training material pep year 1 - m2 (emodule)
DESCRIPTION
year 1TRANSCRIPT
PEP Year 1 – M2 (eModule)
1
1
Part 2: PEP Year 1 M2 (eModule)
PEP Year 1 – M2 (eModule)
2
2
The eModule will cover the following topic
Topic 1: Anti Money Laundering/ Counter Financing
of Terrorism
Topic 2: Code of Ethics and conduct
Topic 3: Replacement of Policies
Topic 4: Fraud Awareness and Agency Conduct
PEP Year 1 – M2 (eModule)
3
3
After completing this module, participants will be able:
• To identify and list the importance of anti-money laundering (AML) and counter financing of terrorism (CFT), code of ethics and conduct (COE) , replacement of policies (ROP) and Fraud Awareness and agency conduct.
• To observe and follow the guidelines of AML/CFT, COE, ROP and Fraud Awareness and agency conduct.
• To appreciate the existence of AML/CFT, COE, ROP and Fraud Awareness and agency conduct in upholding the professionalism of Life Planning Advisor.
PEP Year 1 – M2 (eModule)
4
4
AML/CFT Reading Material
Disclaimer
“This power-point presentation is purely a training tool for the internal agency training programmes of Great Eastern Life Assurance (Malaysia) Berhad. All or any part of the contents of this presentation shall not be used directly or indirectly for soliciting insurance business, policyholder services and/or facilitating any other form of communications with any external party whatsoever. This information is correct as at 29112010”
Topic 1:
PEP Year 1 – M2 (eModule)
5
Understanding Anti Money Laundering
(AMLA)
PEP Year 1 – M2 (eModule)
6
To create awareness amongst agents on anti-money
laundering (AML) and counter financing of terrorism (CFT) and
appreciate its importance
To understand the relevant regulations and laws governing
AML & CFT
COURSE OBJECTIVESCOURSE OBJECTIVES
PEP Year 1 – M2 (eModule)
7
1. Definition
2. BNM Guidelines & Governing Regulations
3. AML/CFT Framework
4. Reporting Structure
5. Suspicious Cases - Modus Operandi
6. Other Developments On AML
7. Q&A
TODAYTODAY’’S OVERVIEWS OVERVIEW
PEP Year 1 – M2 (eModule)
8
MONEY LAUNDERING DEFINED UNDER AMLA
Money laundering is the act of a person who:
a. Engages, directly or indirectly, in a transaction that involvesproceeds from any unlawful activity.
b. Acquires, receives, possesses, disguises, transfers, converts, exchanges, carries, disposes, uses, removes from or brings into Malaysia proceeds of any unlawful activity.
b. Conceals, disguises or impedes the establishment of the true nature, origin, location, movement, disposition, title of, rights with respect to, or ownership of, proceeds of any unlawful activity.
PEP Year 1 – M2 (eModule)
9
WHAT IS MONEY LAUNDERING
Money laundering is the “whitewashing” of proceeds derived from illegal/unlawful activities or the processing of criminal proceeds to disguise their illegal origin.
This process enables the criminals to enjoy these profits without jeopardizing their source.
Vigilant – not expected to be
“willfully blind”
PEP Year 1 – M2 (eModule)
10
WHAT IS SERIOUS OFFENCE
Serious offence = unlawful activity = illegal activity = predicate offence.
Define as activity which is related, directly or indirectly to� Offense specify in the 2nd Schedule of AMLA 2001, or� An attempt to commit any of those offences, or� Abetment of any of those offences.
Cover serious offences committed in Malaysia and offence committed in a foreign country which would also constitute a serious offence in Malaysia.
Currently there are 248 serious offences as set out in the 2nd schedule of AMLA.
PEP Year 1 – M2 (eModule)
11
WHAT IS SERIOUS OFFENCE2nd Schedule of AMLA = An excerpt of offences from 36 Legislations:
1) Anti-Corruption Act,
2) BAFIA Act,
3) Betting Act,
4) Child Act,
5) Common Gaming House Act,
6) Companies Act,
7) Copyright Act,
8) Corrosive & Explosive Substances &
Offence Weapons Act,
9) Customs Act,
10) Dangerous Drugs Act,
11) Dangerous Drugs (Forfeiture of
Property) Act,
12) Development Financial Institutions
Act,
13) Explosive Act,
14) Firearms Act,
15) Futures Industry Act,
16) Insurance Act,
17) Internal Security Act,
18) Kidnapping Act,
19) Money Changing Act,
20) Optical Disc Act,
21) Penal Code,
22) Security Industry Act,
23) Takaful Act.
24) Labuan Offshore Securities Industry Act
25) Labuan Trust Companies Act
26) Islamic Banking Act
27) Offshore Banking Act
28) Payment Systems Act
29) Securities Commission Act
30) Offshore Insurance Act
31) Anti-Money Laundering Act
32) Trade Description Act
33) Malaysian Timber Industry Board
(Incorporation) Act
34) Moneylenders Act
35) Pawnbrokers Act
36) Income Tax Act 1976 (Act 53)
PEP Year 1 – M2 (eModule)
12
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/ money-broking, insurance, insurance broking, adjusting business, Takaful business without valid license.
WHAT IS SERIOUS OFFENCE
PEP Year 1 – M2 (eModule)
13
WHAT IS SERIOUS OFFENCE
Whilst you are not required to have extensive knowledge of serious offences listed in the 2nd schedule, you are required to have the knowledge that a reasonable person in your position would have about such offences.
You are expected to recognize the major offences that are likely to generate illegal proceeds, such as drug trafficking, theft, corruption etc.
However you are not expected to be sure that a serious offence has been committed or whether or not something is actually an unlawful activity for the purpose of AMLA.
It is sufficient that you suspect.
PEP Year 1 – M2 (eModule)
14
MONEY LAUNDERERS
Typical Characteristics - Money Launderers are:
* Focused on Intent
* Innovative
* Rich
* Prepared to lose some money
PEP Year 1 – M2 (eModule)
15
MONEY LAUNDERING PROCESS
Placement – the physical disposal of the initial proceeds, eg: Smuggle over borders, depositing into many bank accounts, payment of premiums (generous policies for self or related parties), purchasing of hefty investment linked policies or top ups for single premium policies
Layering (whitewashing) – series of conversions or creating complex layer to distant from the source to disguise the audit trial and provide anonymity, eg: borrowing against insurance policies, premature termination of policies and liquidating investment linked policies
Integration – returning the criminally derived wealth into legitimate funds, eg: funds reinvested into assets, real estate, stocks, business ventures
PEP Year 1 – M2 (eModule)
16
HOW IS MONEY
LAUNDERED?
�� LAYERINGLAYERING
Conversion / movements to separate the illicit proceeds from thConversion / movements to separate the illicit proceeds from their sourceeir source
* To disguise audit trail* To disguise audit trail
* Provide an appearance of legitimacy* Provide an appearance of legitimacy
* Provide anonymity* Provide anonymity
�� PLACEMENT PLACEMENT
Introducing illegal profits into the Introducing illegal profits into the financial systemfinancial system
�� INTERGATION INTERGATION
After the Layering process, the After the Layering process, the
money are then reintroduced into the money are then reintroduced into the
financial / business system financial / business system -- for for
example: investments in business, example: investments in business,
purchase of assetspurchase of assets
PEP Year 1 – M2 (eModule)
17
DEFINITION OF FINANCING OF TERRORISM
Financing of terrorism generally refers to carrying out of transaction involving funds that may or may not be owned by terrorists, or have been or intended to be used to assist the commission of terrorism
Financing of terrorism includes:
1) providing or collecting of property for carrying out an act of terrorism
2) providing services for terrorism purposes
3) arranging for retention or control of terrorist property or� dealing with terrorist property
In the financing of terrorism, the focus is on the determination or use of funds, which may have been derived from legitimate sources
PEP Year 1 – M2 (eModule)
18
GOVERNING GUIDELINES
� Purpose : To ensure that insurance industry is not a weak linkin money laundering.
� Current Governing Guidelines on AML for insurance industry includes :
1) The Anti-Money Laundering Act (AMLA) 2001 - effective on January 15, 2002.
2) UPW/GP1 : Standard Guidelines on Anti Money Laundering and Counter Financing of Terrorism (AML/CFT) dated 3 November 2006 UPW/GP1[2] amended February 2009
3) UPW/GP1 [2]: Sectoral Guidelines 2 for Insurance and Takaful Industries dated 3 November 2006 amended February 2009
� Note: UPW/GP1 & UPW/GP1[2] – Issued in accordance with the AMLA 2001 and FATF’s 40 Recommendations & 9 Special Recommendations for Implementation wef 15/11/06
PEP Year 1 – M2 (eModule)
19
GOVERNING GUIDELINES
� Previous Guidelines On AML By BNM Which Had Been Superceded By The Issuance Of The Standard & Sectoral Guidelines:
1) Guidelines on Anti-Money Laundering Measures for the Insurance Industry JPI/GPI 27 - issued on April 25, 2001
2) JPI 20/2004 – AMLA 2001 Verification Procedures – issued on August 21, 2004
� BNM is the Competent Authority appointed for the purpose of AMLA 2001 and Great Eastern is a Reporting Institution
� BNM established the National Co-ordination Committee - comprising of 12 other government agencies - to combat money laundering. They include the MACC, Inland Revenue Board, AG’s Chambers, Royal Malaysian Police, Security Commissions, SSM, LOFSA, Anti Narcotics , Ministry Of Finance, Ministry Of Foreign Affairs, Ministry of Home Affairs and Royal Malaysian Customs
PEP Year 1 – M2 (eModule)
20
Reporting Institutions (RI) – 1st Schedule of AMLA
� Banks & FI, � Insurance, Financial Advisers� Takaful, � Islamic Banking, � Securities Industries, � Money Changers, � Offshore Financial Services� Offshore Securities Industries� Genting Casino� Licensed Gaming Outlets/Pool
Betting� Accountants� Lawyers� Company Secretaries� Notaries Public� Bank Pertanian Malaysia Berhad� Moneylender� Pawnbroker� Real Estate Agents, Valuers
� Racing Clubs/ Totalizators Agency� Trust Companies� Non-Bank Remittance Operators� Non-Bank Affiliated Issuers of
Designated Payment Instruments� Unit Trust Management Companies� Fund Management And Future Fund
Managers� Malaysia Buiding Society Berhad� Moneylenders in East Malaysia� Sabah Credit Corporation� Borneo Housing Mortgage Finance
Berhad� Leasing & Factoring Businesses� Eletronic Money Issuers� SME Bank� Dealers In Precious Metals/ Precious
Stones� Lembaga Tabung Haji
PEP Year 1 – M2 (eModule)
21
PROVISIONS IN AMLA 2001
OFFENCE OF MONEY LAUNDERING
Section 4
States that any person who engages in or attempts to engage in, or abets the commission of money laundering, commits an offence and shall on conviction be liable to a fine not exceeding RM5 million or imprisonment for a term not exceeding 5 years or both.
PEP Year 1 – M2 (eModule)
22
PROVISIONS IN AMLA 2001
OFFENCE OF MONEY LAUNDERING
Section 20 – Secrecy Obligation
The provision overrides any obligation as to secrecy or other restriction on the disclosure of information imposed by any written law or otherwise.
Section 24 – Protection Of Person Reporting
No civil, criminal or disciplinary proceedings shall be brought against a person who discloses or supplies any information unless it is done in bad faith.
PEP Year 1 – M2 (eModule)
23
POWER TO SEIZE OF
PROPERTY, RECORD OR DOCUMENT
Section 38
An investigation officer may seize, take possession of and retain for such duration as he deems necessary, any property, record, report or document produced before him in the course of an examination.
PEP Year 1 – M2 (eModule)
24
TIPPING OFFSection 35
a. Any person who knows or has reason to suspect that an investigating officer is acting or proposing to act, in connection with an investigation which is being, or is about to be, conducted under or for the purposes of this Act or any subsidiary legislation made under it and discloses to any other person information of any other matter which is likely to prejudice that investigation or proposed investigation; or
b. Any person who knows or has reason to suspect that a disclosure has been made to an investigation officer under this Act and discloses to any other person information or any other matter which is likely to prejudice any investigation which might be conducted following the disclosure.
Upon conviction, a person shall be liable to a fine not exceeding RM 1 million or to imprisonment not exceeding one year or both.
PEP Year 1 – M2 (eModule)
25
FAILURE TO DELIVER
PROPERTY, RECORD, REPORT OR DOCUMENT
Section 37 (3)
A person who fails to deliver any property, record, report or document that is required by an investigating officer while exercising any of his powers under subsection 1 commits an offence and shall on conviction be liable to a fine not exceeding RM1 million or imprisonment for a term not exceeding 1 year or both and in he case of continuing offence, to a further fine but not exceeding RM1K for each day during which the offence continues after conviction.
Section 41- Arrest
Investigating officer may arrest without warrant a person whom he reasonably suspects to have committed or to be committing any offence under this Act.
PEP Year 1 – M2 (eModule)
26
KEY PROVISIONS FOR
OFFENCES & PENALTY OF MONEY LAUNDERING
Section 22
Officer of a Reporting Institution shall take all reasonable steps to ensure compliance with AMLA. Fine ranges from ≤ RM100,000 or Jail term that ranges from ≤ 6 months or both for failure to comply with S22.
Section 86
If no penalty is expressly provided for the offence under AMLA, Fine ≤ RM250,000
Section 92
Further empowers BNM to compound in cases of continuing offence Compound ≤ 50% of the maximum fine amount
PEP Year 1 – M2 (eModule)
27
BNM’s GUIDELINES
Minimum training requirement of Key Staff include :
� New employees
� Frontline staff (including agents)
� Administrative/operations supervisors, managers (including senior management) and Board of Directors
� Compliance officers
PEP Year 1 – M2 (eModule)
28
AML FRAMEWORK
AS REQUIRED IN UPW/GP1 AND UPW/GP1[2]
� Customer Acceptance Policy
� Customer Due Diligence
� Record Keeping
� On-Going Monitoring
� Suspicious Transaction Reporting
� Combating The Financing Of Terrorism
PEP Year 1 – M2 (eModule)
29
CUSTOMER ACCEPTANCE POLICY
Reporting Institution to develop policy and procedures to address the establishment of business relationship with the customer.
Internal policies and procedures, including customer due diligence, to address different risks posed by each type of customer.
Risk profiling - factors to consider:� the origin of the customers and location of business� background or profile of the customer� nature of the customer’s business� structure of ownership for a corporate customer� any other information suggesting that the customer is of higher risk
Continuously monitor the customers’ transaction activity pattern to ensure it is in line with the customer profile
PEP Year 1 – M2 (eModule)
30
CUSTOMER DUE DILIGENCE
– IDENTIFICATION & VERIFICATION
Know Your Customer (KYC) PolicyDetermination true identity of prospect, to verify and be satisfied that : � Identity of customer is genuine � Insurance transaction to be undertaken is legitimate
Conduct Customer Due Diligence (CDD) When:Establishing a business relationship with the customer� Suspicion of money laundering or financing of terrorism� There are doubts about the reliability or adequacy of previously obtained
information
Unwillingness of customer to cooperate may itself be a factor of suspicion.
Great Eastern’s PolicyThe Company shall not underwrite unless sufficient identification evidence is provided.
PEP Year 1 – M2 (eModule)
31
Generally verification should be performed at the point of sale and via face-to-face contact.
However the verification may be done at or before the time of benefits are paid out if the followings are met :
� Policies sold with premium not exceeding RM5k or RM10k for single premium (in aggregate per annum) - also applicable for policies sold via direct marketing, internet, call centre, direct mailing etc (non-face-to-face).
� Verification of Beneficiary.� Verification of individual members covered under group policies. (verification of the
group policy owner should be done at the point of sale).
Apart from the above, in certain special circumstances where the risks of money
laundering and financing of terrorism are low, delay verification is allowed whereby
CDD needs to be completed not later than 14 days after the business relationship has
been established. (Currently, only group insurance business has such practice of
delayed verification, not applicable to individual business)
CUSTOMER DUE DILIGENCE
– IDENTIFICATION & VERIFICATION
PEP Year 1 – M2 (eModule)
32
INDIVIDUAL CUSTOMERSObtain at least the following information:� Full name� NRIC/passport number� Permanent and mailing address
Substantiate by/ Verify Against :� NRIC for Malaysians/permanent residents� Passport for foreigners� Where there is doubt, produce other supporting identification documents
(with photograph) issued by an official authority
A copy of the verified documents should be retained by the insurer for insurance policy with premium> RM50k p.a. (Currently being reviewed to comply with Group AML Policy – retain all verified documents regardless of amount)
� Date and place of birth� Nationality
CUSTOMER DUE DILIGENCE
– IDENTIFICATION & VERIFICATION
PEP Year 1 – M2 (eModule)
33
CORPORATE CUSTOMERSUnderstand the ownership and control structure in order to detect any unusual
circumstances concerning the changes to the company/business structure or ownership
or the payment profile of its account
Furnish the following documents:� Memorandum/Article/Certificate of Incorporation/Partnership (certified true copies/duly
notarised copies, may be accepted)
� Identification document of Directors/Shareholders/Partners (certified true copies/duly notarised copies, may be accepted)
� Board of Directors’/Directors’ Resolution� Authorisation for any person to represent the company/business� Identification document of authorised person
However, item (1) & (2) are not required if the corporate customer is PLC, GLC, State-
owned companies or financial institutions under BAFIA, IA, TA, LOFSA and DFIA
Where there is doubt: � Conduct a basic search or enquiry on the background.� Verify with the Companies Commission of Malaysia.A copy of the verified documents should be retained by the insurer for insurance policy with premium> RM100k p.a. for group policy premium> RM50k p.a for individual policy (e.g. key man)
CUSTOMER DUE DILIGENCE
– IDENTIFICATION & VERIFICATION
Group AML Policy – retain all
verified documents
PEP Year 1 – M2 (eModule)
34
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
LEGAL ARRANGEMENTTake reasonable measures to:� Understand the relationship among the relevant parties � Obtain satisfactory evidence of its legal status the identity of the
relevant parties Require a written undertaking from the trustees or
nominee that identification documents of the beneficiaries have
been retained and be made available upon request
� The nature of their capacity and duties as trustee or nominee (in GELM, we generally do not deal with Power of Attorney)
CUSTOMER DUE DILIGENCE
– IDENTIFICATION & VERIFICATION
PEP Year 1 – M2 (eModule)
35
BENEFICIAL OWNERSHIP AND CONTROL� Conduct customer due diligence on the person who ultimately owns or
controls the customer’s transaction (individual or corporate customer) if there is any suspicions that the transaction is conducted on someone’s behalf.
CUSTOMER DUE DILIGENCE
– IDENTIFICATION & VERIFICATION
PEP Year 1 – M2 (eModule)
36
POLITICALLY EXPOSED PERSON (PEP)
� PEPs are foreign / domestic individuals being, or who have been, entrusted with prominent public functions. E.g. heads of state or government, senior politicians, senior government officials, 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 their public powers for their own illicit enrichment, especially in countries where corruption is widespread
� Agents are to inform/ disclose to the Company if the current or new customers are PEPs or related to PEPs in the proposal form/agent’s confidential report
� Company is required to take appropriate measures to establish the source of wealth and funds of such person
� Approval from SMT is required for case acceptance
CUSTOMER DUE DILIGENCE
– IDENTIFICATION & VERIFICATION
PEP Year 1 – M2 (eModule)
37
HIGHER RISK CUSTOMERSCompany is required to conduct enhance due diligence when dealings with higher risk customers.� Enhanced due diligence includes at least:
� Obtained more detailed information from customer and publicly available information on the purpose of transaction and source of funds.
� Approval from Head of NB is required for case acceptance.Example of Higher Risk Customers� High net worth individuals� Non-Resident customers, PEP� Customers from locations known for high rates of crime (e.g. drug producing,
trafficking, smuggling)� Countries/Jurisdictions with inadequate AML/CFT laws and regulations as
highlighted by FATF (e.g. NCCT countries).� Businesses/activities identified by FATF as of higher risk, e.g. remittance houses,
currency exchange houses, money transfer agents, casinos, Non-Profit
Organisations, precious metal/stone dealer, etc
� Cash based business and unregulated industries.� Legal arrangements that are complex (e.g. trust, nominee)
CUSTOMER DUE DILIGENCE
– IDENTIFICATION & VERIFICATION
PEP Year 1 – M2 (eModule)
38
RECORD KEEPING (Section 13 & 17)
� Records should be kept for a period of NOT LESS THAN 6 years from the date an account has been closed or transaction has been completed or terminated.
� Failing to comply, a fine not exceeding RM 1.0 mil or 1 year’s imprisonment would be imposed.
� Agents are encouraged to inform the Company to update the customer’s records when there are changes in their employment or nature of business.
PEP Year 1 – M2 (eModule)
39
RECOGNISING & REPORTING
SUSPICIOUS TRANSACTIONS (Section 14 AMLA)
What is Suspicion?
� Subjective and there is no specific provision or definition in AMLA
� Mere speculation but falls short of actual proof or knowledge
� Built on some factual or objective foundation with a degree of satisfaction of suspicion, even if does not amount to belief
� Inconsistent with a customer’s known, legitimate business or personal activities or with the normal business for that type of customer
� The first key to recognition is knowing enough about the customer and his business/profession to recognize that a transaction or series of transaction is unusual
� With effect from 9/3/2007, Reporting Institutions is also required to report any ATTEMPTED transaction(s) that are suspicious (apart from reporting the completed transaction(s) that are suspicious)
PEP Year 1 – M2 (eModule)
40
EXAMPLES OF SUSPICIOUS TRANSACTIONS
Suspicious Transaction? What to Look Out For……………..
Transactions That Do Not Make Economic SenseTransactions in which the nature, size or frequency appears
unusual.
Transactions which are incompatible with the customer’s normal activity
or beyond the customer’s financial means.
Transactions Involving Unusual receipts or payment of fundsTransactions whereby large or unusual premium payment in cash is
received from customer.
Transactions which funds are paid or received through unrelated third
party.
PEP Year 1 – M2 (eModule)
41
Suspicious Transaction? What to Look Out For……………..
Free Look Provision & OthersFree look provision (15 days) of policy offers a readily available
route for laundering money
Use of Address – Using agent’s address instead of Customer’s own
address
Abnormal patterns of top-ups and withdrawals for investment linked
policies
EXAMPLES OF SUSPICIOUS TRANSACTIONS
PEP Year 1 – M2 (eModule)
42
COMBATING THE FINANCING OF TERRORISM
Maintain a database of names and particulars of terrorist in the UN Consolidated List and Gazette Orders issued under section 66C of the AMLA.
Information contained in the database are to be updated and relevant, and made easily accessible to its employees.
Regularly checks on the names of new and existing customers against the names in the database.
If there is a match, take reasonable and appropriate measures to verify and confirm the identity of its customer.
Upon confirmation, immediately inform Bank Negara Malaysia and other relevant authorities and freeze or reject the customer’s transaction.
Part IVA – Suppression Of Terrorism Financing Offences And Freezing, Seizure & Forfeiture of Terrorist Property – Gazetted On 9/3/2007
PEP Year 1 – M2 (eModule)
43
Freezing of Property Or Entities Listed On The UN Consolidated List
AGENCIES
7. Check 8. Match? 9. Inform (RSA)
9. No further
action
Regulatory &
Supervisory
Authority (RSA)
6. Circulate
Order
13. Unfreeze
Funds
10. RSA To
Verify Identity
* BNM
* Securities
Commission
12. Notify RI To
Unfreese
Immediately
11. Correct ?
13. Inform MOIS
(Name &
Amount)
12. Account
Remains
Frozen
Ministry Of
Internal Security
(MOIS)
4. Issue
Order
5. Forward
Order
14. Take Note
& Forward To
MOFA
Ministry Of
Foreign Affairs
(MOFA)
2. Received
List
3. Circulate
List
15. MOFA To
Forward
Details To UN
United Nation
Security Council
(UNSC)
1. Circulate
List
WORKFLOW
------------------------------------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------------------------------------
Relevant
Reporting
Institutions (RI)
* Labuan
Offshore
Financial
Services
Authority
Yes
Yes
No
No
PEP Year 1 – M2 (eModule)
44
Anti-money laundering mechanism has extended to include :
� Reporting of suspected terrorism financing activities.
� Measures for the detection and prevention of terrorism financing.
� Freeze, seize and forfeiture of terrorist property.
LEGAL PROVISIONS TO ADDRESS
TERRORISM FINANCING OFFENCE
PEP Year 1 – M2 (eModule)
45
AMLA INITIATIVES IN GREAT EASTERN
11 June 2002 BOD approved and adopted:
� AML Framework
� Corporate Statement
� Appointment of Compliance Officer
� Setting up of AML Committee and
� Reporting structure of Suspicious Transaction
PEP Year 1 – M2 (eModule)
46
YOUR RESPONSIBILITY
All Agents, department officers and staff, in particular, the front line staff, should be alert and note any unusual proposal/transaction that is inconsistent with the client’s financial flow or transaction pattern.
PEP Year 1 – M2 (eModule)
47
REPORTING SUSPICIOUS TRANSACTION TO
COMPLIANCE SECRETARIAT
BANK NEGARA MALAYSIA
Financial Intelligence Unit (FIU)
COMPLIANCE SECRETARIAT
KEY OPERATING DEPTS,
AGENTS & OTHER INTERMEDIARIES
Head Office or Branch Offices
via AML Form
Sent to:
Email : [email protected]
Fax: 03-4813 3798
Mail: Compliance Department, Level 7, Menara Great Eastern, No. 303, JalanAmpang, 50450 KL.
PEP Year 1 – M2 (eModule)
48
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 3rdparty (seemingly related) for Investment
Linked top-up and subsequently early cancellation/withdrawal.
� Series of application of policy loans and repayments within a short time period.
� Unrealistic wealth compare with customer’s financial profile.
� Staggered policies surrender (with small amount of surrender value per policy, cumulatively, the surrender amount are huge) within several months, with reason not satisfied with agent's services, which could have been done in one occasion.
� Large sum of cash premium payment.
PEP Year 1 – M2 (eModule)
49
PROSECUTED MONEY LAUNDERING CASES IN MALAYSIA
AMLA cases in Malaysia as at 25/6/08 (Source: BNM):
� 35 individuals has been brought to court for 876 charges under AMLA.
� 5 offenders were slapped with order for forfeiture of property without prosecution under Section 56(1) & Section 61 (2) of the AMLA.
Concluded cases as at 25/6/08 (Source: BNM):
� In 2005, a snatch thief pleaded guilty to 5 counts of money laundering charges. Sentenced to 3 years jail on each of the charges.
� In Jan 2007, a bank officer was convicted for CBT, forgery and money laundering. Sentenced to 13 years jail and fined RM19.3 million.
� In Aug 2007, an illegal bookies convicted of money laundering. Sentenced to 2 years jail and fined RM1 million.
� In Jan 2008, a politician was acquitted of 2 counts of money laundering charges against him for receiving proceed earned through illegal activities.
� In May 2008, an bank executive was found guilty of CBT, forgery and money laundering. Sentenced to to 11 years 6 months jail for money laundering, 15 years for CBT and 4 years 9 months for forgery and fined RM939,255.21.
PEP Year 1 – M2 (eModule)
50
Recent Court Cases Reported In The Media:
� On 10/6/2008, a businessman was hauled to the Sessions Court to face 20 charges of money-laundering involving a total of RM1.69 million & 2 charges for violating the Banking and Financial Institutions Act 1989 (BAFIA) - accepting a deposit without license.
He was alleged to have:� transferred RM876,389.91 into his savings account at 3 different banks on 5
occasions; � spent RM200,000 to purchase shares on 2 days; � spent RM500,000 to purchase 2 life investment insurance policies; and � paid RM114,138.76 to settle a car loan for a Mercedes Benz.
� On 26/6//2008, a couple was charged at the Sessions Court to face 189 charges of money-laundering involving a total of RM170 million & 2 charges for violating the Banking and Financial Institutions Act 1989 (BAFIA) - accepting a deposit (RM222 million) without license.
They were alleged to have used the money gained from illegal means to purchase several houses, shop lots, a factory lot, vehicles, including luxury cars and getting exclusive distributorship rights for hydrogen fuel.
PROSECUTED MONEY LAUNDERING CASES IN MALAYSIA
PEP Year 1 – M2 (eModule)
51
Recent Court Cases Reported In The Media:
� On 12/8/2008, a company director was charged in the sessions court for 296 charges of money-laundering involving a total of RM57 million.
His co-partner was earlier charged on 23/6/08 for 94 counts of money-laundering involving a total of RM23.3 million. 3 days later, he was being charged a further 296 charges of money laundering in the same sessions court.
They were charged with transferring the proceeds of unlawful activities ranging between RM897 and RM2 million on each occasion from the company's bank accounts to those of security firms, companies and banks.
Both of them also claimed trial for violating the Banking and Financial Institutions Act 1989 (BAFIA) – illegal deposit taking of more than RM10 million.
PROSECUTED MONEY LAUNDERING CASES IN MALAYSIA
PEP Year 1 – M2 (eModule)
52
�Structuring life insurance transactions to launder proceeds of
corruption (Indonesia)
Insurance Company
Mrs. A’s Saving A/Cs
BBB Bank
CCC Bank
ZZZ Bank
Through multiple
intermediaries in various locations
Through multiple
intermediaries in various locations
Mr.A (Police) and Mrs. A’s Joint Saving A/Cs
JJJ Bank
Other partiesOther parties
Cash Deposits
Cash Withdrawals
Purchase IL policies
Placement
Layering
EXAMPLE OF MONEY LAUNDRER AT WORK
PEP Year 1 – M2 (eModule)
53
� Structuring life insurance transactions to launder proceeds of corruption
(Indonesia)
� During various periods in 2005/2006 Mrs. A bought more than 20 investment-related life insurance policies with insurance premium value mostly of over USD40,000 each in cash, purchased using multiple intermediaries in different areas
� The life insurance company filed an STR in respect of the large cash transactions moving through the company accounts
� Transaction history showed that to pay for the policies Mrs. A used cash withdrawn from her savings account in BBB Bank, CCC Bank and ZZZ Bank and a joint account with her husband Mr. A in JJJ Bank
� The source of funds in the JJJ Bank account had been transferred in from several parties accounts during 2005 totaling about USD620,000 and from Mrs. A’s account in CCC Bank within 2005 for a total amount more than USD250,000
� There were also several amounts deposited in cash by others parties between 2005 estimated at over USD120,000. As Mr. A was a high ranking police officer the STR referral was submitted to law enforcement agency for action and identification of possible corruption and money laundering activities
(Source: APG Typologies Report)
PEP Year 1 – M2 (eModule)
54
�Children of a government official investing in life insurance
(Indonesia):
Insurance Company
A’s Account
XXX BankFormer High Government Official
IL top-up
Integration
Layering
A’s Sister’s Account
XXX BankPurchase single premium IL policy and early surrender within
1 month
Children of
CV GOODCV GOOD
Set up a mining company
Purchase policy under company
Under investigation for corruption
EXAMPLE OF MONEY LAUNDRER AT WORK
PEP Year 1 – M2 (eModule)
55
� Children of a government official investing in life insurance (Indonesia):
� From March – July 2004 there were several additional premium payments (top ups) to a life insurance policy for a total amount more than USD500,000 funded from a man’s account in XXX Bank Ltd.
� In June 2006 that person’s older sister bought a single premium of investment related life insurance product estimated USD200,000. She terminated this insurance policy by July 2006 due to urgently needed for funding a real estate investment. The life insurance company disclosed the early termination insurance policy to law enforcement agency.
� She then established and registered company named “CV GOOD” in September 2006 with capital of approx. USD50,000 to engage in the mining business, with herself assigned as owner/director.
� The woman then bought another life insurance policy in October 2006 with CV GOOD acting as policyholder.
� An exchange of information within the law enforcement agencies revealed that they were the children of a former high government official. The father was under investigation for corruption.
(Source: APG Typologies Report)
EXAMPLE OF MONEY LAUNDRER AT WORK
PEP Year 1 – M2 (eModule)
56
�Purchased of Valuable Assets (Malaysia)
Mr. Y’s Bank A/CMultiple A/Cs
– including A/Cs
maintained by relatives
Multiple A/Cs – including A/Cs
maintained by relatives
Various sources – illegal gambling
operators, prostitution-related biz and illegitimate VCD-selling activities
Various sources – illegal gambling
operators, prostitution-related biz and illegitimate VCD-selling activities
Cash Deposits
Placement
Layering
Transfer
Investment Portfolios
Unit trust
IL policies
InvestmentFixed
Deposit A/C
Place with bank for credit
facilities
Place with bank for credit
facilities
Purchase assets with overdraft and term loans
In his or his family
Members’ names
Repaid loans within a short period of time
Integration
EXAMPLE OF MONEY LAUNDRER AT WORK
PEP Year 1 – M2 (eModule)
57
�Purchased of Valuable Assets (Malaysia)� Mr. Y, a senior government official, elicited corrupt money from various illegal businesses, such as illegal gambling operators, prostitution-related businesses and illegitimate VCD/CD-selling activities
� Mr. Y frequently received large amounts of cash deposits from various sources. The funds were deposited by third parties into his bank account
� The money was immediately transferred to multiple accounts maintained with various financial institutions, including to the accounts held by his immediate family members and friends
� It was then layered into other forms by acquiring local investment portfolios, unit trusts and multiple investment scheme insurance policies
� Some of the funds were also withdrawn to open fixed deposit accounts, which were in turn placed with commercial banks to secure credit facilities. These commercial banks granted him personal overdrafts and term loans or hire purchase facilities to part finance purchase of several properties and vehicles either in his or his family member’s names
� Mr. Y fully repaid most of his loans within a short period. The financial transactions carried out by Mr. Y did not fit his profile as a salaried government official. The financial intelligence gathered from the STR was disclosed to the relevant enforcement agency. To date, approximately RM4.0 million (US$1.1 million) has been seized
(Source: APG Typologies Report)
PEP Year 1 – M2 (eModule)
58
�Stock Manipulation And Use Of Nominees (Malaysia)
Mr. T – controlling shareholder of XYZ Co.
12 Investors –20 A/Cs with 8 SBCs
12 Investors –20 A/Cs with 8 SBCs
Placement
Layerin
g
Manipulate share price of XYZ Co. – from RM1 to RM6
XYZ Co.
Bank A/C of 12 investors
ABC BankProfit from market
manipulation
AAA Company
MMM Company
ZZZ Company
Members of Mr. T’s family
Members of Mr. T’s family
Owned by
Buying and selling of shares without change of change of BO
EXAMPLE OF MONEY LAUNDRER AT WORK
PEP Year 1 – M2 (eModule)
59
�Stock Manipulation And Use Of Nominees (Malaysia)� Mr. T, a controlling shareholder of a company listed on the Kuala Lumpur Stock Exchange (KLSE) used 12 investors as a front for him to manipulate stock.
� Between March and May 2002, the price of XYZ had increased significantly from a low of RM1.00 to a high of RM6.00.
� The group of 12 investors had traded heavily on XYZ shares via 20 accounts maintained at 8 different stock broking firms.
� Investigation revealed that 80% of the total volumes done for XYZ during the relevant period were carried out by these 12 investors with high instances of NCBO (no-change-in-beneficial-ownership) trades. (Note: NCBO: if a person, or a person’s associate, has an interest in the Product before the transaction and has an interest on the same Product after the transaction”)
� Proceeds of approximately RM50 million (USD14.5 million) were generated and deposited into the respective bank accounts of the 12 investors maintained at ABC Bank.
� In order to layer the illicit funds they were then immediately transferred to AAA Company before moving to MMM Company and finally to ZZZ Company (ZZZ later revealed to be owned by members of Mr. T’s family). The accounts of AAA, MMM and ZZZ were also maintained at the same ABC Bank and branch.
(Source: APG Typologies Report)
EXAMPLE OF MONEY LAUNDRER AT WORK
PEP Year 1 – M2 (eModule)
60
�Use Of Nominees For Bank Fraud (Malaysia)
Customers’fixed
deposits
Customers’fixed
deposits
Mr. Z – branch manager of local bank
Liquidate customers’ fixed
deposits
Placement # 2
Layering
5 customers’bank a/cs
5 customers’bank a/cs
Bank A/Cs
Mr. L
Mr. N
Mr. T
Transfer to
Transfer to
Other A/Cs in other banks
Other A/Cs in other banks
Withdrawn
Illegal gambling activities
Illegal gambling activities
Payments for his bets
Involved in
Placement #1
EXAMPLE OF MONEY LAUNDRER AT WORK
PEP Year 1 – M2 (eModule)
61
�Use Of Nominees For Bank Fraud (Malaysia)� Mr. Z was a branch manager of a local bank. He manipulates his position as a branch manager to commit criminal breach of trust by liquidating fixed deposit savings of his branch’s customers.
� Mr. Z liquidated approximately RM19 million (USD 5 million) over a period of three years.
� Mr. Z transferred the monies to five accounts belonging to five different customers at his branch. Subsequently, RM18million was transferred out of these five accounts to three other major accounts that belong to three different individuals, Mr. L, Mr. N and Mr. T.
� Investigations also revealed that Mr L, Mr. N and Mr. T were involved in illegal gambling activities (illegal 4 Digits betting). These three individuals claimed that all the monies transferred into their accounts by Mr. Z were payments from Mr. Z for his bets. However, investigation further revealed that the funds were transferred to other accounts in different banks and eventually withdrawn.
� These three individuals were later found to be collaborating with Mr. Z in his scam. Mr. Z was arrested and charged for criminal breach of trust while Mr. L, Mr. N and Mr. T were charged for committing money laundering under Section 4 (1) of the AMLA.
(Source: APG Typologies Report)
EXAMPLE OF MONEY LAUNDRER AT WORK
PEP Year 1 – M2 (eModule)
62
Computers and components
�Card Skimming And Cash Sales Of Goods (Malaysia)
Ms. A –Sales Rep in boutique
Placement
Customers’ Credit Card Info
Colleagues & Friends
Colleagues & Friends
Steal
Purchase via internet Sold to
Bank A/C
Payments for purchase – via cash deposit machine
EXAMPLE OF MONEY LAUNDRER AT WORK
PEP Year 1 – M2 (eModule)
63
�Card Skimming And Cash Sales Of Goods (Malaysia)� The suspect, Ms. A, worked as a Sales Representative in a boutique in Kuala Lumpur.
� She stole pertinent credit card information from customers who made purchases in the boutique, holders of gold and platinum credit cards.
� Ms. A recorded the credit card number, its expiry date as well as the 3 digits Card Verification Value (CVV) number listed behind the credit card.
� Using the credit card information, Ms. A purchased computers andcomputers components via the internet, impersonating as the actual credit card holders.
� The computers were subsequently sold at attractive prices to her fellow colleagues and friends. Those who purchased the computers from Ms. A were required to make the payment in cash into Ms A’s account via the cash deposit machine.
(Source: APG Typologies Report)
EXAMPLE OF MONEY LAUNDRER AT WORK
PEP Year 1 – M2 (eModule)
64
The Financial Action Task Force (FATF) (established in 1989) is an inter-
governmental body whose purpose is the development and promotion of policies,
both at national and international levels, to combat money laundering and
terrorist financing.
The Task Force is therefore a "policy-making body" which works to generate the
necessary political will to bring about national legislative and regulatory reforms
in these areas.
The FATF monitors members' progress in implementing necessary measures,
reviews money laundering and terrorist financing techniques and counter-
measures, and promotes the adoption and implementation of appropriate
measures globally. Currently has 34 country members.
AML WORLD BODY (FATF & APG)
PEP Year 1 – M2 (eModule)
65
� Malaysia is not a member of FATF but is a member of Asia Pacific Group (APG) on money laundering. APG plays similar role as FATF but at a regional level.
� FATF has established and revised 40 recommendations in 1996 for combating AML worldwide.
� It has further introduced 9 special recommendations in 2001 to address financing of terrorism activities following Sept 11 incident.
AML WORLD BODY (FATF & APG)
PEP Year 1 – M2 (eModule)
66
Briefly 40 Recommendations by FATF involve:
Legal Systems
Make money laundering an offence & confiscate proceeds of crime
Financial and Regulatory
Customer due diligence, record keeping, report suspicious transaction and supervision
Law Enforcement
Competent authorities, international cooperation, prosecution and extradition
FATF 40 RECOMMENDATIONS ON
ANTI MONEY LAUNDERING
PEP Year 1 – M2 (eModule)
67
Currently there is no country being listed as Non Cooperative Countries and Territories
Countries previously in the NCCT list include:Myanmar, Nigeria, Nauru, Philippine, Indonesia & Cook Islands
Myanmar being the last country to be delisted wef October 2006
NON COOPERATIVE COUNTRIES AND TERRITORIES
(NCCTs)
PEP Year 1 – M2 (eModule)
68
Following terrorists attacks on September 11, 2001, the world communities are increasingly concerned with the widespread of terrorism activities.
FATF has further introduced 9 special recommendations to address terrorism financing. The 9 special recommendations are:
1. Ratification and Implementation of UN resolution made in 1999 onsuppression of terrorism financing.
2. Criminalizing the financing of terrorism and associated money laundering.
3. Freezing and confiscating terrorist assets.
4. Reporting Suspicious transaction related to terrorism
FATF – 9 SPECIAL RECOMMENDATIONS ON SUPRESSION
OF TERRORISM FINANCING
PEP Year 1 – M2 (eModule)
69
5. International cooperation and exchange of information
6. Alternative Remittance – Countries should ensure that persons or legal entities that carry out such services illegally are subject to administrative, civil or criminal sanctions.
7. Wire Transfer – Banks are to ensure adequate info are available before executing.
8. Non profit organizations – Countries must ensure that such entities are not used for terrorist activities.
9. Cash Couriers – countries should put in place measures for the declaration of cash above a specified threshold when it is taken into or out of a country.
FATF – 9 SPECIAL RECOMMENDATIONS ON SUPRESSION
OF TERRORISM FINANCING
PEP Year 1 – M2 (eModule)
70
APG MUTUAL EVALUATION PROCESS
� Asia Pacific Group (APG) adopted the Mutual Evaluation Process to evaluate & monitor the progress made by its members in implementing the FATF 40 + 9 Recommendations on anti-money laundering (AML) & counter-financial terrorism (CFT) measures.
� Objective of mutual evaluation (Peer Review) is to assess:
(1) The standard benchmark for AML/CFT measures are met.
(2) Identify weaknesses.
(3) Make recommendations for improvement.
� Evaluation technique is based on detailed questionnaire and a subsequent on-site visit conducted by a team of at least 3 selected experts from the legal, financial and law enforcement fields of other APG members.
MALAYSIA’S 2ND MUTUAL EVALUATION
PEP Year 1 – M2 (eModule)
71
� The findings of the APG assessment team will be compiled in a Mutual Evaluation Report, which describes in detail the system in place and the effectiveness ratings plus the recommendations on areas which requires further progress/ improvement.
� The mutual evaluation reports remain confidential documents unless the Country being evaluated decides or agrees to release its own report. However, short summaries of the mutual evaluation report can be found in the APG Annual Report. (Effective 23/7/07, automatic publication of MER in APG Website)
� Major non-observance/ deficiencies in AML/CFT measures may cause the country being de-listed from the APG membership.
MALAYSIA’S 2ND MUTUAL EVALUATION
PEP Year 1 – M2 (eModule)
72
� Malaysia has undergone the 2nd Mutual Evaluation in February 2007.
� Evaluation team consist of 5 experts:
1) Legal expert from Australia – Ms Elizabeth Ryan, Senior Asst
Director, Commonwealth Director Of Public Prosecutions.
2) Financial expert from UK – Mr Richard Chalmers, Adviser,
International Strategy And Police Co-ordination, Financial Service
Authority.
3) Financial expert from NZ – Mr Peter Dench, Adviser, Financial
System Oversight, Financial Stability Department, Reserve Bank of
New Zealand.
4) Law enforcement expert from Indonesia – Mr Yusfidli Adhyaksana ,
Prosecutor, Attorney General’s Office
5) APG Secretariat – Mr. David Shanon, Executive Secretary (Australia)
MALAYSIA’S 2ND MUTUAL EVALUATION
PEP Year 1 – M2 (eModule)
73
� The experts had visited BNM, the NCC (SSM, LOFSA, Immigration, RMP etc) and several reporting institutions (Genting Casino, CIMB, HSBC, POS M’sia, Maybank Takaful, Takaful Ikhlas, Great Eastern, Money Changer, RHB Islamic Bank, Bank Simpanan, Bank Rakyat etc) to review the AML/CFT compliance programme in place.
� Review report on the country’s AML/CFT framework was published in the APG website on 20/8/07.
MALAYSIA’S 2ND MUTUAL EVALUATION
PEP Year 1 – M2 (eModule)
74
THE AML/CFT ASSESSMENT METHODOLOGY
There are 5 possible levels of compliance as follows:
Compliant (C): The Recommendation is fully observed with respect to all essential criteria.
Largely compliant (LC): There are only minor shortcomings, with a large majority of the essential criteria being fully met.
Partially compliant (PC): The country has taken some substantive action and complies with some of the essential criteria.
Non-compliant (NC): There are major shortcomings, with a large majority of the essential criteria not being met.
Not applicable (NA): A requirement or part of a requirement does not apply, due to the structural, legal or institutional features of a country e.g. a particular type of financial institution does not exist in that country.
PEP Year 1 – M2 (eModule)
75
The APG Mutual Evaluation On Malaysia
Malaysia has obtained a good ratings for the mutual evaluation (as BNM has benchmarked Australia) with the following results:
� 9 Compliant
� 24 Largely Compliant
� 15 Partially Compliant
� 1 Non-Compliant Non-compliance is in relation to the Special Recommendation 9 on cash courier - the assessors were of the view that the declaration imposed by M'sia for cross border cash courier is more for exchange control purposes rather than for AML.
Malaysia has obtained 67% (33 out of 49) compliant of 70% (Compliant & Largely Compliant) and above.
12
9
1514
24
28
13
15
2
10
1
4
0
5
10
15
20
25
30
Australia Malaysia United
States
No. Of Recommendations
Compliant
Largely Compliant
Partially Compliant
Non-Compliant
53% compliant
of 70% and above
67% compliant
of 70% and above
88% compliant
of 70% and above
PEP Year 1 – M2 (eModule)
76
HOW AML AFFECTS ME AS AN AGENT?
� Need to be more vigilant
� Know my customer well
� Report to Compliance Secretariat if any of my customers are suspected to be involved in money laundering activities
PEP Year 1 – M2 (eModule)
77
All rights reserved. No part of this publication may be produced ,translated, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying and recording without the prior written permission of the copyright the developer and owner.
End of Topic 1
AMLA/ CFT Reading Material
PEP Year 1 – M2 (eModule)
Code of Ethics and Conduct
Reading Material
Topic 2:
PEP Year 1 – M2 (eModule)
Statement of Philosophy
1. The Life Insurance Business is based n the philosophy of risk sharing. It is
ubiquitous that such business be operated and administered with the
highest degree of Integrity and Ethics.
2. It is a business based on trust and honesty, requiring high degree of
responsibility and professionalism.
3. The confidence of policy owners and members of the public in the integrity
and honesty of life insurers shall be safeguarded and enhanced.
4. Life Insurers shall at all times see that their business is soundly managed
to ensure the safety of policy owners’ savings and the credibility of their
companies.
5. Life insurers shall maintain a policy of efficient and prompt service to
policy owners and, to assist and advise them where necessary, with the
aim of promoting goodwill
Code of Ethics and Conduct
PEP Year 1 – M2 (eModule)
Life Insurance Selling
• General sales principles
• Explanation of the contract
• Disclosure of underwriting information
• Accounts and financial aspects
Code of Ethics and Conduct
PEP Year 1 – M2 (eModule)
Life Insurance Selling: General Sales Principles
The Agents SHALL:
i. Identify himself that he is an agents of Great Eastern Life Assurance (M) Berhad and produce his Registered Intermediary Authorisation Card.
ii. Policy Proposed is suitable to the needs of the prospect.
iii. Give advice only on matters in which he/she is competent to deal with.
iv. Treat all prospect’s information completely confidential.
v. When making comparison, make it clear the different characteristics of each policy/investment.
vi. Render continuous services to Policyholder.
Code of Ethics and Conduct
PEP Year 1 – M2 (eModule)
Life Insurance Selling: General Sales Principles
The Agents SHALL NOT:
i. Make inaccurate or unfair criticisms of any insurers.
ii. Persuade prospect to cancel any existing policy.
Code of Ethics and Conduct
PEP Year 1 – M2 (eModule)
Life Insurance Selling: Explanation of the Contract
The Agents SHALL:
i. Explain the essential provisions of the contract which he/she is recommending.
ii. Draw attention to any restrictions including exclusions.
iii. Draw attention to the consequent effects of early discontinuance and surrender.
iv. Draw attention to whether the policy qualify for tax relief.
Code of Ethics and Conduct
PEP Year 1 – M2 (eModule)
Life Insurance Selling: Explanation of the Contract
The Agents SHALL:
• Where policy offers participating in profits, descriptions of the benefits shall distinguish between fixed and projected benefits.
• Where projected benefits are illustrated, it should be made clear that they are based on certain assumption. In the case of IL policies, it should be made clear that unit values may fluctuate up or down depending on the value of the underlying investments.
• Use ONLY the whole and latest Sales Illustration (GELSIS) supplied by Great Eastern Life Assurance (M) Berhad. He shall use the whole sales illustration when he is discussing with the prospect and shall not add to itor select only the most favorable aspects of it.
Code of Ethics and Conduct
PEP Year 1 – M2 (eModule)
Life Insurance Selling: Disclosure of Underwriting Information
The Agents SHALL:
i. Ensure that the consequences of non disclosure and inaccuracies are pointed out to the proposer.
The Agents SHALL NOT:
i. Influence the proposer and make it clear that all the answers or statements are the client’s own responsibility.
Code of Ethics and Conduct
PEP Year 1 – M2 (eModule)
Life Insurance Selling: Accounts and Financial Aspects
The Agents SHALL:
i. Acknowledge receipt and maintain a proper account of all the money received in connection with an insurance policy. Shall distinguish the premium from any other payment.
ii. Forward to the company without delay any moneys received.
Code of Ethics and Conduct
PEP Year 1 – M2 (eModule)
87
All rights reserved. No part of this publication may be produced ,translated, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying and recording without the prior written permission of the copyright the developer and owner.
End of Topic 2
Code of Ethics and Conduct
Reading Material
PEP Year 1 – M2 (eModule)
Replacement of Life Insurance
Policies
Topic 3:
DISCLAIMER
This presentation is was prepared with much of the complex details simplified to ease your
understanding. Inevitably, some of the details describing the contents herein has been generalized or
simplified. Whilst every care and diligence been taken to ensure accuracy and comprehensiveness,
should there be any discrepancy between the contents herein and that of the agency contract, agency
rules & regulations and e-circulars issued the latter collectively shall prevail. For the avoidance of doubt
this proposal presentation has no legally binding force and shall not be deemed as an offer or invitation
to treat by any parties hereto or being presented the proposal presentation.
PEP Year 1 – M2 (eModule)
This session will cover the following:
• What is ROP & Frequently Asked Questions on
ROP?
• A flow chart of the ROP appeal process• Brief background and circulars issued on ROP
Replacement of Policies:
PEP Year 1 – M2 (eModule)
What is Replacement of policies (ROP)?
Any transaction involving the purchase of life insurance policy is construed as a replacement of policy if within 12 months before or after a new policy is effected, an existing life insurance policy has been replaced on the same life assured as per Category A or Category B.
Replacement of Policies:
PEP Year 1 – M2 (eModule)
What is meant by 12 months before a new policy is affected?
This is illustrated in the next slide….
Replacement of Policies:
PEP Year 1 – M2 (eModule)At New Business stage…
12 months backwardfrom registration date
Transactions on old policy with same Life AssuredCategory A:• Surrender/Full Withdrawal (ILP)
• Partial surrender (exclude ILP)
• Lapse, APL lapsedCategory B• Extended Tem Assurance (ETA)
• Reduced Paid Up (RPU)
• 1st APL raised with no repayment within 6 months
• Reduce premium
New Proposal RegistrationCONSIDERED AS ROP WHEN:
PEP Year 1 – M2 (eModule)
What is meant by 12 months after a new policy is affected?
This is illustrated in the next slide….
Replacement of Policies:
PEP Year 1 – M2 (eModule)At Customer Service…..
12 months backwardsfrom CS transaction date
New policy issued CONSIDERED AS ROP WHEN:
Transactions on old policy with same Life AssuredCategory A• Surrender/Full Withdrawal (ILP)
• Partial surrender (exclude ILP)
• Lapse, APL lapsed
Category B• Extended Tem Assurance (ETA)
• Reduced Paid Up (RPU)
• 1st APL raised with no repayment within 6 months
• Reduce premium
PEP Year 1 – M2 (eModule)
What happens when a Policy is identified as under ROPCategory A ?
Basic Commission and Overriding Commission will not be paid on the new policy when an existing policy is replaced under Category A.
NOTE:
1. As long as the ROP is classified as ROP Cat A, Basic Commission & OR will not be paid even if the RP Letter is signed and returned to NB / CS.
2. All Basic Commission & all OR will be not paid I.e the Agent will get zero commission and any paid will be clawed back
Replacement of Policies:
PEP Year 1 – M2 (eModule)
What happens when a Policy is identified as under ROP Category B ?
If the RP letter is not signed and returned:• At NB stage: the policy will not be made inforce• At CSD stage: the commission and OR paid will be clawed back and the agent will get zero commission and OR on all subsequent premiums received.
NOTE:
• For Category B ROP, All commissions & OR not paid previously will be paid back once the RP letter is signed and returned to CS.
Replacement of Policies:
PEP Year 1 – M2 (eModule)
What are the types of policies affected by ROP?
1. Traditional policies (Whole Life & Endowment)
2. Term policies (Regular Premium)
3. Investment Link policies (Regular Premium)Note: Please refer to our circular dated 19th October 2009 on ROP for Smart Invest Premier Insurance
Replacement of Policies:
PEP Year 1 – M2 (eModule)
What are the types of policies NOT affected by ROP?
• Single Premium Traditional Policies
• Single Premium Investment Link policies
• Medical policies (e.g Great Medicare)
Note: Medical policies are not affected by ROP when they replace a nonMedical policy.
However ROMP applies where a medical policy replaces another medical policy- pl refer to our circular dated 10th July 2009 Ref CAD/0742/JULY2009 titled” REPLACEMENT OF MEDICAL POLICIES (ROMP)
Replacement of Policies:
PEP Year 1 – M2 (eModule)
What is meant by same life assured?
Ans: The life assured must be the same for the main plan.
What will happen once a policy is identified as ROP?
Ans: A Replacement of policy (RP) letter will be issued by NB or CSwhere the policyholder is required to sign and return the letter within 14 days.
What will happen if the RP letter is not signed and returned to NB Dept?
Ans: The NB will not be made in force
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
What will happen if the RP letter is not returned to CS?
Ans: For category B:The commission and OR will be clawed back and no subsequent commission and OR will be paid on any further premiums received on the NB policy.NOTE: For category A: The commission & OR will be clawed back even if the RP letter is signed and returned.
What will happen if a policy holder who receives the RP letter opts for option 2 in the RP letter where he does not want to continue with the new policy but retain his existing policy?
Ans: Then GELM will consider allowing the policyholder to revive / reinstate the existing policy and will refund all premiums paid on the NB and claw back the respective commissions/OR/production etc on the new policy once the policy is revived / reinstated.
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
What will happen if the policyholder who receives the RP letter opts for option 3 in the RP letter where he is willing to reinstate the lapsed policy or is willing to refund back the surrender cheque plus interest to reinstate back his surrendered policy and also to retain his new policy.
Ans: The new business will be made inforce and the commission and OR will be held back until the existing policy is reinstated. When this occurs, the agent concerned has to inform Agency Admin to credit back the commission and OR.
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
If either the existing or the NB is a Keyman policy, will the NB be considered as a ROP?
Ans: No
Is policy loan considered as a replacement of policy transaction?
Ans: No
When an existing investment link policy is fully withdrawn, will the NB secured within 12 months be considered as ROP?
Ans: Yes
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
If the policyholder cancels the policy within the cooling-off period, and subsequently decides to buy the same policy again within 12 months, will the NB submitted be considered as a ROP?
Ans: No, the NB will not be considered as a ROP
When the installment premium paid is not reduced but the sum assured is reduced for an investment link policy, will a NB secured within 12 months be considered as a ROP?
Ans: No
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
What happens when a NB is submitted and an existing policy with another Insurer has a Category A or B transaction?
Ans: No action will be taken on the NB unless there is a complain from the other insurer /agent through LIAM.
What happens if a NB is submitted and an existing policy under OAC (Life Asia System) has a category A or B transaction?
Ans: The NB will fall under ROP and the respective RP letters will be sent out and action will be taken accordingly.
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
What will happen if an existing policy that has lapsed resulting in a NB on the same life to be penalised, is reinstated / revived?
Ans: The Agent for the New Policy must inform Agency Admin through their Business Development Staff and the full basic commission and OR clawed back will be paid and all monies clawed back will be paid back.
Can an agent submit a “consent letter” / RP letter” together with a new proposal?
Ans: This will only be accepted for replacements of external policies i.e. issued by other Insurers. All replacement of internal polices (i.e. polices issued by GE inclusive of OAC policies) must wait for our RP letter which will be issued together with our SQL.
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
How will an agent know that his NB has been identified as a ROP?
Ans:
At NB stage:The Agent for the NB will be given a copy of the SQL, & also a RP letter & an ROP Notification letter from Agency Administration Dept.
At CS stage: The agent will get a copy of the RP letter & an ROP Notification letter from Agency Administration Dept
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
How will the agent be given his copy of the RP letter?
Ans: The Agent’s copy of the RP letter will be sent to him through his GSM’s box in his respective Branch
How will the policyholder get their RP letter?
Ans: The policyholder’s RP letter will be posted to his last known address by CS and at NB stage, letter is passed through the agent
Will the Company accept it if the signed and returned copy of the RP letter is returned by the Agent?
Ans: Yes
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
Can an agent get a copy of the RP letter if the original copy has been misplaced?Ans: Yes, he can get a copy from his Branch.The Branch administrator can get it from EDMS as the copy of RP letter is not available in ePartner.
When will commission be affected if a new policy is identified as replaced?Ans: a) When the policy is replaced under Category A
b) When the policy is replaced under Category B but the RP letter sent out by CSD is not signed and returned to the Company.
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
How will the commission be penalised?
Ans: All basic commission and overriding commission paid on the new policy will be fully clawed back and no commission and OR will be paid on any subsequent premiums received on the policy.
However, the following will still be paid upon meeting the respective requirements:
– Production bonus
– PR bonus &
– Deferred benefit
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
Will premiums received on a policy identified as ROP and penalisedwith zero commission and OR be considered for maintenance, promotion, supremacy and AOM?
Ans: Yes
Can an Agent submit a request for exemption from being penalisedunder the BNM’s ROP under Category A ?
Ans: Yes
Is there a need to submit ROP Appeals for Category B ROP?
Ans: No as commission & OR will be credited back automatically oncethe RP letter is signed and returned to CS (Customer Service Dept at your Branch and CS informs Agency Admin.
Replacement of Policies: FAQ
PEP Year 1 – M2 (eModule)
ROP Appeal Flow Chart
PEP Year 1 – M2 (eModule)ROP Appeal process:
1. NEW BUSINESS DEPT / CUSTOMER SERVICE:
a) identifies proposal as ROPb) sends out Query (if at NB stage)c) sends our RP letters to Policyholder & cc agentd) At NB Dept: Upon receipt of signed RP letter, makes policy in force
and informs AAD for Category A cases only.e) At CSD:Sends Monthly report of all category A polices to agency
admin NOTE: CSD also informs AAD of category B cases where RP letter is not
returned
2. AGENCY ADMIN:
a) Zerorise basic commission for all such policiesb) Send ROP Notification letter to agents affected stating that:
� Their commission has been held back� The ROP might be exempted from ROP if the policyholder is
aware of the advantages & disadvantages of the ROP� Attach with the ROP Notification letter:
� ROP Exemption Application Form� ROP Comparison worksheet� Policyholder Justification Form
NOTE:If the Agent is convinced that the replacement is to the benefit of the policyholder, the Agent to …..
4. ROLE OF AGENT
Discusses the findings from the comparison worksheet with the policyholder and ensures the P/H understands the positive and negative features of the new and existing polices and gets the signed acknowledgement from the policyholder. Obtains contact details and time for interview.. Passes the signed comparison worksheet, ROP application form and the Justification Form to their respective BDMs who will pass them to Agency Admin
Continued next slide….
NOTE:
BDM / AAD to reject application with incomplete documents required
Moving forth, RP letter to be uploaded to
ePartnerePartner
PEP Year 1 – M2 (eModule)ROP Appeal process: ROP at NB
10. APPEAL COMMITTEE: for recommendation
11. CEO/Appointed Actuary: for decision
12. AGENCY ADMIN
�Replies to respective agents, advises RM/BDM of decision made�Takes action on all appeal policies not exempted and credits back all commissions on appeals approved and where commissions had been clawed back.
7. AGENCY ADMIN
Upon receipt of the signed comparison worksheet & other documents from the agents passes the worksheets to CSD:
8. CSD
Calls and interviews the policyholder and signs acknowledgement that the policyholder is aware of the advantages and disadvantages of ROP
9. AGENCY ADMIN
�Prepares worksheet.�Checks & verifies findings for presentation to Appeal committee
END
Continued
CS calls 3 times
Thereafter will inform agent to revert with contact details within 2 weeks. Appeal will be closed if no response.
STATUS
Latest by end of
3rd month
from Submission Date…
PEP Year 1 – M2 (eModule)
ROP Appeal Process:
ROP Appeal Forms
Policyhold
er Justific
ation
Policyhold
er Justific
ation
Comparis
on Works
heet
Comparis
on Works
heet
ROP Exem
ption App
s
ROP Exem
ption App
s
Note: To rejectreject application if submission of documents are not completed
PEP Year 1 – M2 (eModule)
Fraud Awareness & Agency Conduct
Reading Material
Topic 4:
PEP Year 1 – M2 (eModule)
116
To create awareness amongst agents on Company
Fraud Awareness Policy & Agency conduct and
appreciate its importance
COURSE OBJECTIVESCOURSE OBJECTIVES
PEP Year 1 – M2 (eModule)
Training Agenda
1. Definition of Fraud
2. Types of Fraud
3. Handling of Agency Fraud
4. Guidelines & Procedures governing Fraud investigation Process
5. Our Responsibilities
6. Common Agency Misconduct & its implications
PEP Year 1 – M2 (eModule)
What is Fraud?
An act or omission intended to gain dishonest
or unlawful advantage for the party committing
the fraud or for other related parties
.…From GELM Fraud Control Policy
Definition of FraudDefinition of Fraud
PEP Year 1 – M2 (eModule)
Types of Fraud
• Internal Fraud
• Intermediary/Agency Fraud
• Policyholder & Claims Fraud
• External Fraud
For the purpose of this policy, intermediary includes tied agents, financial advisory firms and insurance brokers (where applicable)
Types of FraudTypes of Fraud
PEP Year 1 – M2 (eModule)
Fraud allegations (commonly known as agency misconduct
cases) are investigated by an independent unit within
GELM –The Market Conduct Enforcement (MCE) unit.
The MCE unit (previously known as the Centralized
Investigation Unit (CIU) was set up in year 2003 and is now
part of the Risk Management & Compliance Department.
Handling of Agency Fraud Handling of Agency Fraud
PEP Year 1 – M2 (eModule)
Cases that are typically investigated by Market Conduct
Enforcement (MCE) unit originate from the following sources:
• Complaints from policyholders/agents/external parties• Feedback from policyholders via Replacement of Policy
confirmation• Feedback from policyholders via Claims application• Referral from line departments • Enquiry from authorities, e.g. BNM, LIAM
Note: Not all agent misconduct cases are investigated by MCE.
Handling of Agency Fraud Handling of Agency Fraud
PEP Year 1 – M2 (eModule)
The following are the categories of major misconduct
(fraudulent in nature) that will be investigated by Market
Conduct Enforcement (MCE) unit :
• Misappropriation of premium• Forgery• Misrepresentation of facts• Others (e.g., misuse of Easipay Form, use of pre-signed form,
non-disclosure, use of unauthorized sales materials, professionalism & integrity)
Handling of Agency Fraud Handling of Agency Fraud
PEP Year 1 – M2 (eModule)
The Company shall be entitled to automatically terminate this agreement by
giving 7 days’ notice in writing to the agent if the agent:-
20.1 – is in breach of any circular or directive issued by the Company pursuant to any government directive, regulation, rule or statute
20.2 – is in breach of any term or condition of this agreement and/or the prevailing agency rules and regulations
20.3 – by any act or omission including any breach of law brings discredit to the reputation and integrity of the company or is guilty of any conduct which in the opinion of the company is prejudicial to the company’s interest
Typical agency agreement clauses used in our investigation process
Continue on next page….
Guidelines & Procedures governing Fraud Guidelines & Procedures governing Fraud
investigation Processinvestigation Process
PEP Year 1 – M2 (eModule)
The Company shall be entitled to automatically terminate this agreement
by giving 7 days’ notice in writing to the agent if the agent:-
20.6 – misappropriates any money or payment in any form made in respect of premium or if he pays or offers to pay as an inducement or otherwise to any proposer for life insurance any rebate or any other form of payment is such rebate of payment is not specified in the policy or if the agent attempts to do any of the above mentioned acts
20.7 – makes a misrepresentation to any person for the purpose of inducing a policyholder of the company or any other insurance company to convert, lapse or surrender his policy or for any other purpose
Typical agency agreement clauses used in our investigation process
Guidelines & Procedures governing Fraud Guidelines & Procedures governing Fraud
investigation Processinvestigation Process
PEP Year 1 – M2 (eModule)
D
O
N
O
T
DO NOT share customers’ information with external parties.
DO NOT under any circumstances, forge signatures in
order to expedite the process.
DO NOT under any circumstances, use policyholder’s
cheque to pay for 3rd party or agent’s own policy.
DO NOT induce a policyholder to convert, lapse or
surrender his policy.
DO NOT use unauthorised sales materials.
DO NOT commit or abet in any fraud activities
Our Responsibility Our Responsibility –– Do or DonDo or Don’’tt
PEP Year 1 – M2 (eModule)
DO explain clearly to the customers on guaranteed and non-
guaranteed features of any insurance plan.
DO remit cash payment collected from the policyholder to
the company as soon as possible.
DO report any suspicions of fraud in accordance with the
reporting requirements
DO be vigilant to prevent and detect fraud
Our Responsibility Our Responsibility –– Do and DonDo and Don’’tt
PEP Year 1 – M2 (eModule)
127
Common Agency Misconduct
& its implications
PEP Year 1 – M2 (eModule)Misappropriation of PremiumMisappropriation of Premium
Examples1. Policyholder pays premium in cash to the agent but the cash
payment was not remitted to the Company.
2. Policyholder’s cheque was used to pay 3rd party or agent’s own policy.
What is Misappropriation of PremiumMisappropriation of Premium?In insurance context, misappropriation of premium is committed when a person dishonestly misappropriates money that has been entrusted to him, or converts to his own use that money in violation of that trust.
PEP Year 1 – M2 (eModule)
No of Cases Registered from January 2008 to December 2010
Misappropriation of Premium Misappropriation of Premium -- StatisticStatistic
45%142652009
45%2431102010
47%511240Total
51%126652008
%Total No. of ComplaintsNo. of cases receivedYear
Penalties imposed on agents upon completion of investigation.
90
26
37
27
No case
28
-
1
27
Pending
Investigation
240
65
65
110
No. of cases
received
87Total
392008
272009
212010
Terminated/
Warning
Year
PEP Year 1 – M2 (eModule)
Based on our experience, some of the common explanations given by our agents when the policyholder filed a complaint against them for not remitting their cash to the company to pay for the premium include the following:-
“I have paid on behalf of the policyholder, which is why when he issued the
cheque, I used it to pay for my other policyholder’s policy.”,
“I was busy or overlooked, forgot to remit the premium.”,
“I had used the policyholder’s premium as I was facing financial difficulty.
Will pay the money back to policyholder.”
Important Note: Any agent who misappropriates any money or
payment in any form made in respect of premium, is in breach of the
Agency Agreement, and if found guilty will be terminated even if the
policyholder withdraws the complaint.
Misappropriation of Premium Misappropriation of Premium –– Actual InstancesActual Instances
PEP Year 1 – M2 (eModule)Signature ForgerySignature Forgery
Examples1. Forging on a form or document pertaining to a life assured who
may be the proposer, an existing policyholder, a fictitious / bogus person, irrespective of whether consent was obtained from the proposer or the existing policyholder.
2. Forging on other documents such as application for policy loans,surrender discharge voucher, with or without the consent of the policyholder.
What is Signature ForgerySignature Forgery?A person who forge a policyholder’s or proposer’s signature with the intention of causing the Company to believe that the document was signed by the policyholder or proposer.
PEP Year 1 – M2 (eModule)
No of Cases Registered from January 2008 to December 2010
23%142332009
27%243662010
26%511133Total
26%126342008
%Total No. of ComplaintsNo. of cases receivedYear
Penalties imposed on agents upon completion of investigation.
49
9
11
29
No case
13
-
-
13
Pending
Investigation
133
34
33
66
No. of cases
received
59Total
252008
222009
122010
Terminated/
Warning
Year
Signature Forgery Signature Forgery -- StatisticStatistic
PEP Year 1 – M2 (eModule)
We received a complaint from a policyholder alleging that some one had
forged her signature on Surrender Discharge Voucher.
Our Company had received a request for surrender of policy and had proceeded to process the request. When the policyholder received the surrender value, she was dissatisfied with the amount and had claimed that she was entitled to full refund as policy was still under free look period. That was when she had discovered that her signature was forged on the Surrender Discharge Voucher.
Our investigation revealed that the surrender voucher was both signed and witnessed by the agent’s Immediate Officer (IO). The IO reverted claiming that his agent was new and both the agent and policyholder were not in town, the servicing agent had authorized the IO to proceed with the cancellation of the policy. To quicken the process, the IO had then forged the policyholder’s signature on the surrender voucher. The IO has misunderstood the refund and had submitted the request for surrender, not realizing that the request could be done under the Free Look period.
The consequence of the IO’s action had led to termination of his Agency
Agreement due to signature forgery, even though the IO had not benefited
money wise from his actions.
Signature Forgery Signature Forgery -- Actual InstancesActual Instances
PEP Year 1 – M2 (eModule)
No of Cases Registered from January 2008 to December 2010
17%142252009
12%243292010
13%51168Total
11%126142008
%Total No. of ComplaintsNo. of cases receivedYear
Penalties imposed on agents upon completion of investigation.
37
9
14
14
No case
5
-
-
5
Pending
Investigation
68
14
25
29
No. of cases
received
24Total
52008
112009
82010
Terminated/
Warning
Year
Misrepresentation of Facts Misrepresentation of Facts -- StatisticStatistic
PEP Year 1 – M2 (eModule)Misrepresentation of FactsMisrepresentation of Facts
Examples1. Telling policyholder that an investment-linked policy has
guaranteed returns with no risks.
2. Informing policyholder that Company will reimburse their claims before the Company assesses the claims.
What is Misrepresentation of FactsMisrepresentation of Facts?Providing false or misleading information or omits to provide material information during sales presentation, thereby inducing the prospect to take up the policy.
PEP Year 1 – M2 (eModule)
136
All rights reserved. No part of this publication may be produced ,translated, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying and recording without the prior written permission of the copyright the developer and owner.
End of Topic 4
Fraud Awareness & Agency
Conduct
PEP Year 1 – M2 (eModule)
•–
All rights reserved. No part of this publication may be produced, translated, stored in a retrieval
system or transmitted in any form or by any means, electronic, mechanical, photocopying and
recording without the prior written permission of the copyright the developer and owner.
PEP Year 1 – M2 (eModule)Sales Training FacultySales Training FacultySales Training FacultySales Training FacultySales Training FacultySales Training FacultySales Training FacultySales Training Faculty
Product Helpdesk (Chung Moun Hor) : 03-4259 8672
Chan Chye Mun
03-4259 [email protected]
Franco Wong Wai Keong
03-4259 [email protected]
Tutu Foong
03-4259 [email protected]
Email: [email protected]