Bank Negara Malaysia (BNM) had, on 28 August 2024, imposed an Administrative Monetary Penalty (AMP)^[1] of RM51,000 on Worldwide Superstar Money Changer Sdn. Bhd. (WSMC) for non-compliance with customer due diligence (CDD) requirements under sections 74 and 75(1)(b) of the Money Services Business Act 2011 (MSBA), read together with paragraphs 14C.1(b) and 14C.12.1 of the Anti-Money Laundering, Countering Financing of Terrorism and Targeted Financial Sanctions for Financial Institutions Policy Document (AML/CFT and TFS for FIs PD). Additionally, WSMC failed to ensure the proper installation and coverage of its CCTV camera at its premises, which is a contravention of sections 74 and 75(1)(b) MSBA read together with paragraph 29.8.3(a) of Governance, Risk Management and Operations for MSB Policy Document (GRMO).

The non-compliances were detected by BNM during an on-site examination. WSMC failed to conduct CDD on four customers facilitated through deliberate acts to split the transactions into amounts below RM3,000 for the conduct of CDD. The examination also found that WSMC did not install any CCTV cameras at its premises where the company keeps its business funds.

Reporting institutions (RIs) are required to conduct CDD to assess their exposure to money laundering (ML)/terrorism financing (TF) risks and take appropriate measures to prevent the RI from being a conduit for facilitating ML/TF and any other serious crimes activities. Furthermore, WSMC failed to implement an important control measure served by the operation of CCTV cameras that enable management to carry out proper surveillance and monitor business operations on an ongoing basis to protect MSB operations from being abused for ML, TF or other illicit purposes.

In deciding to impose the AMP, BNM considered relevant aggravating and mitigating factors, which include:

1. the degree of culpability of individuals within the firm, leading to the non-compliance;
2. the effectiveness of controls in place to detect and prevent non-compliance;
3. WSMC’s past compliance record; and
4. remedial actions taken by WSMC to prevent the recurrence of non-compliance. This includes actions taken to strengthen its CDD processes, extend coverage of its CCTV cameras and reprimand individuals who failed to comply with CDD requirements.

WSMC^[2] paid a total of RM51,000 for the AMP imposed by BNM on 26 November 2024.

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

^[1] BNM issued the AMP pursuant to section 75(2)(b) of MSBA.

^[2] WSMC decided to surrender its license on 12 December 2024.