AMLA Policy

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.

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 voluntarily commits to upholding the spirit of the Act.

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

Altruis strictly prohibits and actively prevents money laundering and any activities that facilitate it, including the funding of terrorist or criminal activities.

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.

4. Compliance Officer (CO)

4.1. Altruis shall designate a Compliance Officer with full authority to oversee and implement this policy.

4.2. The CO must be qualified, experienced, and fit to hold the role with impartiality. Responsibilities include:

• Development and amendment of the AML/CTF program.
• 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 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 the “Know Your Client” process.

9.2. Information collected includes identity verification and source of funds.

9.3. Screening will be conducted against Malaysian IC / UN-issued ID / valid passport. For legal entities: name, legal form and proof of existence, and identification of the authorised representative. For NGOs/charities: certificate of approval and 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.

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 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.