Compliance

1. Summary

ALT Asset Management Sdn. Bhd., a licensed fund management company regulated by the Securities Commission Malaysia, is steadfast in its commitment to combat the scourge of money laundering and terrorist financing, both of which are criminal acts that inflict untold harm on society.

We recognize that Malaysia has implemented comprehensive Anti-Money Laundering (AML) and Counter Terrorism Financing (CFT) legislation that imposes stringent obligations on financial service providers to prevent these criminal activities. ALT Asset Management remains committed to adhering to the highest standards of regulatory compliance and industry best practices.

Our risk-based approach to the assessment and management of money laundering and terrorist financing risks, as well as our Customer Due Diligence (CDD) procedures, are designed to meet international standards. Our investors are required to provide certain personal details and documents when opening an account with us. We perform enhanced due diligence procedures for investors presenting a higher risk, such as those transacting large volumes and Politically Exposed Persons (PEPs).

We have established risk-based systems and procedures for monitoring ongoing customer activity and reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate. We maintain appropriate KYC records for the minimum prescribed periods, provide training on the framework, and raise awareness among all relevant employees.

We are guided by the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLATFPUAA), along with any relevant laws, regulations and guidelines. As such, we have put in place processes and procedures to:

1. Guard against, detect, and report any incidents of money laundering and financing of terrorism to Bank Negara Malaysia;
2. Mitigate and manage actual and/or potential exposure to financial crime and breaches of legislation or regulation;
3. Ensure that there are robust procedures and controls in place; and
4. Protect the assets and reputation of ALT Asset Management.

2. Customer Acceptance

We practise a risk-based approach in assessing our potential and existing customers in order to rate and group them according to the risk of money laundering and terrorism financing (ML/TF) associated with them due to or arising from their origins and location of business, their background and profile, their nature of business, and their structure of ownership.

Customer Due Diligence ("CDD") is conducted on all potential and new customers, as well as Enhanced Due Diligence ("EDD") to customers assessed as higher risk. Periodic reviews for all our existing customers are performed.

We will not commence any business relation, or execute any transaction, and may terminate business relationships if a customer fails to comply with our CDD requirements.

3. Screening of Customers

Screening for listed names is an integral part of our CDD process and we conduct screening on all our new and existing customers against:

1. Our internal watchlist of blacklisted individuals and corporate entities;
2. Politically Exposed Persons and entities/individuals who are sanctioned/suspected/convicted of offences.

4. Transactions Monitoring and Detection

We have put in place processes and systems to monitor customer transactions for identifying suspicious activity, including:

1. Comparison of transactional activities against investment objectives and profile;
2. Whether transaction amounts are consistent with occupation and nature of business.

5. Cash and Third-Party Payments

ALT Asset Management maintains a strict no cash payment and no third-party payment policy. We only accept payments from customer's personal bank account and only pay directly to customer's personal bank account.

6. Reporting

All employees and agents are required to report unusual transactions to the Compliance Officer. We notify authorities via Suspicious Transaction Report (STR) to the Bank Negara Financial Intelligence and Enforcement Department.

7. Training

We continuously provide employees and agents with AML/CTF training, with emphasis on front-line employees exposed to higher risks.