence, a risk-based approach to proliferation financing, disclosure for legal arrangements, and specific obligations for digital asset transactions. The SC then revised its targeted financial sanctions quick guides on 3 and 6 September 2024.
This two-day course is for compliance officers, MLROs and senior compliance staff at stockbrokers, fund managers, unit trust management companies, investment banks, trustees and other CMSA licensees and registered persons. It assumes the AML fundamentals covered in AML/CFT Compliance Officer and does not repeat them. It concentrates on what is specific to the capital market: the SC instrument itself, capital market typologies, trading-based red flags, suspicious transaction reporting where market misconduct and money laundering overlap, and TFS in securities accounts. Platform operators will find their sector covered in AML for Crowdfunding & Digital Asset Platforms, and all staff can take the awareness-level Capital Market Compliance Essentials.
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
The SC Instrument and How It Differs From BNM's
The legal basis under AMLA and the Capital Markets and Services Act, which persons are reporting institutions, and where the SC guidelines depart from the BNM policy document that most compliance officers learned first.
Day 1, 10:15 AM - 10:30 AM
Break
Day 1, 10:30 AM - 11:30 AM
What the June 2024 Revision Changed
Board and senior management responsibilities, integrating the National Risk Assessment into the institutional risk assessment, customer income information, disclosure for legal arrangements, and the obligations that attach to digital asset transactions.
Day 1, 11:30 AM - 12:30 PM
The AMLA Amendment Act 2025
What changed in the underlying Act, in force from 1 March 2026: explicit personal liability for directors, officers and employees, an expanded predicate offence base covering any federal offence carrying more than a year's imprisonment, digital and virtual currencies brought into the definition of a transaction, and a new Financing of Restricted Activities offence tied to the Strategic Trade Act 2010. What this means for a capital market intermediary's existing CDD and reporting processes.
Day 1, 12:30 PM - 1:30 PM
Lunch
Day 1, 1:30 PM - 3:15 PM
Institutional Risk Assessment for a Capital Market Firm
Products, channels, customers and geographies in broking, fund management and investment banking, and turning the National Risk Assessment into firm-specific ratings.
Day 1, 3:15 PM - 3:30 PM
Break
Day 1, 3:30 PM - 4:45 PM
Customer Due Diligence in Securities and Funds
Nominee and omnibus accounts, corporate and trust customers, beneficial owners, politically exposed persons, reliance on third parties and distributors, and ongoing due diligence driven by trading behaviour.
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
Capital Market Typologies and Red Flags
Layering through securities, mirror trades, pre-arranged trades, rapid in-and-out trading, use of third-party accounts, and proceeds from market manipulation and insider trading entering the market.
Day 2, 10:15 AM - 10:30 AM
Break
Day 2, 10:30 AM - 11:30 AM
Suspicious Transaction Reports Where Misconduct and Laundering Meet
Deciding when trading behaviour is a money laundering concern, a market misconduct concern or both, internal review and escalation timelines, and reporting to the Financial Intelligence and Enforcement Department.
Day 2, 11:30 AM - 12:30 PM
Proliferation Financing and Targeted Financial Sanctions
The risk-based approach to proliferation financing, the SC's TFS quick guides, screening customers and related parties, freezing securities and funds, and reporting.
Day 2, 12:30 PM - 1:30 PM
Lunch
Day 2, 1:30 PM - 3:15 PM
Governance, Record Keeping and Examinations
The compliance officer's reporting line, board and senior management information, record keeping, independent audit, and preparing for SC examination.
Day 2, 3:15 PM - 3:30 PM
Break
Day 2, 3:30 PM - 4:45 PM
Workshop: Five Capital Market Cases
Teams work through five cases, including a nominee account funding pattern, a pump-and-dump beneficiary and a sanctions hit on a unit holder, deciding due diligence, reporting and freezing actions.
Day 2, 4:45 PM - 5:00 PM
Wrap-Up and Q&A
Key takeaways, next steps, and close.
Key Outcomes
- Apply the SC AML/CFT/CPF and TFS guidelines rather than the BNM equivalent
- Explain what the June 2024 revision changed and implement it
- Explain what the AMLA Amendment Act 2025 changed from 1 March 2026 and its effect on existing CDD and reporting processes
- Build an institutional risk assessment for a capital market firm
- Recognise capital market money laundering typologies and trading red flags
- Decide and document suspicious transaction reports where market misconduct overlaps
- Implement proliferation financing and TFS controls for securities and fund accounts
Training Mode Physical / Online / Hybrid / e-learning
HRD Corp SBL-Khas Claimable
Level Intermediate. For compliance officers, MLROs and senior compliance staff at capital market intermediaries. Assumes AML Compliance Officer grounding.
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 Five capital market cases with written decisions, plus a written knowledge check
Certificate Certificate of Completion issued to all participants upon full attendance