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ANTI-MONEY LAUNDERING &COUNTER FINANCING OFTERRORISM (AML/CFT)FRAMEWORK AND GUIDELINESAgent’s Reading Material2016Disclaimer:“This reading material is purely used for the internal agency of Great Eastern Life Assurance (Malaysia) Berhad. All or any part of the contents of thisreading material shall not be used directly or indirectly for soliciting insurance business, policyholder services and/or facilitating any other form ofcommunications with any external party whatsoever. This information is correct as at 03/04/2016FOR INTERNAL CIRCULATION & TRAINING PURPOSES ONLYPAGE 1CFE/STF/AML CFT/03/04/2016V1

COURSE OBJECTIVES To create awareness amongst agents and employees on Anti-MoneyLaundering and Counter Financing of Terrorism (AML/CFT) legislationand the regulatory guideline derived from it and appreciate itsimportance. To create understanding of the AML/CFT framework that determinesthe AML/CFT policy and standards in the Company. To create an understanding on the impact of money laundering andterrorist financing to the Company.PAGE2ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

SCOPE OF COVERAGE Definitions of Money Laundering & Terrorist Financing(ML/TF)The Anti-Money Laundering/Counter Financing ofTerrorism (AML/CFT) Legislation & Bank NegaraMalaysia (BNM) GuidelinesThe AML/CFT FrameworkReporting StructureSuspicious Cases – Modus OperandiOther developments on AML/CFTPAGE3ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Definition of Money LaunderingA process whereby criminals attempt to hide & disguise thetrue origin and ownership of the proceeds derived fromcriminal activities to give it a legitimate appearance.“This is a process to make illegitimate income appearlegitimate thereby avoiding prosecution, conviction &confiscation of the criminal funds.”PAGE4ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Definition of Money Laundering UnderAML/CFT LegislationThe definition of Anti-Money Laundering,Anti-Terrorism Financing and Proceeds of UnlawfulActivities Act 2001 (“AMLA 2001”) states thatMoney laundering is the act of a person who:a)Engages, directly or indirectly, in a transaction that involves proceedsfrom any unlawful activity.b)Acquires, receives, possesses, disguises, transfers, converts, exchanges,carries, disposes, uses, removes from or brings into Malaysia proceedsof any unlawful activity.c)Conceals, disguises or impedes the establishment of the true nature,origin, location, movement, disposition, title of, rights with respect to, orownership of, proceeds of any unlawful activity.PAGE5ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Who are the Money Launderers?The typical characteristics of money launderers are: Focused on intent Innovative / Knowledgeable Rich Prepared to lose some moneyPAGE6ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Money Laundering ProcessAlso called“whitewashing”.Conversion /movements toseparate the illicitproceeds from theirsourceIntroducingillegalprofits intothe financialsystem To disguiseaudit trail Provide anappearance oflegitimacyAfter the Layering process, the money are thenreintroduced into the financial / businesssystem - for example: investments in business,purchase of assetsPAGE7 ProvideanonymityANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Definition of Financing of TerrorismFinancing of terrorism generally refers to carrying out transactionsinvolving funds that may or may not be owned by terrorist, or that havebeen, or are intended to be, used to assist the commission of terrorism.More detailed description of financing of terrorism includes :1) providing or collecting properties for carrying out an act ofterrorism2) providing services for terrorism purposes3) arranging for the retention or control of terrorist properties or dealing with terrorist properties.PAGE8ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

AML/CFT Legislation and Regulation Purpose : To ensure that insurance/takaful industry has a strong control andinitiative on anti-money laundering efforts. Current AML/CFT Legislation and Regulation for insurance/takaful industryinclude :1)NewAnti-MoneyLaundering, AntiTerrorismFinancing andProceeds ofUnlawful ActivitiesAct 2001 effectiveon 15 /1/ 2002(AMLA 2001)previously known asThe Anti-MoneyLaundering and AntiTerrorism FinancingAct 20011) JPI/GPI 27 Guidelines on AntiMoney LaunderingMeasures for theInsurance Industry issued on25/4/20012) JPI 20/2004 –AMLA 2001VerificationProcedures –issued on21/8/2004Legislation1)UPW/GP1 : StandardGuidelines on Anti MoneyLaundering and CounterFinancing of Terrorism(AML/CFT).2) UPW/GP1 [2]: AntiMoney Laundering andCounter Financing ofTerrorism (AML/CFT)Sectorial Guidelines 2 forInsurance and TakafulIndustries.1) BNM/RH/STD 029 –1 Anti-MoneyLaundering andCounter Financing ofTerrorism (AML/CFT) –Insurance and Takaful(Sector 2)Issued on 4/9/2013 andtook effect on15/9/2013Originally Issued on15/11/2006 and revisionon 3 /2/2009RegulationsNote: The regulatory guideline was issued in accordance with the AMLA 2001 and Financial Action Task Force’s(FATF) 40 Recommendations for Implementation with effect from 15 September 2013.For more details on AML/CFT Legislation and Regulation, please visit: RNALCIRCULATION& TRAININGPURPOSESANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)

Governing Legislation and RegulationAMLA 2001 & the Governing GuidelineGovernment AgenciesRegulatorNational Coordination Committee: Companies Commission of MalaysiaLabuan Financial Services AuthorityRegistrar of SocietiesSecurities commissionInland Revenue BoardImmigration DepartmentMACCRoyal Malaysian CustomsRoyal Malaysia PoliceMinistry of FinanceMinistry of Foreign AffairsHome MinistryMinistry of Domestic TradeCooperatives & Consumerism Attorney-General Chambers Ministry of International Trade tionBank NegaraMalaysia(BNM)Competent Authorityappointed oversee theenforcement of AMLA 2001Deposit-TakingInstitutionsMoney ServicesBusinessInsurerInsurers(Great Eastern)* Full list in 1st schedule of AMLA2001.ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

What is a Serious Offence?Defined as an illegal activity which is related, directly or indirectly toML/TF: any of the serious offences specified in the Second Schedule ofAMLA 2001. An attempt to commit any of those offences, or Abetment of any of those offences.The AMLA 2001 covers serious offences committed in Malaysia andoffence committed in a foreign country which would also constitute aserious offence in Malaysia.The serious offences are as set out in the 2nd schedule of AMLA 2001,taken from 42 legislations.PAGE11ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

What is Serious Offence?2nd Schedule of AMLA 2001:Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001.International Trade in Endangered Species Act 2008.Anti-Trafficking in Persons and Anti-Smuggling of Migrants Act 2007.Islamic Financial Services Act 2013.Betting Act 1953.Kidnapping Act 1961.Capital Markets and Services Act 2007.Kootu Funds (Prohibition) Act 1971.Child Act 2001.Labuan Financial Services and Securities Act 2010.Common Gaming House Act 1953.Labuan Islamic Financial Services and Securities Act 2010.Companies Act 1965.Malaysia Anti-Corruption Commission Act 2009.Control of Supplies Act 1961.Malaysia Palm Oil Board (Licensing) Regulations 2005.Control of Supplies Regulations 1974.Malaysian Timber Industry Board (Incorporation) Act 1973.Copyright Act 1987.Moneylenders Act 1951.Corrosive and Explosive Substances and Offensive Weapons Act 1958.Money Services Business Act 2011.Customs Act 1967.Optical Discs Act 2000.Dangerous Drugs Act 1952.Pawnbrokers Act 1972.Dangerous Drugs (Forfeiture of Property) Act 1988.Penal Code.Development Financial Institutions Act 2002.Sales Tax Act 1972.Direct Sales and Anti-Pyramid Scheme Act 1993.Service Tax Act 1975.Excise Act 1976.Strategic Trade 2010.Explosives Act 1957.Strategic Trade (United Security Council Resolutions) Regulations 2010.Financial Services Act 2013.Trade Descriptions Act 2011.Firearms (Increased Penalties) Act 1971.Wildlife Conservation Act 2010.Income Tax Act 1967.Malaysian Palm Oil Board Act 1998PAGE12FORINTERNALCIRCULATION& TRAININGPURPOSESANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)

What is Serious Offence?Some examples of serious offences include : Corruption/ bribery. Smuggling offences. Trafficking in firearms/ drugs. Unlawful gambling, deposit taking or investment schemes. Robbery/ murder/ theft/ extortion/ kidnapping/ abduction. Infringement of copyright. Person living on or trading in prostitution. Criminal breach of trust (CBT)/ cheating/ forgery. Insider trading/ market manipulation. Carrying on banking/FI/merchant banking/discount house/ moneybroking, insurance, insurance broking, adjusting business, Takaful businesswithout valid license.PAGE13ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Key Provisions in AMLA 2001Section 4DescriptionImplicationAny person who engages in or attemptsto engage in, or abets the commission ofmoney laundering, commits an offence5 times the value of proceeds or RM5million (whichever is higher), and 15years imprisonment.Section 20DescriptionImplicationThe provision overrides any obligation as No institution under the law canto secrecy or other restriction on thewithheld information of suspecteddisclosure of information imposed byperson from investigating officer.any written law or otherwise.PAGE14ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Key Provisions in AMLA 2001Section 22 DescriptionImplicationOfficer of a Reporting Institution shalltake all reasonable steps to ensurecompliance with AMLA 2001. RM1 million or 3 years imprisonmentor bothin the case of continuing offence, a further fine but RM3K for each day or part thereofduring which the offence continues to be committed.Section 24 – Protection Of Person ReportingDescriptionImplicationNo civil, criminal or disciplinaryproceedings shall be brought against aperson who discloses or supplies anyinformation unless it is done in bad faith.Person who aids in the investigation bydisclosing or supplying information will beprotected by the law.PAGE15ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Key Provisions in AMLA 2001Section 26DescriptionImplicationFailure to provide document orinformation requested by the examiner. RM3 million or 5 years imprisonmentor bothSection 27DescriptionImplicationFailure to appear before the examiner RM3 million or 5 years imprisonmentor bothPAGE16ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Key Provisions in AMLA 2001Section 35 – Tipping Off (Leakage of information)DescriptionImplicationIf you disclose any information to anyoneabout a proposed investigation.Liable upon conviction RM3 million or 5 years imprisonmentor bothSection 37 (3) – Failure to Deliver Property, Record, Report Or DocumentDescriptionImplicationFailure to provide any property/ record/report/ document that is required by aninvestigating officer.Liable upon conviction RM3 million or 5 years imprisonmentor both* in the case of continuing offence, a further fine but RM1K for each day during whichthe offence continues after conviction.PAGE17ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Key Provisions in AMLA 2001Section 38 – Power To Seize Of Property, Record Or DocumentsDescriptionImplicationAn investigation officer may seize, takepossession of and retain for such durationas he deems necessary, any property,record, report or document producedbefore him in the course of anexamination.In previous cases, certain records, reportsand documents has been requested byIOs from MACC where the original aretaken & retain.Section 41 – Investigation Officer May Arrest Without WarrantDescriptionImplicationInvestigating officer may arrest withoutwarrant a person whom he reasonablysuspects to have committed or to becommitting any offence under this Act.This is not necessary done only by thepolice but agents from other lawenforcement agencies like MACC.PAGE18ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Key Provisions in AMLA 2001Section 86DescriptionImplicationFor penalty that is not expressly RM1 millionprovided for any offences under AMLASection 92DescriptionImplicationFurther empowers BNM to compoundin cases of continuing offenceCompound rate of 50% of themaximum fine amountPAGE19ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Key Provisions in AMLA 2001Section 87 – Offence Committed By Any Person In An Official CapacityDescriptionImplicationWhere an offence is committed by a corporation /association, the director, controller, officer / partner /person concerned in management is deemed guiltyunless he proves that :For a company likeGreat Eastern, theliable person could bethe ComplianceOfficer, Head ofDepartment and/orpersons responsiblefor certain tasks The offence is committed without the consent orconnivance; and He exercised such diligence to prevent thecommission of the offence as he ought to haveexercised, having regard to the nature of his functionin that capacity and to the circumstances.PAGE20ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkAs Required by BNM’s AML/CFT Guidelines & GroupAML/CFT Policy: Risk Based Approach Application Customer Acceptance Standard Customer Due Diligence Standard On-Going Monitoring Standard AML/CFT Training Standard Record Keeping Practices Suspicious Transaction Reporting Combating The Financing Of TerrorismPAGE21ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkCustomer Acceptance Standard Reporting Institutions are required to develop policy and procedures toaddress the establishment of business relationship with the customer. The objective is to address different risks posed by each type of customerthrough profiling. Risk profiling – Factors to consider: the origin of the customers and location of businessbackground or profile of the customernature of the customer’s businessstructure of ownership for a corporate customerany other information suggesting that the customer is of higher riskPAGE22ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkCustomer Due Diligence Standard – Know Your Customers (KYC)Identification & VerificationDetermine the true identity of prospect, to verify and be satisfied that: Identity of customer is genuine. The Company shall not have any business dealingswithi. anonymous person or any person using a fictitious nameii. non-policy holder who does not transact in relation to an insurance policy issuedby the companyiii. financial institutions which do not have adequate controls against criminalactivities or shell banksiv. any person and entities sanctioned/designated in the Monetary Authority ofSingapore (MAS) & BNM (Anti-terrorism Measures) regulations or otherapplicable regulations issued by the relevant authorities. Insurance/Takaful transaction to be undertaken is legitimate Verify all parties to the contract – include any underlying principals thatpolicy/certificate owners are acting on behalf, all joint applicants to the contract,principal shareholders and directors for group life policies/certificates and to includeverification of beneficiaries if they are not the policy/certificate owners.PAGE23ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkCustomer Due Diligence Standard – Know Your Customers (KYC)Generally, verification should be performed at the point of sale and via face-to-face contact.Although the ultimate responsibility of CDD remains with the Insurance Company / TakafulOperator, reliance is placed on agents/intermediaries as first point of contact to performCustomer Due Diligence (CDD) at point of sale.Amount of PremiumAny amount (effective from 1 January 2014)On who?Customer, its Beneficial Ownerand Natural Person appointed toact on a customer’s behalf.Beneficiary, Payee, Executors/Administrators of an estate inrelation to death claims andalso to panel hospitals, panelclinics and service providerIdentificationWhen establishing businessrelationshipAt the point of nomination andat the time of payoutVerification*When establishing businessrelationshipLatest at the point of payoutPAGE24ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkCustomer Due Diligence Standard – Know Your Customers (KYC)Current CDD PracticesInformation and documents required to perform identification and verificationA.Individual CustomersObtain at least the following information: Full name NRIC / passport number Permanent and mailing address Date and place of birth Nationality Occupation type Name of employer & nature of businessTo be substantiated / verified against : NRIC for Malaysians/permanent residents Passport for foreignersA copy of the verified documents should be collected by agents/intermediaries andretained by the insurer/takaful operator regardless of premium/contribution amount(effective from 1 January 2014) ANTI-MONEY LAUNDERING & COUNTER FINANCING OF TERRORISM (AML/CFT)PAGE25FOR INTERNAL CIRCULATION & TRAINING PURPOSES ONLY

The AML/CFT FrameworkCustomer Due Diligence Standard – Know Your Customers (KYC)B. Corporate CustomersUnderstand the ownership and control structure in order to detect any unusual circumstancesconcerning the changes to the company/business structure or ownership.Furnish the following a copy of the following documents:1)2)3)4)5)Memorandum/Article/Certificate of Incorporation/PartnershipIdentification document of Directors/Shareholders/Partners (Form 24/Form 49,may be accepted)Board of Directors’/Directors’ ResolutionAuthorisation for any person to represent the company/businessIdentification document of authorised personPAGE26ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkCustomer Due Diligence Standard – Know Your Customers (KYC)B.Corporate Customers (cont’d)To identify the natural person(s) (directors/ shareholders) with equity interest of more than25%. Where no natural person is identified, to identify relevant natural person who holds theposition of senior management of the corporation.C.Clubs, Societies and CharitiesFurnish the following documents: relevant constituent documents (or other similar documents). the identification of the office bearer. authorisation for any person to represent the club, society or charity.D. Legal ArrangementsTake reasonable measures to: Understand the relationship among the relevant parties. Obtain satisfactory evidence of its legal status the identity of the relevant parties. The nature of their capacity and duties as trustee or nominee. (in Great Eastern,we do not deal with Power of Attorney)PAGE27ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkCustomer Due Diligence Standard – Know Your Customers (KYC)Know Your Customer (KYC)For higher risk customers or in a more suspicious situation, further CDD measure knownas KYC is conducted. This is done through completion of the follow forms, depending onthe threshold of sum assured or annualized premium/contribution: Financial Questionnaire 1 – To be filled by agent on customer’s behalf. Details to becompleted includes purpose of insurance/takaful, proposer’s annual earned & unearnedincome, and declaration of networth. Financial Questionnaire 2 – To be filled by customer. Details to be completedincludes, purpose of insurance/takaful, proposer’s annual earned & unearned income,percentage of in company share (for company directors only), and relationship to lifeassured/person covered (if different).PAGE28ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkCustomer Due Diligence Standard – ECDDEnhanced Customer Due Diligence (ECDD)The Company shall conduct enhanced due diligence on higher risk customers orwhen establishing a business relationship with customers: Whom are suspected of money laundering or financing of terrorism Where there are doubts about the reliability or adequacy of previouslyobtained informationAn ECDD will include the following measures: Obtaining more detailed information on the customer and through publiclyavailable information, in particular, on the purpose of the transaction andsource of funds and Obtaining approval from the Senior Management before establishing anybusiness relationship with the customer.*Unwillingness of customer to cooperate may itself be a factor of suspicion. It isthe Company’s policy that underwriters shall not underwrite unless sufficientidentification evidence is provided.PAGE29ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkCustomer Due Diligence Standard – ECDDPOLITICALLY EXPOSED PERSON (PEP) PEPs are foreign / domestic individuals being, or who have been, entrusted with prominentpublic functions. E.g. heads of state or government, senior politicians, senior governmentofficials, judicial or military officials and senior executives of public organisations The concern placed in dealing with PEPs lies with the possibility of such PEPs abusing theirpublic powers for their own illicit enrichment, especially in countries where corruption iswidespread Agents are to inform/ disclose to the Company if the current or new customers are PEPs orrelated to PEPs in the proposal form/agent’s confidential report Company is required to take appropriate measures to establish the source of wealth andsource of funds of such personPAGE30ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkTraining StandardAML/CFT Training Standard sets out the requirement for the Training & AwarenessProgrammeMinimum training requirement includes: New employees and agents. It is compulsory for all agents to undergo AML/CFTTraining within 2 years of joining the Company. The Board of Directors and Senior Management team to ensure that there isadequate training provided including promoting staff awareness on individualAML/CFT obligations and penalties if they failed to discharge their duties properlyunder the Act. Refresher course will also be made available on regular basis for all staff (includingagents) who have attended the initial training.PAGE31ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkRecord Keeping Practices Records should be kept for a period of NOT LESS THAN 6 years from thedate an account has been closed or transaction has been completed orterminated. Scope of record keeping extended to include accounts, businesscorrespondence and documents relating to an account, businessrelationship, transaction or activity with a customer as well as result of anyanalysis taken. Failing to comply, a fine of up to RM3 million or imprisonment to a term notexceeding 5 years would be imposed. Agents are encouraged to inform the Company to update the customer’srecords when there are changes/updates in the customers’ personalinformation including but not limited to their NRIC/passport number,nationality, occupation/employment and nature of business.PAGE32ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkRecognizing & Reporting Suspicious Transactions on ML/TF(Section 14)What is Suspicion? Subjective and there is no specific provision or definition in AMLA. With effect from 9/3/2007, Reporting Institutions are also required to report anyATTEMPTED transaction(s) that are suspicious (apart from reporting the completedtransaction(s) that are suspicious).Suspicious Transaction? What to Look Out For?1.Transactions That Do Not Make Economic Sense Transactions in which the nature, size or frequency appears unusual. Transactions which are incompatible with the customer’s normal activity or beyondthe customer’s financial means.PAGE33ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkRecognizing & Reporting Suspicious Transactions (Section 14)2. Transactions Involving Unusual receipts or payment of funds Transactions whereby large or unusual premium/contribution payment in cashis received from customer. Transactions which funds are paid or received through unrelated third party.3. Others Abnormal patterns of top-ups and withdrawals for investment RING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Suspicious Cases – Modus Operandi Request for refund to be paid to unrelated 3rd party. Change payment mode when requested to complete financial questionnaire. Use of funds from 3 party (seemingly related) for Investment Linked top-upand subsequently early cancellation/withdrawal. Series of application of policy loans and repayments within a short timeperiod. Unrealistic wealth compared with customer’s financial profile. Staggered policies/certificate surrender (with small amount of surrender valueper policy/certificate, cumulatively, the surrender amount are huge) withinseveral months, with reason not satisfied with agent's services, which couldhave been done in one occasion. Large sum of cash premium/contribution payment.rdPAGE35ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

The AML/CFT FrameworkReporting Suspicious TransactionKEY OPERATING DEPTS,AGENTS & OTHER INTERMEDIARIESHead Office or Branch OfficesIn the event of any suspicious transactionsdetected, it is important to escalate toCompliance within 2 working days via thefollowing communication channels:Email:GELM/OACM: AML-MY@greateasternlife.comCOMPLIANCE DEPARTMENTFinancial Crime Intervention UnitGETB : 8Mail :BANK NEGARA MALAYSIAFinancial Intelligence Unit (FIU)PAGE36GELM & OACMGETBCompliance Dept, Level 10Compliance Dept, Level 3Menara Great Eastern,Menara Great Eastern,No. 303, Jalan Ampang,No. 303, Jalan Ampang,50450 Kuala Lumpur.50450 Kuala Lumpur.ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Sanctions ComplianceSanction is a restriction or prohibition, imposed by one country orgroup of countries forming an alliance (“sanctioning party”) to anothercountry, region, entity, vessel or an individual (“the sanctioned party”),that is intended to coerce certain behaviours on the part of, or toachieve a certain result with respect to, the sanctioned party.There are various types of sanctions: Diplomatic Military Sports Trade Economic/FinancialPAGE37ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Sanctions ComplianceEconomic/financial/trade sanctions aim to achieve domestic andforeign policy goals set by national governments and internationalbodies, including: Diminishing the power and influence of regimes considered to be asecurity threat or oppressive to their subjects Cutting off international criminals, such as narcotics traffickers andterrorists from the financial system Preventing the proliferation of weapons of mass destructionPAGE38ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Sanctions Compliance “Sanctioned Countries” refer to the countries which are subjected to acomprehensive sanction program by the sanctioning party. Comprehensivesanction generally prohibits all direct or indirect imports/exports, trade brokering,financing or facilitating against most goods, technology and services. Currently, the following are deemed to be Sanctioned Countries (in line withOCBC):- Cuba;- Crimea Region of Ukraine;- Iran;- Sudan;- Democratic People’s Republic of Korea(North Korea); and- Syria “Sanctioned Person” refers to an individual or entity which is being sanctionedby the sanctioning party, including the family members and close associates ofsuch individual or entity.PAGE39ANTI-MONEYLAUNDERING& COUNTERFINANCINGOFONLYTERRORISM (AML/CFT)FORINTERNALCIRCULATION& TRAININGPURPOSES

Sanctions ComplianceSanctioning Countries & BodiesApart from sanctions of United Nation Security Council (“UNSC”) which arerelating to terrorist financing and proliferation financing, sanctions from thefollowing countries and bodies shall also be observed and adhered to:1. Bank Negara Malaysia (BN

To create understanding of the AML/CFT framework that determines the AML/CFT policy and standards in the Company. To create an understanding on the impact of money laundering and terrorist financing to the Company. ANTI-MONEY LAUNDERING & COUNTER FINANCING OF TERRORISM (AML/CFT)

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