1.Apexchange - AML Policy
Apexchange Sdn. Bhd.
ANTI-MONEY LAUNDERING POLICY[Approved by the Board of Directors]
1. STATEMENT
1.1 Apexchange Sdn. Bhd. is a licensed MSB provider authorized as a payment institution by the Bank Negara Malaysia under the Money ServicesBusiness Act 2011
1.2 APEXCHANGE is required by regulations to have in place internal control mechanisms, risk management procedures and money laundering
controls when providing money services to customers. Consequently APEXCHANGE is committed to manage the AML risk and has adopted an Anti-
Money Laundering compliance policy (‘AML Policy’) to detect and prevent money laundering and terrorist financing by incorporating compliance with the:
1.1.1 AML/CFT Act 2001, The Standard Guidelines on Anti Money Laundering and Counter Financing of Terrorism (UPW/GP1) issued November 2006
(ammended February 2009) ; and Anti Money Laundering and Counter Financing of Terrorism Sectoral Guidelines 3 (UPW/GP1[3]) issued
November 2006; and Guide Lines on Governance and Operational Requirements issued October 2012; and Guidelines on Risk Management and
Internal Controls for Conduct of Money Services Business issued December 2012;
1.1.2 Duties of Licensees and Remittance Business Regulation 2012; and Anti Money Laundering and Counter Financing of Terrorism (AML/CFT) - Money Services Business (Sector 3 ) issued September 2013
2. SCOPE
2.1 This AML Policy has been published to help APEXCHANGE customers and introducers of business understand the statutory and regulatory obligations of
APEXCHANGE as a money service business and payment institution and it applies to APEXCHANGE, its directors, Compliance officers and employees
who deal with customers and introducers of business in relation to its products and services.
2.2 APEXCHANGE will establish and implement appropriate risk sensitive policies and procedures to customer due diligence in identifying and
verification of identity and residence; ongoing monitoring of business relationships; reporting of suspicious transactions internally to the
Compliance Officer at first instance and then to the FIU in suspicious activity reports or other reports required to the law enforcement agencies and
regulatory authorities; assessment of money laundering risks; application of enhanced measures in higher risk situations; record keeping; monitoring and
compliance procedures; internal communications of policies and procedures and staff awareness and training on money laundering matters.
3. AML POLICY
3.1 It is the policy of APEXCHANGE to actively pursue the detection and prevention of money laundering and any activity that facilitates money laundering orfunding of terrorist or criminal activities or such acts designed to conceal or disguise the true origins of criminally derived proceeds so that unlawful
proceeds appear to have been derived from legitimate origins or constitute legitimate assets.
3.2 In dealing directly with customers and introducers of business, APEXCHANGE, Compliance officers and employees are required to comply with internal systems and controls and procedures in the prevention of use of its products and services for money laundering, terrorists funding or criminal activities.
3.3 Where customers are introduced to APEXCHANGE, it is required to verify their identity and residence pursuant to statutory and regulatory obligations in
the same way as it will do for its own customers.
3.4 APEXCHANGE does not
3.4.1 Enter into business relationships or execute transactions where details of the customer and/or beneficiary are unknown or cannot be identified or
verified including corporations owned by persons who hold bearer shares;
3.4.2 Enter into business relationships or execute transactions where the customer is listed or becomes listed in United Nations Security Council
financial sanctions list;
3.4.3 enter into business relationships or execute transactions where the customer or his assets are freezed by Bank Negara Malaysia;
3.4.4 accept non-cash payment transactions from customers;
3.4.5 establish customer relationships with shell banks incorporated in a jurisdiction in which it has no physical presence and which is unaffiliated with a
regulated financial institution or group;
3.4.6 transmit funds to any individuals or politically exposed persons (PEPs) and their family and close associates or political parties known to be
supporting terrorism or suspected criminal organizations or on Bank Negara Malaysia Treasury sanction list; and
3.4.7 enter into business relationships or execute transactions for customers who refuse to provide identification information and documents when
requested to so or who produce misleading information or whose identity and residence can-not be verified properly through independent sources.
3.4.1 Enter into business relationships or execute transactions where details of the customer and/or beneficiary are unknown or cannot be identified or
verified including corporations owned by persons who hold bearer shares;
3.4.2 Enter into business relationships or execute transactions where the customer is listed or becomes listed in United Nations Security Council
financial sanctions list;
3.4.3 enter into business relationships or execute transactions where the customer or his assets are freezed by Bank Negara Malaysia;
3.4.4 accept non-cash payment transactions from customers;
3.4.5 establish customer relationships with shell banks incorporated in a jurisdiction in which it has no physical presence and which is unaffiliated with a
regulated financial institution or group;
3.4.6 transmit funds to any individuals or politically exposed persons (PEPs) and their family and close associates or political parties known to be
supporting terrorism or suspected criminal organizations or on Bank Negara Malaysia Treasury sanction list; and
3.4.7 enter into business relationships or execute transactions for customers who refuse to provide identification information and documents when
requested to so or who produce misleading information or whose identity and residence can-not be verified properly through independent sources.
3.4 If APEXCHANGE decides not to establish business relationship with a customer or if there are reasonable grounds to suspect that the customer's
transaction to be in breach of the money laundering regulations criminal or terrorist financing laws and have made a STR, APEXCHANGE will not be
obliged to provide any reason for its actions which may include the blocking and stopping of its service.
3.5 by using APEXCHANGE products and services, customers agree to disclosure of such reports and personal information that it may possess as may be
required or requested by governmental and regulatory authorities and investigate and enforcement agencies and the courts, without their prior consent.
3.5 All internal Compliance Officer Reports of suspicious activity and external reports to the governmental enforcement agencies and regulatory authorities
will be documented in APEXCHANGE records.