POLICY STATEMENT

AIIMAN and our group of companies (collectively known as “AHAM Capital Group” and referred to as “we”) are committed to implementing process and procedures to prevent our group of companies from being used as a money laundering and terrorism financing vehicle. This Anti-Money Laundering and Anti-Terrorism Financing (“AML”) Policy serves as a guide to all personnel, including our Senior Management and Board of Directors, vigilant in the fight against money laundering and terrorism financing.

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 with regards to anti-money laundering and anti-terrorism financing in Malaysia. As such, we have put in place process 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 AHAM Capital Group.

These process and procedures include:

CUSTOMER ACCEPTANCE

We practice 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. This helps us in assessing and mitigating these risks and is crucial in detecting and preventing our group of companies from being used for and/or involved in any ML/TF activities.

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 to ensure that a customer’s profile remains updated and relevant.

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.

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 the following lists:

1. Our internal watchlist in which we maintain a database of blacklisted individuals and corporate entities for detection of suspected persons; and
2. Politically Exposed Persons and entities/individuals who are sanctioned/suspected/convicted of offences.

TRANSACTIONS MONITORING AND DETECTION

We have put in place processes and systems designed to monitor customer transactions for the purpose of identifying suspicious activity. We review, from time to time, amongst others:

1. A comparison of the customer’s transactional activities and their investment objectives and their profile;
2. Whether the amount of money involved is consistent with the occupation and nature of business of the customer.

CASH AND THIRD-PARTY PAYMENTS

AIIMAN maintains a strict no cash payment and no third-party payment policy, where we only accept payments made for investments from our customer’s personal bank account. We also do not pay our customers in cash, and only directly to our customer’s personal bank account. AIIMAN reserve the right to seek out additional information/documents as we believe necessary in order to comply with this policy.

REPORTING

All employees and agents are required to report any unusual transactions to the AML Officer, and we will notify the authorities as soon as suspicious transactions are identified using a Suspicious Transaction Report (STR) to the Bank Negara Financial Intelligence and Enforcement Department.

TRAINING

We continuously provide our employees and agents with trainings to create awareness with regards to their AML/CTF responsibilities with special emphasis on those employees (e.g. front-line employees) who are exposed to higher risks of potential ML/TF. These trainings are conducted on a regular basis, to keep employees and agents informed of any new changes in legislation or guidelines issued by the regulatory bodies.