AML Risk Assessment Report Template for Malaysia

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Key Requirements PROMPT example:

AML Risk Assessment Report

"I need an AML Risk Assessment Report for a newly established digital payment service provider in Malaysia, focusing particularly on cryptocurrency transaction risks and cross-border payment channels, to be completed by March 2025."

Document background
The AML Risk Assessment Report is a crucial compliance document required by Malaysian regulatory authorities, particularly Bank Negara Malaysia, to evaluate and document an organization's exposure to money laundering and terrorism financing risks. This report is mandatory for reporting institutions under the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA) and must be conducted periodically or when significant changes occur in the business environment. The document provides a systematic analysis of inherent risks, control effectiveness, and residual risks, helping organizations understand their risk exposure and maintain compliance with Malaysian AML/CFT regulations.
Suggested Sections

1. Executive Summary: High-level overview of key findings, risk ratings, and critical recommendations

2. Introduction and Scope: Purpose of the assessment, methodology used, and scope of review including timeframe and limitations

3. Business Profile Assessment: Detailed analysis of the organization's business model, products/services, customer types, and geographical presence

4. Inherent Risk Assessment: Evaluation of inherent AML risks across different risk categories including customer, product, geographic, and transaction risks

5. Control Environment Assessment: Analysis of existing AML controls, policies, procedures, and their effectiveness

6. Residual Risk Assessment: Assessment of remaining risks after considering control effectiveness

7. Gap Analysis: Identification of gaps between current state and regulatory requirements/best practices

8. Risk Rating and Conclusions: Overall risk rating and key conclusions from the assessment

9. Recommendations: Detailed recommendations for addressing identified gaps and enhancing AML framework

Optional Sections

1. Technology and Systems Assessment: Detailed review of AML-related systems and technologies - include for organizations with significant technological infrastructure

2. Transaction Testing Results: Results of sample transaction testing - include when specific transaction testing was performed

3. Historical Incident Analysis: Analysis of past AML incidents or regulatory issues - include when there is relevant historical data

4. Regulatory Compliance Review: Detailed assessment against specific regulatory requirements - include for regulated entities

5. Branch/Subsidiary Assessment: Specific assessment of different branches or subsidiaries - include for organizations with multiple locations

6. Training and Resources Assessment: Evaluation of AML training programs and resource adequacy - include for larger organizations

Suggested Schedules

1. Risk Assessment Methodology: Detailed explanation of risk assessment approach, scoring criteria, and methodologies used

2. Risk Assessment Matrices: Detailed risk scoring matrices and calculations for different risk categories

3. Control Testing Results: Detailed results of control testing performed during the assessment

4. Statistical Analysis: Detailed statistical data and analysis supporting the risk assessment findings

5. Interview List and Summaries: List of stakeholders interviewed and key points from interviews

6. Document Review List: List of all documents reviewed during the assessment

7. Regulatory Requirements Matrix: Detailed mapping of applicable regulatory requirements and compliance status

8. Action Plan Template: Template for tracking implementation of recommendations

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions
Relevant Industries

Banking

Insurance

Securities and Investment

Money Services Business

Digital Payment Services

Gaming and Casino

Real Estate

Precious Metals and Stones Dealers

Legal Services

Accounting Services

Trust and Company Service Providers

Credit and Financial Institutions

Cryptocurrency and Digital Assets

Investment Management

Relevant Teams

Compliance

Risk Management

Internal Audit

Legal

Operations

Financial Crime Prevention

Customer Due Diligence

Transaction Monitoring

Investigations

Board Oversight

Executive Management

Regulatory Reporting

Relevant Roles

Chief Compliance Officer

AML Compliance Manager

Risk Management Officer

Internal Auditor

Compliance Analyst

Money Laundering Reporting Officer (MLRO)

Chief Risk Officer

Regulatory Compliance Director

AML Investigation Specialist

Due Diligence Officer

Financial Crime Prevention Manager

Compliance Monitoring Officer

Board Director

Chief Executive Officer

Head of Legal

Industries
Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA): The primary legislation governing AML/CFT requirements in Malaysia, providing the legal framework for preventing, detecting, and punishing money laundering and terrorism financing activities
BNM's Anti-Money Laundering, Countering Financing of Terrorism and Targeted Financial Sanctions for Financial Institutions (AML/CFT and TFS for FIs): Policy document issued by Bank Negara Malaysia providing detailed guidelines on AML/CFT requirements, risk assessment procedures, and compliance obligations for financial institutions
Financial Services Act 2013: Provides the regulatory framework for financial institutions in Malaysia, including provisions related to reporting and compliance requirements for AML/CFT
Islamic Financial Services Act 2013: Similar to the Financial Services Act but specifically for Islamic financial institutions, including AML/CFT requirements for Islamic banking and finance
FATF Recommendations: International standards on combating money laundering and terrorism financing that Malaysia has committed to implement as a FATF member
Malaysian Anti-Corruption Commission Act 2009: Relevant for assessing corruption risks which often intersect with money laundering risks
Companies Act 2016: Relevant for beneficial ownership requirements and corporate transparency which are crucial elements in AML risk assessment
BNM's Risk-Based Supervisory Framework: Guidelines on how to conduct risk assessments and implement risk-based approaches in AML/CFT compliance
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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