AMLA Policy

Anti-Money Laundering & Counter-Terrorism Financing (AML/CTF) Policy

Abbreviations & Definitions

This AML/CTF Policy of Altruis, including all related procedures and documents

1. Introduction

This Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy is developed to ensure Altruis operates with high standards of integrity, transparency, and accountability in all its activities and financial operations. The Policy provides a structured framework to prevent and mitigate any risks associated with money laundering, terrorism financing, or other unlawful financial activities.

2. Statement of Commitment

2.1. Altruis is a Non-Profit Organisation (NPO) registered under the Registry of Societies, Malaysia.
2.2. Being an NPO, Altruis is not categorized as a Reporting Institution under Schedule 1 of the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA). However, Altruis is committed to being a model of good governance by voluntarily implementing AML/CTF policies and practices.
2.3. This policy is a testament to Altruis’s commitment to combatting all forms of money laundering and terrorism financing, ensuring its operations are transparent, ethical, and aligned with both national and international standards.

3. Money Laundering & Terrorism Financing

3.1 Policy Prohibition
Altruis strictly prohibits and actively prevents money laundering and any activities that facilitate it, including the funding of terrorist or criminal activities.
3.2 Definitions
Money laundering involves concealing the origins of illegally obtained money to make it appear legitimate. It typically occurs in three stages:
● Placement: Introduction of illicit funds into the financial system.
● Layering: Concealing the origin through complex transactions.
● Integration: Reintroducing funds as seemingly legitimate assets.

Terrorism financing may involve both lawful and unlawful funds intended to support terrorist activities. It is often less detectable due to small transaction amounts and the use of legitimate channels.

 

4. Compliance Officer (CO)

4.1. Altruis shall designate a Compliance Officer with full authority to oversee and
implement this AML/CTF policy.
4.2. The CO must be qualified, experienced, and fit to hold the role with impartiality.
4.3. Responsibilities include:
● Development and amendment of the AML/CTF program.
● Staff training and advisory.
● Monitoring compliance across all levels.
● Serving as the reporting officer to authorities.
● Maintaining records and liaising with regulators when required.

 

5. Effective Date

5.1. This policy is effective starting 1 January 2025.

6. Review

6.1. The policy shall be reviewed annually before 31 December 2025.
6.2. External parties may be appointed for independent reviews and assessments.

7. Circulation of Policy

7.1. This policy will be made accessible to all Altruis staff and volunteers via hardcopy and digital formats.
7.2. A mandatory workshop will be held before implementation to ensure awareness and understanding.
7.3. Refresher training will be conducted periodically, especially after policy amendments.

8. Risk Assessment & Risk Register

8.1. Altruis maintains a Risk Register developed from assessments of its donors, partners, and operations.
8.2. High-risk countries identified by FATF or other authorities (e.g., Israel and North Korea) will not be considered for collaboration.

 

9. Customer Due Diligence (CDD)

9.1. CDD is mandatory before engaging with any donor, partner, or collaborator. CDD is part of “Know Your Client” process.
9.2. Information collected includes identity verification and source of funds.
9.3. Screening will be conducted against:
● UN Sanctions List
● Ministry of Home Affairs (MOHA) List

9.4. Required documents:
For Individuals:
● Malaysian IC / UN-issued ID / valid passport

 

For Legal Entities:

● Name, legal form and proof of existence.
● Company/business registration number.
● Company’s profile.
● Business and registered address.
● To identify the authorised representative of the company/business.
● Certificate of Incorporation.
● Constitution (if applicable).
● Directors’ Resolution (if applicable).
● Partnership Agreement (if applicable).

For NGOs/Charities:

● Certificate of approval, registered constitution

 

10. Enhanced Due Diligence (EDD)

10.1. Applied for high-risk parties or jurisdictions flagged by FATF or sanctions lists.
10.2. EDD ensures deeper verification of the donor’s or partner’s legitimacy and
source of funds.

 

11. Record Keeping

11.1. All due diligence records shall be securely retained for 7 years.
11.2. Records include financial documents, CDD/EDD data, STRs, and HR files.
11.3. Both physical and digital record systems will be maintained and regularly
reviewed.

 

12. Ongoing Due Diligence (ODD)

12.1. Regular due diligence will be carried out on:
● Repeat donors
● Transactions exceeding thresholds set by Altruis

 

13. Politically Exposed Persons (PEP)

13.1. Altruis adopts FATF's definition of Foreign, Domestic, and International PEPs, including family members and close associates.
13.2. All PEPs will undergo EDD and be reported to the Compliance Officer.

14. Suspicious Transaction Reporting (STR)

14.1. Any transaction that is irregular, lacks clear purpose, or appears suspicious must be reported immediately to the CO.
14.2. The CO is responsible for submitting STRs to the Financial Intelligence and Enforcement Department of Bank Negara Malaysia (BNM).
14.3. STRs are strictly confidential and protected under applicable laws.