Bank Negara Malaysia (BNM) had, on 6 March 2025, imposed an Administrative Monetary Penalty (AMP)^[1] of RM6,000 on JAGS Money Sdn. Bhd. (JAGS) for non-compliances with the sanctions screening requirements under subsection 74(3) of the Money Services Business Act 2011 (MSBA), read together with paragraphs 27.3.5, 27.3.7 and 27.4.1 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).^[2]

The non-compliances resulted from JAGS’ failure to promptly update the sanctions database upon the publication of the Domestic List^[3] and failure to conduct sanctions screening on new customers against the Domestic List.

JAGS, as a reporting institution (RI), is required to conduct sanctions screening on existing, potential or new customers against the Domestic List and United Nations Security Council Resolutions (UNSCR) List^[4] as part of customer due diligence and ongoing due diligence processes. In response, JAGS has since taken remedial measures by subscribing to timely notifications of publications of the Domestic List and enhancing internal procedures to ensure timely updates of the sanctions database.

The AMP amount was determined by considering the relevant aggravating and mitigating factors, including:

1. severity of the non-compliances;
2. JAGS’ current controls, which were assessed to be generally adequate;
3. past compliance record of JAGS; and
4. assessment on JAGS’ post-misconduct behaviour, including the remedial actions taken to prevent recurrence of non-compliances.

JAGS paid a total of RM6,000 for the AMP imposed by BNM on 17 March 2025.

BNM requires all RIs to maintain a high level of commitment in ensuring compliance with targeted financial sanctions requirements. BNM will not hesitate to take appropriate supervisory and enforcement actions should any RI fall short of meeting its regulatory requirements.

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

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

^[2] The AML/CFT and TFS for FIs PD was in effect from 1 January 2020 to 5 February 2024 and has since been superseded by the Anti-Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing and Targeted Financial Sanctions for Financial Institutions Policy Document (AML/CFT/CPF and TFS for FIs PD), which took effect on 6 February 2024. These requirements are preserved under paragraphs 27.3.5, 27.3.7 and 27.4.1 of the AML/CFT/CPF and TFS for FIs PD.

^[3] Domestic List is a list of names and particulars of specified entities as declared by the Ministry of Home Affairs under the relevant subsidiary legislation made under section 66B(1) of the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA), following the entities involvement in acts of terrorism.

^[4] UNSCR List is 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 UNSCR and are deemed as specified entity by virtue of section 66C(2) of the AMLA.