On 31 October 2025, Bank Negara Malaysia (BNM) imposed an Administrative Monetary Penalty (AMP)^[1] of RM14,000 on Moneywave Sdn. Bhd. (Moneywave) for non-compliances with the sanctions screening requirements under section 74(3) of the Money Services Business Act 2011 (MSBA), read together with:

• paragraphs 27.3.1, 27.3.6, 28.2.2 and 29.2.2 of the Anti-Money Laundering, Countering Financing of Terrorism and Targeted Financial Sanctions for Financial Institutions Policy Document (2019 AML/CFT and TFS for FIs PD); and
• paragraphs 27.3.1, 27.3.6, 28.2.2 and 29.2.2 of the Anti-Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing and Targeted Financial Sanctions for Financial Institutions Policy Document (2024 AML/CFT/CPF and TFS for FIs PD)^[2].

These provisions require Moneywave, as a reporting institution (RI), to maintain a sanctions database based on the United Nations Security Council Resolutions (UNSCR) List^[3] and Domestic List^[4]. Sanctions screening is essential to protect RIs and the broader financial system from being abused for terrorism and/or proliferation financing activities.

BNM detected the non-compliances during an on-site examination. The examination revealed that Moneywave failed to maintain any sanctions database based on the UNSCR List and the Domestic List.

In response, Moneywave has taken remedial measures by subscribing to a commercial sanctions database service, which has been integrated into its currency exchange system.

BNM has considered the relevant aggravating and mitigating factors in determining the imposition of the AMP. This includes:

1. the severity of the non-compliances;
2. Moneywave’s current controls to ensure compliance with the requirements, which were assessed as generally adequate;
3. Moneywave’s past compliance record; and
4. Moneywave’s post-misconduct behaviour and the effectiveness of remedial actions taken by Moneywave to prevent the recurrence of non-compliances.

Moneywave paid RM14,000 for the AMP on 4 November 2025.

BNM requires all RIs to ensure compliance with targeted financial sanctions requirements. BNM will not hesitate to take appropriate supervisory and enforcement actions should any RIs fail to meet legal or regulatory requirements.

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

^[1] BNM imposed the AMP pursuant to section 75(2)(b) of the Money Services Business Act 2011.

^[2] The 2019 AML/CFT and TFS for FIs PD was in effect from 1 January 2020 to 5 February 2024 and has since been superseded by the 2024 AML/CFT/CPF and TFS for FIs PD, which took effect on 6 February 2024.

^[3] UNSCR List contains a list of names and particulars of persons as designated by the United Nations Security Council (UNSC) or its relevant Sanctions Committee pursuant to the relevant UNSC Resolutions (UNSCR) and are deemed as:

1. specified entities by virtue of section 66C(2) of the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA) for Targeted Financial Sanctions on Terrorism Financing;
2. designated persons under the relevant Strategic Trade Act 2010 (STA) subsidiary legislation for Targeted Financial Sanctions on Proliferation Financing; and
3. designated persons under the relevant Central Bank of Malaysia Act 2009 (CBA) Regulations for Targeted Financial Sanctions under the Other UN-Sanctions Regimes.

^[4] The Domestic List is a list of names and particulars of specified entities as declared by the Minister of Home Affairs under relevant subsidiary legislation made under section 66B(1) of the AMLA.