Maybank

Anti-Money Laundering/Counter Financing of Terrorism Policy

Maybank Group continues to adhere to the requirements of the Anti-Money Laundering and Anti-Terrorism Act 2001 (AMLATFA 2001), regulatory guidelines, its processes and procedures as well as international standards and best practices on a continuous basis. Increased sophistication and broader reach and networks in money laundering and terrorism financing (ML/TF) globally have elevated the ML/TF threat to the next level. In the fight against money laundering and terrorist financing, Maybank Group is committed to have strong AML/CFT practices which are necessary in ensuring the Group's AML/CFT risks are carefully managed. These will help lower the cost of doing business arising from AML/CFT investigations and cases as well as protect the integrity and reputation of the Group.

The Group continues to strengthen its enterprise-wide AML/CFT programme by adopting a risk-based approach to ensure that key measures are emplaced to prevent and mitigate money laundering and terrorist financing commensurate with the compliance risks that have been identified and assessed.

As part of its surveillance mechanism to combat money laundering and financing of terrorism, Group Compliance (GC) regularly communicates to business sectors the list of persons/ entities suspected of terrorism as issued by United Nations Security Council (UNSC), as to ensure that proper screening is carried out.

It has become evident that relevant AML/CFT training needs to be enhanced and customised accordingly. GC will continue to reinforce its involvement in specific training and certification programmes to remain robust. Every effort is also being made to ensure that AML/CFT training materials fit in with the changing risk and regulatory landscape.

GC has published on the Group's corporate website the AML/ CDD Questionnaires and Global USA Patriot Act Certification which provide an overview of the Group's practices, compliance to relevant laws and BNM guidelines, as well as its due diligence requirements for establishment of correspondent banking services. Our AML/CFT Policy Statement also provides a brief description of the general principles and key measures to which the Group adheres.

The Group will remain vigilant over the level of compliance at the business sectors with regards to AML/CFT rules and measures. Thematic examinations will continue to be carried out on branches and subsidiaries for AML/CFT compliance, when the need arises. Assessing the effectiveness of the AML/ CFT controls that have been established and maintained by entities within the Group forms a vital component of the Group's ongoing risk assessment towards meeting the revised Financial Action Task Force (FATF) Recommendations.

The new FATF Recommendations are an essential component in ensuring the Group's accountability and transparency and adherence to regulatory requirements.

As strengthening the Group-wide AML/CFT programme is a shared responsibility, the business sectors will be managed with an appropriate balance between risk taking activities and business prudence.

In such a case, the year 2012 has reflected the Group's strength and unique advantages in meeting this regulatory requirement.