Data and Compliance Report (DCR) Submission: What You Need to Know for 2024 [Issue 2 of 4]
The DCR is an essential annual submission for firms, documenting compliance efforts and risk assessments to meet Bank Negara Malaysia’s standards. The submission deadline will be January 15, 2025, and no extensions will be granted. Before initiating the report, firms must appoint a Compliance Officer (CO), who will oversee the process and act as a liaison with BNM.
Primary Sections of the DCR Include:
- Institutional and Business Information: Firms must provide essential business details, including the firm’s structure, sector designation, and CO information. This section also examines international affiliations or branch operations to assess a firm’s global exposure.
- Risk Assessment: This section requires firms to conduct thorough ML/TF/PF risk assessments across types of products/services, transaction volumes, payment methods, and the value of transactions.
- AML/CFT Compliance Program: Firms must demonstrate their AML/CFT compliance policies, including customer due diligence (CDD), risk-based screening of clients, employee training, and audit functions. Large institutions must further document employee screening processes and AML/CFT program efficacy, detailing how they address risk at various transaction points.
- Sanctions Screening: As part of their AML/CFT obligations, firms are required to screen clients against sanctions lists. Firms must indicate the sources and updates of these lists and verify that sanctioned individuals or entities do not conduct business through their services.
- Client Profile and Transactions: This segment breaks down client demographics, transaction values, and payment methods, requiring firms to account for cash transactions and categorize them by value. This data helps to determine potential exposure to ML/TF risks, especially among high-cash industries.
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