Pilot Train-The-Trainer (TTT) Programme: Anti-Money Laundering & Counter Financing Of Terrorism (AML/CFT) For Designated Non-Financial Businesses And Professions (DNFBPs)
  • Overview
  • Objectives & Outline
  • Methodology
  • Participant Profile
  • Trainer
  • Overview




    6, 7, 13 and 14 Dec 2021


    9:00 AM – 5:00 PM


    Meeting Room 1 & 2, Lanai Kijang,
    Bank Negara Malaysia,
    10, Perkarangan Tun Ismail, 50480 Kuala Lumpur
    This training programme for DNFBPs aims to provide hands-on knowledge and skills for TTT participants to understand and design their training programmes that complies with the requirements of AML/CFT law and regulations.

    The programme will equip TTT participants with thorough understanding of the AML/CFT compliance framework, impact of regulatory non-compliance, trends in Money Laundering, Terrorism Financing and Proliferation Financing (ML/TF/PF), sanctions and other requirements as prescribed in BNM’s Policy Document on AML/CFT and TFS for DNFBPs and NBFIs.

    This programme will also provide an intensive one-day ABS Hybrid Certified Instructor workshop using flipped based training. It is specifically designed to enable a fast-track for subject matter experts (SME) to enhance their skills in designing, delivering, and evaluating training for both virtual and in-person training. Participants will be able to gain the essential skills, best practices, practical tools, strategies, techniques and new virtual learning technology to make their training energetic, engaging and effective.



    / PAX

    *Subject to 6% Service Tax

  • Objectives & Outline
    By the end of the programme, TTT participants will be able to:-

    • Examine the latest updates on ML/TF/PF and the various methods used by criminals and its consequence
    • Apply RBA methodology to identify, assess ML/TF risks and recommend preventive and mitigation measures that commensurate with identified risk level
    • Explain the processes needed to perform an effective Customer Due Diligence, Enhanced Due Diligence and Ongoing Due Diligence (CDD/EDD/ODD) including sector specific implementation of the requirements.
    • Examine key reporting obligations for reporting institutions under the law (Part IV of AMLA 2001) and process of executing quality STR based on the principals of 5Ws &1H
    • Appraise the need to comply with international and domestic sanctions’ rules and regulations
    • Examine the impact of regulatory non-compliance on RIs
    • Understand the emerging typologies of ML/TF activities and sector specific vulnerabilities.
    • Design competency-based training for both virtual and in-person training using suitable delivery methods, effective presentation and facilitation skills.
    • Understand the importance and types of learner’s engagement.
    • Assess participants’ competency using suitable in-person and virtual assessment tools.
    • Familiarise with various online tools and training technology that can be used effectively for delivering blended, flipped and web-based learning.

    DAY 1

    Unit 1: Understanding money laundering (ML), terrorism financing (TF) and proliferation financing (PF)
    • Examine the methodology of ML/TF/PF
    • Differentiate between ML/TF/PF
    • Examine the impact of ML/TF/PF to the country and its economy

    Unit 2: International standards, frameworks and guidelines
    • Examine the role of international, regional and domestic bodies in preventing ML/TF/PF.
    • Sharing of the 2015 mutual evaluation outcomes and recommendations (IO4, IO10 & IO11 - gaps identified on DNFBPs)
    • Overview of National Risk Assessment (NRA) and what it means to RIs?
    • Policy, Circular and Guidance issued by the Competent Authority (applicability based on size of the firms)

    Unit 3: Importance of CDD (KYC), Mitigation and Control of High-Risk Customers
    • Section 16 of the AMLA -CDD, EDD, ODD
    • CDD measures for various types of customers: Individuals, Legal Persons (including GLCs, SOCs, Approved Person), Legal Arrangements and Clubs & Societies
    • Beneficial Ownership of Legal Persons
    • Assessing and validating high-risk customers
    • Mitigation of risk posed by politically exposed persons (PEP) and close associates
    • Onboarding of non-face to face customers
    • Record keeping and MIS

    Practice session : Role play on onboarding a high-risk customer.

    Unit 4: Sanctions and sanctions screening
    • FATF – Recommendations 6 and 7
    • United Nations Security Council Resolutions (UNSCRs)
    • Unilateral sanctions (e.g. OFAC and USA Patriot Act)
    • Strategic Trade Act 2010
    • Screening system and controls

    Who and what should be screened?

    DAY 2

    Unit 5: Risk Based Approach Implementation
    • Key elements and main coverage of RBA
    • When do you perform risk profiling?
    • Identify relevant risk factors for customer
    • Assign individual and corporate customer risk scores and creating risk status
    • Assess the overall customer risk for the company/firm
    • Identify risk factors for the RI
    • Assign RI risk scores and creating risk status
    • Assess the company wide ML/TF risks of the RI
    • ML/TF risk mitigation and control measures
    • Risk monitoring and review

    Practice session : Develop Customer Risk Profiling (CRP) and Institutional Risk Assessment (IRA) based on a case study.

    DAY 3

    Unit 6: Raising an effective Suspicious Transaction Report
    • Obligations from Sections 13 to 19 of AMLA 2001
    • Transaction Monitoring of respective sectors (trigger events)
    • Evaluate whether the case/subject matter has grounds for suspicion and applying the 5Ws & 1H principals in STR reporting
    • Examples of Quality vs Non-Quality STRs
    • Consequence of failure to report STR

    Practice session: Write-up on STR based on a given case study

    Unit 7: Responding to LEAs Orders and Impact of ML/TF/PF
    • Regulatory obligations – responding to LEA orders
    • Impact from high profile cases on Compliance functions – lessons learned

    Unit 8: Money Laundering and Terrorism Financing Typologies
    • Examine the typologies involving ML/TF within DNFBPs and the control measures
    • Evaluate the emerging ML/TF trends in other sectors and applicability to DNFBPs
    • The types and characteristics of businesses that are vulnerable to be used by criminals to launder illegitimate income

    DAY 4

    Unit 9: Designing & Develop Training Course
    • Adult learning theory & instruction design.
    • Develop session plan and contents according to training needs.
    • Practical application – Developing session plan.

    Unit 10: Facilitate Training Session
    • Conducive learning environment to achieve training objectives.
    • Presentation techniques.
    • Explore various blended learning tools.
    • Facilitating with digital technology.
    • Practical application – Using digital technology in hybrid training.

    Unit 11: Conduct Training Evaluation
    • Training Evaluation, feedback and assessment.
    • Incorporating digital technology into assessment process.
    • Practical application – Using digital technology in post training evaluation and feedback.

  • Methodology


    Lecture, case studies, discussion, quizzes, MCQs and practical application


    • 4-days classroom workshop
    • Assessment:

    • Post programme: 10 multiple-choice questions (MCQs) at the end of Day 1 to Day 3 (10 MCQs x 3 days = 30 MCQs).
    • Submission of TTT assessment portfolio

    • Training needs assessment
    • Training design & methodology
    • Training presentation (live or pre-recorded training: face to face or virtual)
    • Training evaluation

    Note: The self-paced assignment is to be completed and submitted within 4 weeks after completion of the TTT programme.

  • Participant Profile
    Nominated participants from Licensee Authorities (LAs) and Self-Regulatory Bodies (SRBs)
  • Trainer

    Day 1 Trainer

    Nurul Fitrah Md Nazri

    Nurul Fitrah is currently the Head of Compliance Academy & Policy at a leading Malaysian bank. Her previous roles include the Head of Compliance Department at Touch n Go Sdn Bhd and Group Compliance of the CIMB Group AML Remediation Department.

    She started her legal career with the International Affairs Division, Attorney General’s Chambers and has participated in international treaties negotiation as well as drafted several legislations relating to transnational organised crime. Later, she joined the FIED, BNM as AML/CFT policy analyst with primary role in sanctions policies and subject matter expert for terrorism financing. She was part of the team that drafted the AML/CFT Sector 1 policy and amendments to AMLATFPUA Act 2001. Besides that, she was also one of the resident speakers for BNM on AML/CFT.

    Nurul Fitrah obtained her law degree from the International Islamic University and has extensive working experience in the legal and regulatory field.

    Day 2 Trainer

    Lim Poh Hong

    Lim Poh Hong is Head of Compliance at one of the leading remittance companies with global presence in Malaysia. Prior to joining the Money Services Business (MSB) industry, she was a finance lecturer with several universities for more than 10 years.

    She was a former President of the Group of Compliance Officers (GOCO) for the MSB industry and one of its pioneer committee members. Poh Hong was invited to share her experience in implementing RBA as a panel speaker at the National Compliance Conference in December 2018. Presently, she is an examination committee member for the Certified AML/CFT Compliance Officer (CAMCO) Programme jointly offered by the Asian Institute of Chartered Bankers and the Asian Banking School. She is also an industry panel expert for the Malaysia National Occupational Skills Standards (NOSS).

    Poh Hong has an MBA (Finance) and a Bachelor of Science (Agribusiness) from Universiti Putra Malaysia (UPM), is a Certified AML Specialist from ACAMS (US) and is also a Certified Training Professional from the Finance Accreditation Agency (FAA).

    Day 3 Trainer


    Yunos Yusop is currently the Money Laundering Compliance Officer and Group Head of AML/CFT Compliance at a Malaysian bank. He has had over 20 years of experience in the financial industry, which includes working on Risk Management projects with Bankers Trust of London (BT), Arthur Anderson, AT Kearny and other major consultation firms. He has also gained extensive experience managing and combating internal and external fraud while working with a Retired Deputy Director of CID of the Royal Malaysian Police. His experience include setting-up the Group AML/CFT office for a leading universal banking group, served at the Fraud Intelligence Department & Forensic Services and a Head of Compliance and Head of AML/CFT for a foreign bank in Malaysia.

    Yunos holds a B. Economic (Hons), B. Jurisprudence (Law), an MBA (Finance) from Ecole Superieure de Gestion, Paris. He also holds a Certificate in Internal Auditing for Financial Institutions (CIAFIN) as well as an Advanced Certification in AML/CFT, specialist certificate in Money Laundering Risk in Correspondent Banking and Managing Sanctions Risk and Certified Professional AML/CFT (Manchester).

    Yunos is a Member of the International Compliance Association, Associate Member of Asian Institute of Chartered Bankers (AICB) and Associate Member of the Malaysian Association Certified Fraud Examiners. He is also a Certified Professional Trainer (Malaysian Institute of Management) and a Certified TTT trainer by HRDF Malaysia. He is a Research Fellow of the Institute of Crime and Criminology, HELP University and moderates AML/CFT Module in MSc in Economic Crime Management. He also served as a Deputy Chairman to the Compliance Officers Networking Group (CONG) in 2017, Director of Training for Malaysian Association Certified Fraud Examiners (MACFE) and EXCO Member for Transparency International Malaysia.

    Day 4 Trainer

    Dr Vijayan Paramsothy

    Dr Vijay is the Director of Graduate Training & FSTEP, and Senior Consultant at the Asian Banking School. He started his career working in one of the big 8 Chartered Accountants and Management Consultancy firms in the UK. He has over 20 years of banking experience working in local and foreign banks up to a senior management level, ranging over a diverse range of disciplines.

    He is currently involved in structuring bespoke technical and soft skill programmes for banks. In addition, he is involved in the curriculum working committee for professional qualification programmes such as the Chartered Banker and Bank Risk Management. He is also a designated Chartered Banker trainer, bringing a fresh approach to self-directed learning using mind-mapping techniques, case studies and problem-based learning. Dr Vijay has published banking and finance related textbooks and journal articles internationally, including, “Success Factors for the Implementation of Entrepreneurial Knowledge Management in Malaysian Banks” (Journal of Information & Knowledge Management, 2013).

    Dr Vijay holds an Honours Degree in Accounting and Finance from Scotland, a Master of Science Degree in Multimedia Technology (Banking), a Doctor of Business Administration (Banking Strategy and Marketing) from Australia, and a Doctor of Philosophy (Knowledge Management in Banking) from Malaysia. He is also a Certified Training Professional (ARTDO), a Certified TTT trainer (HRDF) and he is also a member of the Cambridge Judge Business School Executive Education alumni.

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