CIMB GROUP HOLDINGS BERHAD (706803-D)

Location: 17th Floor, Menara CIMB, Jalan Stesen Sentral 2, 50470 Kuala Lumpur, Malaysia
CIMB Group Holdings Berhad is the Financial Holding Company of the Financial Group, as
defined and regulated under Malaysias Financial Services Act 2013, Islamic Financial Services
Act 2013 and the Anti-Money Laundering and Anti-Terrorism Financing Act 2001.
CIMB Group Holdings Berhad is listed on Bursa Malaysia Securities (stock code: 1023)
Anti-Money Laundering Questionnaire
The Attached Questionaire provides an overview of the Groups policies, practices and preventive efforts to combat
money laundering and the financing of terrorism. Where there is a conflict between the Groups policies and a foreign
reporting institutions regulatory requirements, the more stringent of the stringent requirement shall prevail.

I. General AML Policies, Practices and Procedures:

1. Is the AML compliance program approved by the FIs board or a
senior committee?
2. Does the FI have a legal and regulatory compliance program that
includes a designated officer that is responsible for coordinating and
overseeing the AML framework?
3. Has the FI developed written policies documenting the processes
that they have in place to prevent, detect and report suspicious
transactions?
4. In addition to inspections by the government supervisors/regulators,
does the FI client have an internal audit function or other
independent third party that assesses AML policies and practices on
a regular basis?
5. Does the FI have a policy prohibiting accounts/relationships with
shell banks? (A shell bank is defined as a bank incorporated in a
jurisdiction in which it has no physical presence and which is
unaffiliated with a regulated financial group.)
6. Does the FI have policies to reasonably ensure that they will not
conduct transactions with or on behalf of shell banks through any of
its accounts or products?
7. Does the FI have policies covering relationships with Politically
Exposed Persons (PEPs), their family and close associates?
8. Does the FI have record retention procedures that comply with
applicable law?
9. Are the FIs AML policies and practices being applied to all branches
and subsidiaries of the FI both in the home country and in locations
outside of that jurisdiction?
II. Risk Assessment
10. Does the FI have a risk-based assessment of its customer base and
their transactions?
11. Does the FI determine the appropriate level of enhanced due
diligence necessary for those categories of customers and
transactions that the FI has reason to believe pose a heightened risk
of illicit activities at or through the FI?

Yes
Y
Y

Y
Y
Y

Yes
Y
Y

Note 1: For ease of reference, the CIMB Groups AML/CFT policies, efforts and countermeasures have been
categorized based on the The Wolfsberg Group financial services industry principles and questionnaire for
Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies. All rights in relation to
the form and structure of the questions remain with the Group.

Page 1 of 7

No

No

III. Know Your Customer, Due Diligence and Enhanced Due Diligence
12. Has the FI implemented processes for the identification of those
customers on whose behalf it maintains or operates accounts or
conducts transactions?
13. Does the FI have a requirement to collect information regarding its
customers business activities?
14. Does the FI assess its FI customers AML policies or practices?
15. Does the FI have a process to review and, where appropriate,
update customer information relating to high risk client information?
16. Does the FI have procedures to establish a record for each new
customer noting their respective identification documents and Know
Your Customer information?
17. Does the FI complete a risk-based assessment to understand the
normal and expected transactions of its customers?
IV. Reportable Transactions and Prevention and Detection of
Transactions with Illegally Obtained Funds
18. Does the FI have policies or practices for the identification and
reporting of transactions that are required to be reported to the
authorities?
19. Where cash transaction reporting is mandatory, does the FI have
procedures to identify transactions structured to avoid such
obligations?
20. Does the FI screen customers and transactions against lists of
persons, entities or countries issued by government/competent
authorities?
21. Does the FI have policies to reasonably ensure that it only operates
with correspondent banks that possess licenses to operate in their
countries of origin?
V. Transaction Monitoring
22. Does the FI have a monitoring program for unusual and potentially
suspicious activity that covers funds transfers and monetary
instruments such as travelers checks, money orders, etc?
VI. AML Training
23. Does the FI provide AML training to relevant employees that
includes:
Identification and reporting of transactions that must be reported to
government authorities.
Examples of different forms of money laundering involving the FIs
products and services.
Internal policies to prevent money laundering.
24. Does the FI retain records of its training sessions including
attendance records and relevant training materials used?
25. Does the FI communicate new AML related laws or changes to
existing AML related policies or practices to relevant employees?
26. Does the FI employ third parties to carry out some of the functions
of the FI?
27. If the answer to question 26 is yes, does the FI provide AML training
to relevant third parties that includes:
Identification and reporting of transactions that must be reported to
government authorities.
Examples of different forms of money laundering involving the FIs
products and services.
Internal policies to prevent money laundering.
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Yes
Y

No

Y
Y
Y
Y

Y
Yes

No

Yes
Y

No

Yes
Y

No

Y
Y
Y
Y

Additional information:
1. Sanctions
As a responsible member of the international financial community, CIMB Groups policies
require its reporting institutions (RIs) to comply with:
1. International Sanctions by United Nations;
2. Sanctions and orders issued by the Government of Malaysias regulators and law
enforcement agencies (LEAs) or the RIs home country regulator;
3. Sanctions by other regulators or LEAs recognised by Malaysia; and
4. Restrictions on international transactions with:
other entities from countries that have been sanctioned by the US-OFAC, the
UK Treasury, the European Union (EU), particularly when dealing in
international currencies (e.g. USD, EUR, GBP); or
agent/ correspondent banks that adopt their own national or international
sanctions.
In relation to the High Risk countries, where the Financial Action Task Force (FATF)
has called for counter measures to be applied, CIMB Group entities will refrain from
entering into any business relationship, transaction (whether directly or indirectly) or
provide any financial services to designated persons or entities (designated persons)
including the governments, its agencies financial institutions and government linked
companies (GLCs) or persons or entities known to be controlled by such entities.
This would include non-residents, non-resident companies and non-resident controlled
companies, where ambiguity or opacity of beneficial ownership, may give rise to control
by such entities. Restriction on relationships are deemed to include the facilitation,
arrangement, facilitation of the entering into or continued participation in any transaction
or relationship, including but not limited to remittance services, correspondent banking,
agency or partnering agreements.
2. Correspondent Banking Accounts and Relationships:
Banking Reporting Institutions within CIMB Group do not permit third parties to directly
access nor use correspondent accounts to transact on behalf of others.
3. Contact Information:
For more information related to AML/CFT, sanctions or other information, please contact
the Group AML Office at:
General Line
: +603 2261 8888
Facsimilie Line (General/AML): :+603 2261 0251/ +603 2261 0249
Group AML Office Representatives:
Subramaniam Vayaravasamy, Vice President (subramaniam.vayaravasamy@cimb.com)
Andy Yew Choo Ying ,
Vice President (andy.yew@cimb.com)
Sugantha Muthukrishnan, Asst. Vice President (sugantha.muthukrishnan@cimb.com)
For specific entities within the Group, please contact the respective AML Compliance
Officer as listed in Appendix 1.

Page 3 of 7

Appendix 1
CIMB Group Reporting Institution

No.
1

Name of
Reporting
Institution
CIMB Group
Holdings
Berhad

Jurisdiction

Company Registration
Number

Anti-Money Laundering Compliance

Officer

Malaysia

706803-D

Geetha Sivapathasundram
geetha.sivapathasundram@cimb.com
Ang Swee Leong
sweeleong.ang@cimb.com

CIMB Bank
Berhad

Malaysia

CIMB Islamic
Bank Berhad

Malaysia

671380 - H

CIMB Factor
Lease Bhd

Malaysia

109053 - D

CIMB Bank (L)

Limited

Malaysia

LL00104 /
930009A (Licensed
Labuan Bank)

CIMB Bank
Berhad,
Labuan
Offshore
Branch

Malaysia

090100D (Licensed
Labuan Bank)

CIMB Trust Ltd

Malaysia

LL04054 (Co. No) /

LT0035 (Offshore
Bkg Licence No.)

Cheng Pau Yun

pauyun.cheng@cimb.com

CIMB Bank PLC

Cambodia

Co.1935E/2010

In Vansophea
vansophea.in@cimb.com.kh

CIMB Bank
Berhad,
Shanghai
Branch

China

310000500536146

10

PT Bank CIMB
Niaga Tbk

Indonesia

09.03.1.65.14394
(Regn No.) /
249544/U.M.II
(License No.)

11

CIMB Bank
Berhad,
Singapore
Branch

Singapore

S99FC5759D

CIMB Thai Bank

Public
Company
Limited

Thailand

12

13491 - P
Subramaniam Vayaravasamy
subramaniam.vayaravasamy@cimb.com

Baharudin Othman
baharudin.othman@cimb.com

Mary Tu Mei Ling

mary.tu@cimb.com

Xu Bin Amy
amy.xu@cimb.com

Juliana Amelia Nehat

Juliana.Nehat@cimbniaga.co.id

Wong Foong Har

foonghar.wong@cimb.com

0107537002338
(Bor Mor Jor.480)

Page 4 of 7

Thaphop Kleesuwan
thaphop.k@cimbthai.com

No.
13

Name of
Reporting
Institution
CIMB Bank
Berhad,
London Branch

Jurisdiction

Company Registration
Number

United
Kingdom

FC022225

CIMB Bank
Berhad,
Hong Kong
Branch

Hong Kong

F 20376

15

CIMB
Investment
Bank Berhad

Malaysia

18417 - M

16

CIMB Futures
Sdn Bhd

Malaysia

257674 - P

17

CIMB
Commerce
Trustee Berhad
(formerly
BHLB Trustee
Berhad)

Malaysia

313031 - A

18

CIMB Islamic
Trustee Berhad
(formerly CIMB
Trustee
Berhad)

Malaysia

167913 - M

19

CIMB Middle
East BSC

Bahrain

61558

20

CIMB
Investment
Bank Berhad,
Brunei
Darussalam

Brunei

AGO/RFC/731/06 (Reg Cert

of Co. Incorporated outside
Brunei Darussalam)

CIMB Principal
Asset
Management
Berhad

Malaysia

22

CIMB Principal
Islamic Asset
Management
Berhad

Malaysia

217841 - M

23

PT CIMBPrincipal Asset
Management

Indonesia

Reg Cert (Tanda

Daftar Perusahaan)
09.03.1.67.24923

CIMB-Principal
Asset
Management
(S) Pte Ltd

Singapore

14

21

24

Anti-Money Laundering Compliance

Officer
Helen Cai
helen.cai @cimb.com

Rosa Leung
rosa.leung@cimb.com

Tan Gua Hui

guahui.tan@cimb.com
Norhanizah Mohd Nor
hanizah.nor@cimb.com

Linda Ong Gaik Bee

linda.ong@cimb.com

Muhammad Bilal Aslam

muhammad.bilal@cimb.com

Rasydan Haji Nokman

Rasydan.nokman@cimb.com

304078 - K

Yap Ben Shiow

benshiow.yap@cimb-principal.com.my

200607208K

Page 5 of 7

Rudi Hermanto Sagala

rudi.sagala@cimb-principle.com.my

Neo Wei Chiat

weichiat.neo@cimb-principal.com.my

No.
25

Name of
Reporting
Institution
CIMB Principal
Asset
Management
Company
Limited

Jurisdiction

Company Registration
Number

Thailand

0105547164509

Anti-Money Laundering Compliance

Officer

Pornpimol Changariyawong
pornpimol.cha@cimb-principal.com.my

26

CIMB Insurance
Brokers Sdn
Bhd

Malaysia

38040-H

Mohd Zaidi bin Abd Rahim

zaidi.abdrahimow.yap@cimbprincipal.com.my

27

Touch 'n Go
Sdn Bhd

Malaysia

406400-X

Azhar Bin Shaharuddin

azhar.shaharuddin@touchngo.com.my

28

CIMB Securities
(Singapore)
Pte Ltd
(formerly
CIMB-GK
Securities Pte
Ltd)

Singapore

198701621D

CIMB Securities
International
(Australia) Pty
Ltd

Australia

CIMB Securities
Ltd
(formerly CIMB
Securities
(HK) Ltd)

Hong Kong

PT CIMB
Securities
Indonesia
(formerly PT
CIMB-GK
Securities)

Indonesia

32

CIMB Securities
(India) Pvt. Ltd

India

Co. Identification nos.

U65923MH2012PTC237343

33

CIMB Securities
Ltd, Korea
Branch

Korea

101-84-06802

34

CIMB (Private)
Limited

Sri Lanka

PV 82537

35

CIMB Securities
(USA) Inc.
(formerly
CIMB-GK
Securities
(US) Inc.)

United
States

5219 71703

29

30

31

Alvin Seah Kheng Seng

alvin.seah@cimb.com

ABN 84 002 768 701

Jane Lamming
jane.lamming@cimb.com

Cert. Incorporation
290697/Business
Regn. Certificate
14050536-000

Rosa Leung
rosa.leung@cimb.com

09.03.1.67.25789
Indriastuti Widi Utami
Indriastuti.Utami@cimb.com

Shishir Karnik
shishir.kamik@cimb.com
Tanny Kang
tanny.kang@cimb.com
Anarkali Moonesinghe
anarkali.moonesinghe@cimb.com

Helen Chin-Luk
helen.chinluk@cimb.com

Page 6 of 7

No.
36

Name of
Reporting
Institution
CIMB Securities
(UK) Ltd
(formerly
CIMB-GK
Securities
(UK) Ltd)

Jurisdiction

Company Registration
Number

United
Kingdom

0271 9607

Anti-Money Laundering Compliance

Officer

Helen Cai
helen.cai @cimb.com

37

CIMB Securities
Ltd, Taiwan
Branch

Taiwan

53665693

38

CIMB Securities
(Thailand) Co.
Ltd (formerly
BT Securities
Ltd)

Thailand

0105542081800

Carol Cheng
carol.cheng@cimb.com

Nakorn Lampaves
nakorn.La@cimb.com

Last Updated: March 17, 2014

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