On 17 November 2025, Bank Negara Malaysia (BNM), imposed a compound^[1] of RM46,000 on Boardroom Corporate Services Sdn. Bhd. (Boardroom) for failure to promptly submit suspicious transaction report (STR)^[2] and failure to conduct enhanced customer due diligence (EDD).^[3]

As a reporting institution (RI), Boardroom is required to promptly submit an STR to BNM^[4] when a customer fits its established internal criteria (“red flags”).^[5] This mitigates the risk of RIs from being used as channels for money laundering and terrorism financing (ML/TF), and other serious crime activities. Additionally, the STR submitted provides BNM and other law enforcement agencies with valuable information and/or intelligence on potential criminal activities to support financial crime investigations.

RIs are also required to conduct EDD on their customers^[6] when ML/TF risks are assessed to be higher or when nominee services^[7] are provided. This allows RIs to assess their exposure to ML/TF risks more effectively and implement appropriate mitigation measures.

During an on-site examination, BNM discovered that Boardroom failed to promptly submit an STR for a customer who matched its internal red flags. Boardroom also failed to conduct EDD on one high-risk customer and two customers who received nominee services. These failures were due to Boardroom’s inadequate awareness of its responsibilities as an RI.

Boardroom has taken remedial measures to strengthen its AML/CFT controls and processes. This includes a comprehensive review of higher-risk customer profiles and transactions to ensure effective STR reporting, as well as improvements to the documentation and record-keeping procedures of the EDD processes.

In deciding the compound to be imposed, relevant aggravating and mitigating factors were considered. This includes the severity of the breaches and Boardroom’s:

1. overall weakness in AML/CFT control measures during the material time;
2. past compliance record; and
3. post-misconduct behaviour and the effectiveness of remedial actions to prevent recurrence of breaches.

On 16 December 2025, Boardroom paid RM46,000 for the compound imposed by BNM.

BNM requires all RIs to maintain a high level of commitment in ensuring compliance with AML/CFT requirements. BNM will not hesitate to take appropriate supervisory and enforcement actions should any RI fail to meet legal and/or regulatory requirements.

The enforcement action taken against Boardroom is in line with the approach and processes outlined in the published Enforcement Approach.

^[1] BNM imposed the compound pursuant to section 92 of the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA), with the written consent of the Public Prosecutor.

^[2] This is set out under section 86(b) of the AMLA read together with section 83 of the same Act for breach of paragraph 19.3.2 of the Anti-Money Laundering, Countering Financing of Terrorism and Targeted Financial Sanctions for Designated Non-Financial Businesses and Professions (DNFBPs) and Non-Bank Financial Institutions (NBFIs) Policy Document (AML/CFT and TFS for DNFBPs and NBFIs PD).

^[3] This is set out under section 86(b) of the AMLA read together with section 16(5) of the same Act for breach of paragraphs 14.11.1 and 14C.2.1 of the AML/CFT and TFS for DNFBPs and NBFIs PD.

Note: The AML/CFT and TFS for DNFBPs and NBFIs PD was in effect from 1 January 2020 to 5 February 2024 and has since been superseded by the Anti-Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing and Targeted Financial Sanctions for Designated Non-Financial Businesses and Professions (DNFBPs) and Non-Bank Financial Institutions (NBFIs) Policy Document (AML/CFT/CPF and TFS for DNFBPs and NBFIs PD), which took effect on 6 February 2024. These requirements are preserved under paragraphs 19.3.2, 14.11.1 and 14C.2.1 of the AML/CFT/CPF and TFS for DNFBPs and NBFIs PD.

^[4] BNM is the competent authority as appointed under section 7(1) of the AMLA.

^[5] Under paragraph 19.3.2 of the AML/CFT and TFS for DNFBPs and NBFIs PD, RIs must consider submitting an STR when any of their customer’s transactions or attempted transactions fit the RI’s description of “red flags”.

^[6] Under paragraphs 14.11.1 and 14C.2.1 of the AML/CFT and TFS for DNFBPs and NBFIs PD, RIs are required to perform EDD where the ML/TF risks are assessed as higher risk and where nominee services are provided respectively.

Note: The requirements concerning nominee services are applicable specifically to certain DNFBP sectors.

^[7] Refer to nominee shareholding, directorship or partnership services, where applicable.