Aml Ctfs

Anti-Money Laundering & Counter Terrorism Financing Statement

Kedah Islamic Asset Management Berhad (KIAM) is a licensed fund management company regulated by the Securities Commission Malaysia. We are firmly committed to combating money laundering, terrorism financing, and all forms of financial crime, which pose serious threats to the integrity of the financial system and society at large.

We recognise that jurisdictions worldwide have enacted comprehensive Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) laws imposing stringent obligations on financial institutions. In line with these global standards, KIAM upholds the highest levels of regulatory compliance and industry best practices. Our commitment to preventing money laundering and terrorist financing is unwavering, supported by robust systems, controls, and governance frameworks comparable to those adopted by regulated banking institutions.

Risk-Based Framework and Due Diligence

KIAM adopts a risk-based approach to identifying, assessing, and managing money laundering and terrorism financing risks. Our Customer Due Diligence (CDD) framework is designed to meet international best practices and regulatory expectations.

All investors are required to provide relevant personal information and supporting documentation when establishing a relationship with us. Where higher risks are identified—such as large transaction volumes, complex ownership structures, or Politically Exposed Persons (PEPs)—Enhanced Due Diligence (EDD) measures are applied to ensure a thorough assessment.

We conduct ongoing reviews of customer profiles to ensure information remains accurate, relevant, and up to date. KIAM reserves the right to decline, suspend, or terminate business relationships where CDD requirements are not satisfactorily met.

Customer Screening

Customer screening forms an integral part of our AML/CFT framework. All new and existing customers are screened against:

  • KIAM’s internal watchlists, including databases of blacklisted individuals and entities; and
  • Relevant lists covering Politically Exposed Persons, sanctioned individuals or entities, and those suspected or convicted of financial crimes.

This process supports early detection and mitigation of potential financial crime risks.

Transaction Monitoring and Detection

KIAM has implemented systems and processes to monitor customer transactions on an ongoing basis to identify unusual or suspicious activities. These include, but are not limited to:

  • Assessing whether transaction patterns are consistent with a customer’s stated investment objectives and risk profile; and
  • Evaluating whether transaction values align with the customer’s occupation, source of funds, and nature of business.

Cash and Third-Party Payment Controls

KIAM enforces a strict no-cash and no third-party payment policy. All investment payments must originate from the customer’s own bank account, and all withdrawals or distributions are made solely to the customer’s registered bank account.

We reserve the right to request additional information or documentation at any time to ensure compliance with this policy and applicable regulations.

Reporting Obligations

All employees and agents are required to promptly report any unusual or suspicious activities to the Compliance Officer. Where necessary, KIAM will submit a Suspicious Transaction Report (STR) to the Financial Intelligence and Enforcement Department of Bank Negara Malaysia in accordance with regulatory requirements.

Training and Awareness

KIAM places strong emphasis on continuous training and awareness. Regular AML/CFT training is provided to employees and agents, with enhanced focus on staff exposed to higher ML/TF risks, such as front-line and client-facing personnel. These programmes ensure ongoing awareness of regulatory developments, emerging risks, and evolving best practices.

Regulatory Framework

KIAM’s AML/CFT framework is guided by the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLATFPUAA), as well as all relevant laws, regulations, and guidelines issued by Malaysian regulatory authorities.

Through this framework, we aim to:

  • Detect, prevent, and report money laundering and terrorism financing activities to the relevant authorities;
  • Mitigate exposure to financial crime and regulatory breaches;
  • Maintain robust internal controls and governance; and
  • Safeguard the assets, reputation, and integrity of KIAM.