On 17 November 2025, Bank Negara Malaysia (BNM), imposed a compound^[1] of RM8,625 on Ilham Secretarial Services (Ilham) for failure to promptly submit a suspicious transaction report (STR).^[2]

As a reporting institution (RI), Ilham is required to promptly submit an STR^[3] to BNM.^[4] 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.

During an on-site examination, BNM discovered that Ilham failed to promptly submit an STR on irregular transactions involving one customer. This failure was due to Ilham’s inadequate awareness of its responsibilities as an RI.

Ilham has taken remedial measures to strengthen its AML/CFT controls by establishing and implementing an STR reporting mechanism at the institution.

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

1. current controls to ensure compliance with the requirements;
2. past compliance record; and
3. post-misconduct behaviour and the effectiveness of remedial actions taken to prevent recurrence of breaches.

On 15 December 2025, Ilham paid RM8,625 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 Ilham 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 Public Prosecutor.

^[2] This  is set out under section 14(1)(b) of the AMLA, read together with section 86(a) of the AMLA.

^[3] Under section 14(1)(b) of the AMLA, RIs are required to promptly report any transaction where the identity of the person involved, the transaction itself or any other circumstances concerning that transaction gives any officer or employee of the RI reason to suspect that the transaction involves proceeds of an unlawful activity or instrumentalities of an offence.

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