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Malaysia – (AMLA – Issue 4)

Guidelines Relating to the Obligations of Company Secretary as a Reporting Institution Under the Anti-Money Laundering, Anti-Terrorism Financing Proceeds of Unlawful Activities Act 2001 (AMLA) [Issue 4 of 4]

This section delves into the intricacies of the AML/CFT Compliance Programme tailored for company secretaries.

AML/CFT Compliance Programme 

  • Policies, Procedures, and Controls
  • Responsibilities of Board, Senior Management
  • Compliance Management Arrangements
  • Employee Screening Procedures
  • Employee Training and Awareness Programmes
  • Independent Audit Function
  • Application for a Small-sized Secretarial Firm
  • Application for Company Secretary Who is Employed by a Company to Handle Secretarial Functions of the Company/ Group of Companies – In-House Company Secretaries


As a conclusion, a company secretary must be able to appreciate his obligations under the Companies Act 2016 (CA2016) and the AMLA to ensure that he fully understands the requirements under these two distinct sets of regulations. The understanding of AMLA will help company secretaries to mitigate risk more effectively to ensure that no entity or individual can exploit potential gaps in the system, prevent loopholes in the regulatory framework as well and maintain the integrity of the company secretarial profession. Company secretaries are strongly encouraged to enhance their competence by participating in certified AML/CFT courses offered by SSM, BNM, professional bodies, and other relevant agencies. This will enable them to effectively fulfill their roles and responsibilities.