Limit of the transfer amount

❖ Cash Transaction limit - RM50，000

● A limit on physical cash transactions (i.e. currency notes and coins), as

provided under Clause 21 of the Currency Bill 2019 that was passed by
Dewan Rakyat and Dewan Negara in December. Any transactions above this
limit will have to be made electronically, by cheque or through the banking
system. This will cover all physical cash transactions i.e. consumer-to-
consumer, entity-to-entity, entity-to consumer (vice versa)
●
● To illustrate the application of the measure, the cash transaction limit is
assumed to be at RM50,000, with exemptions for most financial institutions
and exigent circumstances. Any physical cash payments above RM50,000 in
a single transaction is not allowed. Multiple transactions are also considered
as a single transaction if it is made with the same person, for the same
purpose, and within the same day. Actions to circumvent the application of
the limit is an offence.
chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://
www.bnm.gov.my/documents/20124/761679/CTL+InfoPack+Eng.pdf

❖ No limit for online transaction

● Real Time Electronics Transfer of Funds and Securities (RENTAS)
● No limit set for the transfer of funds between members. However, the
minimum transaction amount for third party payments (payments that
originate from a non-RENTAS member or beneficiary) is set at RM10,000.
This limit does not apply for payments to and from Bank Negara Malaysia and
government agencies.
https://www.bnm.gov.my/types-of-payment-systems

Is there any step that needs to be done if the amount is over the limit?
(report to normal bank or report to Bank Negara or any step?)
(after reporting to bank, any further steps need to do or the further liability is on the bank)

Customer Due Diligence (CDD) is a requirement under the Anti-Money Laundering, Anti-
Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA) and Money
Services Business Act 2011 (MSBA). CDD shall be conducted on customer conducting
transactions involving an amount equivalent to RM3,000 and above. Please produce your
identification document before making any transaction involving an amount equivalent to
RM3,000 and above.

GUIDELINES ON PREVENTION OF MONEY LAUNDERING AND TERRORISM

FINANCING FOR CAPITAL MARKET INTERMEDIARIES
Paragraph 6.3 : The board of directors must ensure the reporting institution regularly
reviews its policies, procedures and controls to ensure effectiveness and in line with
international developments, particularly the FATF Recommendations on combating.
Anti-Money Laundering, Countering Financing of Terrorism and Targeted Financial
Sanctions for Financial Institutions (AML/CFT and TFS for FIs)

chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.bnm.gov.my/
documents/20124/938039/AMLCFT+PD.pdf

22.1 General
S 22.1.1 Reporting institutions are required to promptly submit a suspicious transaction
report to the Financial Intelligence and Enforcement Department, Bank Negara Malaysia
whenever the reporting institution suspects or has reasonable grounds to suspect that the
transaction (including attempted or proposed), regardless of the amount:
(a) appears unusual;
(b) has no clear economic purpose;
(c) appears illegal;
(d) involves proceeds from an unlawful activity or instrumentalities of an offence; or
(e) indicates that the customer is involved in ML/TF.

22.1.2 Reporting institutions must provide the required and relevant information that gave
rise to doubt in the suspicious transaction report form, which includes but is not limited to the
nature or circumstances surrounding the transaction and business background of the person
conducting the transaction that is connected to the unlawful activity.

S 22.1.3 Reporting institutions must establish a reporting system for the submission of
suspicious transaction reports.

Triggers for Submission of Suspicious Transaction Report

22.3.1 Reporting institutions are required to establish internal criteria (“red flags”) to detect
suspicious transactions.

22.3.2 Reporting institutions must consider submitting a suspicious transaction report when
any of its customer’s transactions or attempted transactions fits the reporting institution’s list
of “red flags”.

22.3.3 Reporting institutions may refer to Appendix 4 of this policy document for examples of
transactions that may constitute triggers for the purpose of reporting suspicious transactions.

22.3.4 Reporting institutions may be guided by examples of suspicious transactions provided

by Bank Negara Malaysia or other corresponding competent authorities, supervisory
authorities and international organisations.

Example of Suspicious transactions given by Suruhanjaya Sekuriti

1. Large Cash Transactions Larger or unusual settlements of securities transactions in
cash form.
2. Opening of trading accounts with large cash sum (above RM 50,000).
3. The crediting of a customer’s margin account using cash and by means of numerous
credit slips by a customer such that the amount of each deposit is not substantial, but
the total of which is substantial.
 4. Depositing large cash amounts in the reporting institution’s multiple bank accounts in
the same day [Updated 21/4/2014]

Summary :
1. no limit for online transaction, but limit for cash transaction
2. individual/company no need do report if transfer big amount
3. the bank need to do report to bank negara if there is suspicious transaction
4. individuals/companies only need to be aware the transaction won't be suspicious.

Steps to prevent money laundering - Reporting Institution

Six steps to ensure the practice of due diligence and the compliance with the Anti Money
Laundering audit report is taken

Step 1: Know Your Clients

The information used for verification must come from a reliable and independent source
document, information, or data. If information is not accessible through these sources, you
must obtain the necessary documentation from your client directly. If the client is unwilling to
cooperate, immediately file a Suspicious Transaction Report (STR), and under no
circumstances should you commence a business relationship with him/her.

Customer due diligence is the process of identifying and verifying the identity of your
customer. A reporting institution must be satisfied that the customers are whom they say
they are. This includes knowing: the identity of the customer* the identity of beneficial owner
i.e. people behind the transaction the identity of person conducting transaction if the
transaction is done on behalf of someone else or the person you dealing with is a
representative appointed by a legal person the purpose i.e. why the transaction is
undertaken

Sub-paragraph 6.2 (e)GUIDELINES ON PREVENTION OF MONEY LAUNDERING

AND TERRORISM FINANCING FOR CAPITAL MARKET INTERMEDIARIES :
Customer Due Diligence: A reporting institution must have an effective procedure to
identify its customers and obtain satisfactory evidence to verify its customer's’
identity.

Step 2: Screening
At this stage of the AML/CFT screening, you need to examine your potential client’s name
against the Ministry of Home Affairs (MOHA) and the United Nations Security Council
Resolutions (UNSCR) Sanctions Lists for Terrorism, Proliferation, and other UN-Sanctions
Regimes for a possible positive name match. If there is a positive name match, conduct the
following steps: freeze the client’s funds, block all transactions, and reject the client
immediately.

Step 3: Risk Profiling

Risk profiling should be conducted based on the following risk factors: client,
product/services, geographical location, and form of the delivery channel used. If no prior
risk profiling has been done before, please refer to the Appendix 8 of Policy Document for
Anti-Money Laundering, Countering Financing of Terrorism (AML/CFT) and Targeted
Financial Sanctions for Designated Non-Financial Businesses and Professions (DNFBPs) &
Non-Bank Financial Institutions (NBFIs) on how you can perform risk profiling.

Step 4: Enhanced Due Diligence

For clients that are of a higher risk, enhanced customer due diligence is needed for you to
conduct meticulous checks on your customers. Information regarding their sources of
income must be gathered. Afterwhich, you would need to seek approval from your senior
management before commencing a business relationship with said client. If you get
suspicious about your client during the term of your business relationship, please file a
Suspicious Transaction Report (STR) immediately.

Step 5: Submit STR

If a STR needs to be filed, you can submit it through email or fax it to the relevant authorities
at Email: str@bnm.gov.my , Fax: +603-2693 3625

Step 6: Record Keeping

Lastly, Bank Negara Malaysia may inspect reporting institutions for their compliance with the
AML/CFT regulations and the Anti Money Laundering audit report would be examined.
Therefore, it is crucial that you keep all KYC information, copies of ID, transaction details,
and analyses done for STR (if any) submitted

Ensure that all of the information is easily accessible only to the relevant authorised persons
as records have to be kept for a minimum of six years.

If there are any changes to your client’s information, the AML/CFT screening process must
be repeated for you to update the necessary information accurately. This process is done to
ensure that your client complies with the Anti Money Laundering rules of Malaysia and
fosters a sense of integrity and stability in the business community.