(Slides) Module 2 - Customer Due Diligence Process

GROUP OF
COMPLIANCE OFFICERS
Module 2
Customer Due
Diligence
Process
(CDD)
Version 2.0
GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME 2
9:00 am Introduction & CDD
11:00 am Break
Training Agenda
11:30 am CDD (Continuation)
1:00 pm Lunch
CDD (Continuation)
2:00 pm
ECDD
3:30 pm Break
4:00 pm ODD
5:00 pm End
GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

3
Learning Objectives
• Covers the fundamental aspects of

the Customer Due Diligence (CDD)
Process, which is one of the main
principles in mitigating and managing
ML/TF risks to MSB.
• Provides in-depth understanding of

the CDD process, techniques to
perform effective due diligence on
customers and how to identify
suspicious activities.
4
Learning Outcomes
By the end of this module, participants will have

greater understanding of the CDD process
which includes:
• The importance of due diligence in managing

and mitigating ML/TF risks of the business
• The effective ways to perform due diligence in
identifying and verifying customers or
beneficial owners:
• Know when to obtain additional information
/ supporting documents on higher risk
customers / transactions
• Able to conduct ongoing monitoring to
identify irregular transactions patterns or
suspicious activities
• Able to implement ML/TF control measures
more effectively

5
 Definition Purpose Objective
General Introduction  Overall Overview
 Display of Notice Requirement
 What is CDD & When to conduct CDD

 Customer & Beneficial Owner (‘BO’)
 Processes - Types of CDD
CDD - Specific CDD
 Non Face to Face
- Sanction Screening Processes
 Inability to Complete CDD Exercise
 3rd Party Reliance
 What is ECDD & When to conduct ECDD

ECDD  Situation warrants conduct of ECDD
- PEPs
- Higher Risk Countries
 What is ODD & why it is needed?

 ODD Features
ODD  ODD Conduct
 ODD Tools
 3rd Party Reliance
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7
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Customer Due Diligence or CDD, is the process where relevant
information about the customer is collected [in assessing their
background to determine their identity] and evaluated [in
assessing the level of risk they possess] for any potential risk for
money laundering or terrorist financing or proliferation financing
activities. CDD is essential for KYC. The objective of CDD is to
enable MSB to understand the nature and purpose of customer
relationships, which may include understanding the types of
transactions which a customer is likely to engage. These
processes assist MSB in determining when transactions are
potentially suspicious.
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CDD is a regulatory
requirement
CDD REGULATORY REQUIREMENT

Section 16 AMLA
AML/CFT & TFS for Fis

Para 14C
RI (in this case) MSB
conduct CDD on customer (and BO)

10
Overall CDD Process monitor cost
in mitigating & managing ML/TF Risks next transaction
On-going Due
Red Flags CDD/ECDD
Diligence (ODD)
Pre-Transaction During Transaction Post Transaction
Develop Red Flags Implement CDD/ECDD Analyze transactions

measures
Identify parameters to detect • Monitor & check transactions
• CDD: Include identification &
customer transactions & are consistent with the
verification processes
behaviors that may trigger customer profile
suspicion for the purpose of: • ECDD: obtain additional info • Ensure customer info is up-to-
• Conducting ECDD and approval from senior date
• Reporting suspicious management • Review and update Red Flags
transactions*
Feedback loop to continuously improve the effectiveness of CDD implementation
*Note:
• Red Flags will be covered separately in Module 3
• Not all red flag triggers require a submission of STR

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CDD OVERVIEW - Customer Verification & Monitoring
Customer Verification Customer Monitoring
CDD ECDD ODD

Customer Due Enhanced Customer Due On-going Due
Diligence Diligence Diligence
Identify Customer & Beneficial Owner Continuously monitor the customer
• Face to face or electronic verification of • Back office monitoring after transaction is

customer, to know who MSB is dealing with performed
• Use transaction data from exception
• Identify & verify customer / beneficial owner’s report to form transaction patterns to
from acceptable ID in accordance to the identify and detect irregularities
respective limits or situations
• Review the customer’s ML/TF risks and to
address any ML/TF attempts
• Raise STR if there is basis of suspicion

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DISPLAY OF NOTICE
A requirement in conducting CDD
Para 14C.3
Requirement to display
notice (both physical &
digital) in a conspicuous
position at MSBs approved
premises in the format below
informing customers of the
CDD requirements

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 What is CDD?
 When to conduct CDD
 Customer & Beneficial Owner (‘BO’)
- Difference between Customer & BO
- Types of Customer & BO :-
(i) Individual
(ii) Legal Person :-
(a) Companies
(b) Legal Arrangement
(c) Clubs Societies Charities
- Meaning of ‘Existing Customer’
 Processes - Types of CDD:-
(a) Standard CDD
(b) Simplified CDD
- Specific CDD for:
(a) Money Changing / Wholesale of Currency
(b) Wire Transfer / Remittance
- Verification (and Delayed Verification)
- Non Face to Face
- Sanction Screening Processes
 Inability to Complete CDD Exercise & Issue of Tipping Off
 3rd Party Reliance
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Co need to decide Based
acceptable CD .
on co exercise
CDD Using reliable, independent source document, data or information,

MSBs are required to:
What action is required?
reliable and
g-
• Identify the customer & verify the customer’s identify;
Para 14C.4 independent
source of dox
• Verify that any person acting on behalf of the customer is so
authorised, and identify and verify the identity of that person;
• Identify the beneficial owner and take reasonable measures to

verify and verify the identity of the beneficial owner such that
Reporting Institution (‘RI’) [which is MSB in this case] is satisfied
that it knows who the beneficial owner is; and
• Understand, and where relevant, obtain information on the

purpose and intended nature of the business relationship.

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CDD
When to perform CDD?
Situations
Para 14C.1
• When establishing business relations, where applicable
• When providing money changing and wholesale

currency business
depend on the amount
• When providing wire transfer/remittance services
• When in suspicion of ML/TF activities regardless of the

amount transacted, or
• When in any doubt about the accuracy or adequacy of

previously obtained information need to updated

CDD
Individual Customer
MSB shall require individual customers
to produce acceptable IDs for CDD
verification.

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CDD
Beneficial Owner
Refers to any individual who ultimately owns or
controls the company or another individual on
whose behalf a transaction is being conducted.

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CDD
on Beneficial Owner – Individual
For Representative or Authorised Person
On Behalf Transactions
• Perform CDD on the representative
• Identify the beneficial owner

• Take reasonable measures to verify the identity of the
beneficial owner using relevant information or data obtained
from a reliable source and obtain information on, the purpose
and intended nature of the business relationship (when
necessary)

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CDD For Individual
Who is Beneficial Owner? • The BO is the person on whose behalf a transaction is

conducted
For Company
• The BO is the natural person(s) who ultimately own or control

the company
• Through direct or indirect ownership; or
• Shareholders / Directors with equity interest of 25% the
company
For Legal Arrangement*
• For trusts, the settlor, the trustee(s), the protector (if any), the
beneficiary or class of beneficiaries, and any other natural
person exercising ultimate effective control over the trust
(including through the chain of control/ownership);or
• For other types of legal arrangements, the persons in equivalent
Beneficial Owner (BO)
or similar positions
*such as foundations, and legal arrangements such as trusts which administer
and distribute funds

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CDD – Customer Identification
Types of Customers / Persons
Natural Person Refers to an individual
Legal Person Refers to companies, corporate bodies or others similar entities
Authorised Person Refers to any individual authorized to perform transaction on

behalf of the companies
Beneficial Owner Refers to
Beneficial Owner(s) • Individual who owns or controls a company Beneficial Owner(s)
• Individual on whose behalf a transaction is being conducted
Beneficiary Can either be an individual, company or arrangement
Legal Arrangement Refers to trusts or similar arrangements

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LEGAL PERSONs Para 14C.10.4 to Para 14C.10.11
1. For customer who is a legal person, RI needs to understand customer’s :-
(i) business
(ii) ownership
(iii) control structure
2. RI needs to identify and verify customer based on :-

(i) Identity : name, legal form (and proof of existence)
(ii) Powers : those regulate and bind customer + names of persons having Senior Management position
(iii) Address : Registered Office & Principal Place of Business
3. RI needs to identify & verify person authorised to represent customer (in this case – the Legal Person).
How? When dealing with such person, through:-
(i) Letter of Authority or
(ii) Directors’ Resolution
4. Identification & verify BO following this sequence:-

(i) Identity of Natural Person [He who ultimately control ownership interest in Legal Person. At minimum, this
includes identifying directors / shareholders having equity interest of >25% / partner]
(ii) Whenever in doubt person with controlling ownership is [(i) above] or (where no natural person exert control over interest
ownership), identify the natural person exercising control of Legal Person through OTHER means
(iii) Where there is no natural person identified through (i) and (ii) above, identify relevant natural person holding Senior
Management position
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LEGAL PERSONs (continue)
5. Whenever in doubt of identity of persons in (Item 2 to 4 in Slide 23), RI shall:- winding up / dissolution
(i) conduct BACKGROUND basic search (or inquiry). Purpose to ensure the person is not:-
(a) under dissolution
(b) under liquidation
(c) a bankrupt
(ii) verify authenticity of information provided by the person with *SSM, *LFSA or any other authority
• SSM – Companies Commission of Malaysia

• LFSA – Labuan Financial Services Authority
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SUMMARY : CDD on Legal Person(s)
Identify & Verify For Sole-Proprietorship / Partnership
For Company For Sole-Proprietorship / Partnership
• Certificate of incorporation Form 24

At Entity Level / Form 49
• Name of the company • Memorandum & Articles of • Business Registration Certificates
• Legal Form / proof of existence Association (From A / B)
• Address of the registered office • Business License [for WCB} • Business License (Form D)
• Principal place of business • ID of Directors
• Form 24
• Form 49
[Note:
Name of Forms have changed name for
companies incorporated under
Companies Act 2016]
At Individual Level
• ID of the Sole-proprietor or partners
• Identity of beneficial owners and • Letter of authority
• Letter of authority or directors’ • ID of authorized persons
authorised persons resolution
• ID of authorised persons
If in Doubts
*Or Corporate profiles obtained from SSM as per Q52 of FIED FAQ
Where there is any doubt as to the • Conduct a basic search or enquiry on the background
identity of the persons • Verify the authenticity of the information with SSM or other relevant agencies

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Samples of Director’s Details
SSM Corporate Profile

SSM Corporate Profiles can be accepted as
an alternative document to identify and verify
Legal Persons (Q52 FAQ)
Shareholders Details
Corporate Details

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Companies Exempt Verification MSBs are being exempted from verifying the Legal Person’s :-
Para 14C.10.9 (i) Directors; and
(ii) Shareholders
for Legal Person(s) that fall under the following category:-
• Public listed companies or corporations listed in Bursa Malaysia;

• Foreign public listed companies:-
MSBs are exempted from obtaining a copy of the:
(i) listed in recognised exchanges; and
(ii) not listed in higher risk countries
(i) Certificate of Incorporation; or
• Foreign financial institutions that are not from higher risk countries;
(ii) Constitution
• Authorised person under FSA and IFSA (ie any person that has been
granted a license or approval)
• Persons licensed or registered under Capital Markets & Services Act
2007
• Licensed entities under the Labuan Financial Services & Securities
Act 2010 and Labuan Islamic Financial Services & Securities Act
2010;
• Prescribed institutions under DFIA
• Licensed entities under MSBA
Notwithstanding above, RI must identify and maintain information relating to identity of directors & shareholders of
Legal Person referred to under Para 14C.10.9. How? Through public register, other reliable sources or based on
information provided by customer

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CDD
Legal Arrangement:
e.g. Trust Para 14C.10.12 to 16
For customers that are legal arrangement, MSBs are required
to understand:-
(i) Nature of customer’s business;
(ii) Its Ownership; and
(iii) Control structure

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CDD on Legal Arrangement
RI needs to identify and verify CUSTOMER through:-
(i) Name;
Legal form + proof of existence ; or
Any reliable references to verify the identity of the customer.
(ii) Power – that regulate & bind customer (as well as names of relevant having Senior Management position; and
(iii) Registered Office address + Principal Place of Business Address
RI needs to identify and (take reasonable measure to) verify BENEFICIAL OWNER through:-
(i) For TRUST - identity of settlor

- identity of trustee(s)
- identity of protector(s) [if any]
- identity of beneficiary or class of beneficiaries
- identity of any natural person exercising ultimate effective control over TRUST (including through chain or ownership)
(ii) For other types of legal arrangement(s)
- identity of persons in equivalent or similar positions

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CDD on Legal Arrangement (continue)
In situation where it is not

practical to identify every
YES
beneficiaries, can MSB rely on 3rd
Party to verify identity of
beneficiaries?
but RI need to
comply with Para 16
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CDD on
Clubs, Societies
and Charities Para 14C.10.17 to Para 14C.10.19
Organizations which are set up to provide
services to its members and general public
registered with the Registry of Society (ROS)

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1. RI shall conduct CDD and require customer to furnish relevant information including:-
(i) Certificate of Registration; and
(ii) Constituent documents
2. RI needs to identify and verify:-

(i) Office bearer;
(ii) Any person authorised to represent the customer
3. RI needs (take reasonable measures) to identify and verify Beneficial Owners of customer
4. When in doubt on identity of persons mentioned above, RI shall verify the authenticity of the information
provided with:-
(i) ROS – Registrar of Societies
(ii) LFSA – Labuan Financial Services Authority
(iii) SSM – Companies Commission of Malaysia
(iv) LAD – Legal Affairs Division under Prime Minister’s Department
(v) Any other relevant authority
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Para 14C.15
Definition of ‘Existing Customer’

Those who are customers PRIOR to CDD obligations under *S16 AMLA becoming applicable to RI. AMLA
came into force on 15.1.2002. So, it refers to customers prior to 15.1.2002.
What to do with these customers?

Apply CDD requirement on them on the basis of MATERIALITY & RISK
How to assess materiality and risk? Consider the following:-

(i) nature and circumstances surrounding the transaction
(ii) material change on the way account/business relationship operate
(iii) insufficient customer’s information
(iv) change in customer’s information
What to do with these customers now? Conduct CDD on such existing relationships.
WHEN? At appropriate times
WHAT aspect to consider?
(i) Whether and when CDD measures have (previously) been undertaken
(ii) Adequate data obtained
*Section 16 AMLA is on CDD requirement
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Full name Date of
How to IDENTIFY Customer & BO? birth
ID Number
Para 14C.10
By obtaining at least NINE (9) of Residential

AND
the following information. Mailing
Contact Address
Number
(home, office/
RI is REQUIRED to verify the mobile)
Customer and/or
identity of Customer & BO
BO Purpose of
Name of Transaction
Employer/
Nature of
Employment/
Guidance – sample CDD Form Nature of
business
[See Appendix 2 of AML/CFT & Occupation Nationality
TFS for Fis] Type

34
Para 14C.11.4
RI may conduct simplified CDD where ML/TF risks are assessed as LOW
Pre-Condition
-Need prior BNM approval
Condition(s)
(i) analyse ML/TF risks ADEQUATELY
(ii) established mechanisms and internal controls for effective on going monitoring of
customer & transaction [ensuring prompt detection of unusual / suspicious transactions]
(iii) BOD approval for simplified CDD implementation
(iv) periodic review on ML/TF risks
5 Information required for Simplified CDD (on customer and BO)

(i) full name
(ii) Nric No./Passport No./reference No. of any other official document
(iii) residential and/or mailing address
(iv) Date of Birth
(v) nationality
35
Para 14C.12
Introduction
It is CDD conducted on specific type of transaction, namely:-
(i) Money Changing & Wholesale of Currency
(ii) Wire Transfer / Remittance Business
Money Changing & Wholesale of Currency Wire Transfer / Remittance Services

6 CDD Information required for transaction between
RM3K to RM10K:- 6 CDD Information required for transaction below
RM3K:-
(i) Full name (i) Full name
(ii) Nric No./Passport No./reference No. of any other (ii) Nric No./Passport No./reference No. of any other
official document official document
(iii) Residential and/or mailing address (iii) Residential and/or mailing address
(iv) Date of Birth (iv) Date of Birth
(v) Nationality (v) Nationality
(vi) Purpose of transaction (vi) Purpose of transaction
For transaction RM10K and above – Conduct For transaction RM3K and above – Conduct
Standard CDD (see slide 34) Standard CDD (see slide 34)
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VERIFICATION
What does it mean?
Para 14C.6 - 9
What is ‘VERIFY’?
An act of making sure that (in this case – issue of identity of customer or BO) is true, accurate and
justified.
Verify AGAINST what?

Reliable & independent:-
(i) Documentation;
(ii) Electronic Data;
(iii) Other measure(s) [RI deems necessary].
To what EXTEND should the verification be?

- RI to decide based on (and commensurate with) ML/TF risks identified
WHEN to do it (verify identity of Customer & BO)?

Before or during:-
(i) establishing business relationship; or
(ii) conducting transaction (for occasional customer)
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DELAYED Para 14C.11.6
VERIFICATION
Can be done? Yes
When?
RI may complete verification WHEN:-
(i) ML/TF risks assessed LOW; and
(ii) verification not possible (at the point of establishing business relationship)
Conditions to be SATISFIED
(i) Delayed verification must be as soon as reasonably practicable [not more than 10 working days]
(ii) Delay is essential (so as not to interrupt RI normal conduct of business)
(iii) ML/TF risk are effectively managed [adopt RISK MANAGEMENT PROCEDURES]
(iv) No suspicion of ML/TF risks
Measures to manage risks of delayed verification

RI can limit:-
-number of transaction
-types of transaction
-amount of transaction
38
CDD
Para 14C.16
Non Face-to-Face Business Relationship
RI may establish NF2F business relationship provided:-
(i) Obtained BOD’s approval prior to implementation of

NF2F relationship
(ii) Obtained prior approval from BNM to implement NF2F

[for online/mobile remittance & money changing]
(*BNM has the right to revoke Para 14C.16.16)

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MEASURE(s) to IDENTIFY & VERIFY customer’s identity
Para 14C.16.10
(i) established independent contact with customer Verify again+ reliable source
(ii) verify customer’s information against reliable & independent sources to confirm his identity &
identifying known (or suspected) ML/TF risks associated with customer
(iii) request, sighting and maintain records (of additional documents) in customer verifications
40
NF2F Requirement(s) for Remittance & Money
Changing transaction Para 14C.16.14
(i) ONLY transact with individual who has a bank account
(ii) robust and appropriate IT security control measures in place

[linking customer’s account to only one mobile device – authenticating purpose] *
*BNM may impose specific controls deem appropriate
41
ADDITIONAL requirement (for Remittance transaction) Para 14C.16.15
(i) Individual Customer (including Expatriate)
Total daily transactional limit not more than RM30K
(ii) Individual Customer (foreign worker)
Total monthly transactional limit : not more than RM5K Foreigner stay at
hotel
AND use address of
hotel
-funds only remitted to home country
-beneficially must be pre-registered by customer with RI during establishment of business relationship
-RI must have proper internal process
[including: -appropriate control & procedures in place to attend to customer’s request to change/alter pre-
registered beneficiaries (and its monitoring procedure to identify suspicious pattern)]
42
TARGETED FINANCIAL SANCTIONS
These are measures for asset freezing and prohibitions to prevent funds or other
assets from being made available, directly or indirectly, for the benefit of
specified entities / designated persons who are being sanctioned.
43
Terrorism Financing Proliferation Financing Other UN Sanctions Regimes
Act of providing financing to Act of providing funds or Any other United Nation
terrorist acts and for terrorist financial services which are Sanctions Committee
and terrorist organisations, used, in whole or in part for the (UNSC) sanctions regimes
through legitimate or manufacture, acquisition, in relation to upholding of
illegitimate sources possession, development, peace and security, and
export, trans-shipment, prevention of armed
brokering, delivery and related conflicts and human right
material (including technologies violations.
and dual use goods used for
non-legitimate purposes), in
contravention of national laws
or, where applicable,
international obligations.
Para 27 Para 28 Para 29
44
TARGETED FINANCIAL SANCTIONS on
TERRORISM
FINANCING
Para 27
45
Financing of:-
- terrorist acts;
- terrorists;
- terrorist organizations.
46
Al-Qaeda
Key areas of Afghanistan / Pakistan
Terrorism Activities Taliban
Islamic State Afghanistan
Iraq / Syria
Abu Sayyaf
Boko Haram
Philippines
Nigeria
Jemaah Islamiyah
Indonesia

47
INTRODUCTION
Definition
Customer
(i) Beneficial Owner
(ii) Beneficiary
Domestic List
Name and Particulars of SPECIFIED ENTITIES declared by Minister of Home Affairs under subsidiary
legislation made under Section 66B(1) AMLA
Related Party
(a) Person related to :-
(i) Properties Wholly /Jointly by
or SPECIFIED ENTITY
(ii) Funds
Controlled (directly/indirectly) by
On behalf of
(b) Person acting Or SPECIFIED ENTITY
At direction of
(
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INTRODUCTION (continuation)
UNSCR List
Refer to who?
Those whose names
and particulars
designated by UNSC /
relevant Sanctions
Committee
Which are deemed as

Bad SPECIFIED ENTITIES by virtue
guy of Section 66C(2) AMLA
Note:
UNSC = United Nation Security Council
UNSCR = United Nation Security Council Resolutions
49
What RI needs to do?
Needs to keep updated with relevant UNSCR including:-
UNSCR 1267 (1999) New UNSCR published

in UN website
UNSCR 1373 (2001)
UNSCR 1988 (2011)
UNSCR 1989 (2011)
UNSCR 2253 (2015)

+
What are these UNSCR list about?
Sanctions against individuals and entities belonging/related to:-
(i) Taliban
(ii) ISIL (Da’esh)
(iii) Al- Qaida
50
MAINTENANCE OF SANCTIONS LIST Domestic List
RI needs to maintain the following lists:-
RI needs to keep updated Domestic List published
UNSCR List in Gazette
RI needs to maintain sanction database on UNSCR List RI to maintain sanction database on Domestic List
RI ensure information in database updated (effected RI ensure information in database updated

(effected without delay upon publication in
without delay upon publication in UN website)
Gazette)
Consolidated UNSCR List can be found in Consolidated Domestic List can be found in
http://www.un.org http://www.federalgazette.agc.gov.my
List shall remain in database until specified entities List shall remain in database until specified entities
delisted (published in UN website) delisted (published in Gazette)
BNM will queries are the list

updated
51
SUMMARY
What RI needs to do?
(1) Keep updated with relevant UNSCR relating to combating the financing of terrorism
[See the list in Para 27.2.1]
(2) Maintain Sanctions List [Para 27.3.1- Para 27.3.9]

(a) UNSCR List
(b) Domestic List
(3) Other requirement(s) [Para 27.3.10 – Para 27.3.12]

(a) Must ensure information contained in sanctions database is COMPREHENSIVE & easily ACCESSIBLE
(b) May MONITOR & CONSOLIDATE other countries’ unilateral sanctions lists
(c) May consider electronic subscription services [to ensure prompt updates on sanctions database]
either subscribe or download
52
Sanctions Screening on Customer
Sanctions Screening on Customers [Para 27.4]

Screen who?
-Existing Customers
-Potential or New Customers
Screen against?
-Domestic List
-UNSCR List
Screen (without delay) for?

-Positive name match in RI’s entire customer database
53
Step 1
Conduct on who? Customer [existing, potential or new] to see if customer is specified entity or
related parties
Conduct against what? To see if got positive name matched against :-

- Domestic List
- UNSCR List
When to conduct? During

- CDD process; and
- ODD process
What to do if customer’s name positive matched?
54
Step 2 : Make sure it is TRUE POSITIVE (true match)
How to make sure it is TRUE POSITIVE? [eliminate FALSE POSITIVE]
RI must make further inquiries for:-
- Additional information
- Additional identification documents
Get additional information and/or identification documents FROM:-

- Customer
- Counter Party
- Credible Source
- Direct inquiry with FIED (BNM) on whether customer is SPECIFIED ENTITY (for similar/common name situation)
55
STEP 3 : ACTION [if TRUE POSITIVE]
Do the following IMMEDIATELY WITHOUT DELAY

(i) FREEZE (customer’s funds)
(ii) BLOCK transactions
If customer is potential customer - REJECT
Purpose : Prevent Fund Dissipation
STEP 4 : REPORTING
- Immediately report to FIED & Inspector General of Police

- Immediately report STR
56
PROLIFERATION
FINANCING
Para 28
57
INTRODUCTION
Definition
Customer
(ii) Beneficiary
UNSCR List
Name and Particulars of persons designated by UNSC (or its relevant Sanctions Committee) deemed
DESIGNATED PERSONs under Strategic Trade Act 2010 (STA)
Related Party
(a) Person related to :- Wholly /Jointly owned by
(i) Funds DESIGNATED
or PERSON
(ii) Financial Assets Controlled (directly/indirectly) by
(iii) Economic Resources
(b) Person acting On behalf of

Or DESIGNATED PERSON
At direction of
(
58
RI needs to MAINTAIN SANCTION LIST
(i) Keep updated list

of countries and persons designated as restricted end-users and prohibited end users under STA
[in accordance with relevant UNSCR for the prevention of proliferation of weapons of mass destruction]
(ii) Keep updated on new decisions of UNSCR (or its relevant Committee) See Appendix 6
(iii) Maintain sanctions database
(iv) Ensure information in sanctions database is updated (and effected without delay upon publication)
(v) Refer to Consolidated UNSCR List UN website : http://www.un.org
(vi) List maintain until delisting of designated country or person as published in UN website
(vii) Ensure information in database is COMPREHENSIVE & EASILY ACCESSIBLE by staffs
Implementation of Counter PF Compliance Programme Para 28.9
RI is required to implement into AML/CFT Compliance Programme

Purpose – countering Proliferation Financing & Proliferation of Weapons of Mass Destruction
59
Step 1
Conduct on who? Customer [existing, potential or new]

- UNSCR List

- CDD process; and
- ODD process
60

- Customer
- Counter Party
- Credible Source
- Direct inquiry with FIED (BNM) on whether customer is DESIGNATED PERSON (for similar/common name
situation)
Related Party
- RI needs to examine & analyse past transactions of DESIGNATED PERSON and related party
- RI needs to maintain record of analysis
61

(i) FREEZE (customer’s funds, other financial assets and economic resources); or
Purpose : Prevent Dissipation of funds, financial assets & economic resources
STEP 4 : REPORTING
- Immediately report to FIED on detection, freezing, blocking, rejection action

[To report, use form in Appendix 8a]
- Periodic Reporting : where RI in possession or in control of frozen or blocked funds or
financial assets or economic resources on any changes to the same
[To report, use form in Appendix 8b]
Note: RI does not need to submit report on customer who conduct one off transaction
-STR on:
(i) Related Transaction
(ii) Attempted Transaction
62
OTHER
SANCTION(S)
Para 29
63
INTRODUCTION
Definition
Customer
(ii) Beneficiary
UNSCR List
Name and Particulars of persons designated by UNSC (or its relevant Sanctions Committee) deemed
DESIGNATED PERSONs under relevant Central Bank of Malaysia Act 2009 (CBA) regulations
Related Party
(a) Person related to :- Wholly /Jointly owned by
(i) Funds DESIGNATED
or PERSON
(ii) Financial Assets Controlled (directly/indirectly) by
(iii) Economic Resources
(b) Person acting On behalf of

Or DESIGNATED PERSON
At direction of
(
64
RI needs to MAINTAIN SANCTION LIST
(i) Keep updated list

of countries and persons under CBA Regulations [in accordance with relevant UNSCR relating to upholding of peace &
security through prevention of armed conflicts and human rights violation]
(ii) Keep updated on new decisions of UNSCR (or its relevant Committee) See Appendix 7
(iii) Maintain sanctions database
(iv) Ensure information in sanctions database is updated (and effected without delay upon publication)
(v) Refer to Consolidated UNSCR List UN website : http://www.un.org
(vi) List maintain until delisting of designated country or person as published in UN website
(vii) Ensure information in database is COMPREHENSIVE & EASILY ACCESSIBLE by staffs
65
Step 1
Conduct on who? Customer [existing, potential or new]

- UNSCR List

- CDD process; and
- ODD process
66

- Customer
- Counter Party
- Credible Source
- Direct inquiry with FIED (BNM) on whether customer is DESIGNATED PERSON (for similar/common name
situation)
Related Party
- RI needs to examine & analyse past transactions of DESIGNATED PERSON and related party
- RI needs to maintain record of analysis
67

(i) FREEZE (customer’s funds, other financial assets and economic resources); or
Purpose : Prevent Dissipation of funds, financial assets & economic resources
STEP 4 : REPORTING
- Immediately report to FIED on detection, freezing, blocking, rejection action
:
[To report, use form in Appendix 8a]
- Periodic Reporting : where RI in possession or in control of frozen or blocked funds or financial assets
or economic resources on any changes to the same
[To report, use form in Appendix 8b]
Note: RI does not need to submit report on customer who conduct one off transaction
-STR on:
(i) Related Transaction
(ii) Attempted Transaction
68
FAILURE to
satisfactorily
complete CDD
What can/must RI do?
69
CDD - Failure to satisfactorily complete CDD
Para 14C.17
RI SHALL NOT
- Open account;
- Commence business relation;
- Perform any transaction [potential customer]
RI SHALL
- Terminate business relations [existing customer]
MUST CONSIDER TO SUBMIT STR under Para 22

70
35. (1) Any person who—
TIPPING
(a) knows or has reason to suspect that an investigating
officer is acting, or is 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
OFF
any subsidiary legislation made under it and discloses
to any other person information or any other matter
which is likely to prejudice that investigation or
proposed investigation; or
(b) knows or has reason to suspect that a disclosure has
been made to an investigating 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,
An offence under Section 35 of AMLA
commits an offence and shall on conviction be liable to a
fine not exceeding three million ringgit or to
imprisonment for a term not exceeding five years or to
both.
71
RI suspicious of ML/TF + REASONABLY believes by performing CDD
would TIP OFF customer
What can RI do?
RI is PERMITTED to pursue CDD process
RI is to DOCUMENTED basis of not able to complete CDD
RI is to IMMEDIATELY file STR under Para 22
Note:
RI is allowed to continue transaction for the PURPOSE of making further
inquiry/investigation on ML/TF suspicion
72
RELIANCE ON 3RD PARTY to conduct CDD
Para 16
Allowable?
Yes
Who bears burden of CDD responsibility & accountability?

RI
What RI needs to have?

Internal policies & procedures to mitigate risk on 3rd party’s reliance [including those from AML/CFT deficient
jurisdictions posing ML/TF risks]
Which 3rd Party country RI CANNOT rely on?

Those identified in Para 17
73
RELIANCE ON 3RD PARTY to conduct CDD (cont)
Para 16
Governing Relationship between RI and 3rd Party Para 16.5
-Arrangement must clearly specifies rights, responsibilities & expectations
-At MINIMUM, RI must be able:-
(i) obtain (immediately) all CDD information required under Para 14

[can be done through written confirmation that 3rd Party has conducted CDD in accordance to Para 14];
(ii) to be REASONABLY SATISFIED that 3rd Party :-

(a) has adequate CDD processes;
(b) has record keeping measure in place;
(c) is able to IMMEDIATELY produce CDD information & relevant document (upon request)
(d) is properly regulated & subjected to AML/CFT supervision authority
[can be done through attestation from 3rd Party]
74
75
What is ECDD
When to conduct ECDD
Situation warrants conduct of ECDD:-

- PEPs
- Higher Risk Countries
76
Enhanced Customer Due
Diligence (ECDD) is the CDD
process of gathering data and
information to verify the identity of
customers, but with additional
information required to mitigate the
risk associated with them.
77
Para 14C.13 WHEN is ECDD required?
RI is required to perform ECDD where ML/TF risks are
ASSESSED as higher risk
ECDD shall involve the following:

(i) Obtaining CDD information under Para 14C.10
(ii) Obtaining additional information on customer & BO
(iii) Inquire source of wealth or source of funds [PEP needs both]
(iv) Obtaining *Senior Management approval before establishing (or continuing – for existing customer)
business relationship
[*refers to Senior Management at Head Office]
In ADDITION, RI may also consider the following ECDD measure(s) in line with ML/TF risks identified:-
(i) Obtaining additional information on intended level of business relationship
(ii) Obtaining additional information on the intended level of nature of business relationship
(iii) Inquiring reason(s) for intended (or performed) transactions
(iv) Requiring 1st payment to be carried out through customer’s banking account subject to similar CDD
measures

78
ECDD – Supporting Documents
Example
Travelling Documents
such as:
Travel Itinerary Airline Ticket Visa
Business Documents
such as:
Invoice Purchases Order Delivery Note
Finance Documents
such as:
Salary Slip Payment Voucher Bank Statement Saving Passbook
Other Documents
such as:
Wining Tickets Sales Contract

79
Politically Exposed
Person
Para 15
See the list in Para 6.2

80
APPLICABILITY
Applicable to all types of PEP & family members or close associates (of those PEPs)
[Definition of PEP & family of PEP – see Para 6.2]
Definition of Close Associate

RI take reasonable measures to determine extent to which these individual are directly engaged (or
involved) in PEP’s activity
FOREIGN PEPs
 RI needs to put in Risk Management System [to determine whether customer/BO is PEP]
 Once determined positively – MUST conduct ECDD (as specified under Para 14C.13) and enhanced
ODD (under Para 14C.14.4)
DOMESTIC PEPs/person entrusted with prominent public function by an international organisation 

 RI must take reasonable measures to determine whether customer or BO is a domestic PEP/
 Once determined positively – RI must assess level of ML/TF risks posed by business relationship
[assessment needs to take into account customer profile on Risk Profiling]
 ECDD and Enhanced ODD must be conducted once risk assessed as higher risk
 CDD if RI satisfied risks assessed not as higher risk
CESSATION of PEP status

RI to consider the following factors:
(i) level of informal influence that PEP could still exercise
(ii) whether PEP (previous and current functions) (in official capacity/otherwise) linked to same substantive
matter
81
82
WHAT RI needs to know and do? Para 17
Conduct ECDD proportionate to risk, business relationships and transaction with any person from higher
risks countries (called for by FATF) or by Government of Malaysia
The FATF has identified jurisdictions with strategic deficiencies in their frameworks to combat money
laundering and the financing of terrorism and proliferation: high-risk jurisdictions subject to a call for
action (‘Black List’) and jurisdictions under increased monitoring (‘Grey List’)
BLACK LIST [High Risk Jurisdictions Subject to a Call for Action]

Countries that have significant strategic deficiencies in their regimes to counter money laundering, terrorist
financing, and financing of proliferation. For all countries identified as high-risk, the FATF calls on all members and
urges all jurisdictions to apply enhanced due diligence, and in the most serious cases, countries are called upon to
apply counter-measures to protect the international financial system from the ongoing money laundering,
terrorist financing, and proliferation financing (ML/TF/PF) risks emanating from the country.
Democratic People's Republic of Korea (DPRK) & Iran

[as at 21.2.2020]
83
GREY LIST [Jurisdictions under Increased Monitoring]
Jurisdictions under increased monitoring are actively working with the FATF to
address strategic deficiencies in their regimes to counter money laundering,
terrorist financing, and proliferation financing. When the FATF places a jurisdiction
under increased monitoring, it means the country has committed to resolve swiftly
the identified strategic deficiencies within agreed timeframes and is subject to
increased monitoring.
See the updated list of countries in February 2021. Find them here:-
https://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/increased-
monitoring-february-2021.html
84
Counter measures
● Limit business relationship or transactions with

ECDD - Higher Risk Countries identified countries or persons
● Submit annual report with summary exposure
(as specified by BNM)
● Conduct other measures specified by BNM
ECDD ● Review and amend, or if necessary terminate,
Blacklist (Automatic) correspondent banking relationships with
financial institutions in the country concerned
● Conduct enhanced external audit, by increasing
Apply counter the intensity and frequency, for branches and
measures subsidiaries of RI located in the country
proportionate concerned.
to risks
Grey List
Assess risks High Enhanced CDD applies
Low Normal CDD applies

85
Point(s) to NOTE
ECDD shall include any specific CDD measures imposed by FATF/Gov. of Malaysia
RI is required to apply counter measure [proportionate to the risks] when called upon to do
so by FATF/ Gov. of Malaysia
Counter measures includes :-

(i) limit business relationship
(ii) limit financial transactions
86
87
 What is ODD & why it is needed?
 ODD Features:-
- Measures
- Consideration
 ODD Conduct
 ODD Tools
 3rd Party Reliance
88
ODD
What is On-going
Due Diligence?
An ongoing monitoring of the business relationship
where transactions are continuously scrutinized
throughout the course of relationship to ensure that:
• the transactions being conducted are consistent with

the MSB’s knowledge of the customer, the business
and risk profile including, where necessary, the
source of funds; and
• Ensuring that the documents, data or information

held are up to date

WHY need to conduct ODD?
It is a requirement under Section 16(4) of AMLA
A reporting institution shall conduct ongoing due diligence on all accounts,

business relationships, transactions and activities.
90
RI needs to:-
1. Scrutinize Transaction (throughout course of business relationship)
WHY need to scrutinize?

To ensure transaction conducted is CONSISTENT with RI’s knowledge on:-
(i) Customer
(ii) Customer’s business
(iii) Customer’s risk profile
(iv) Customer’s source of funds
HOW frequent need to scrutinize transaction?

Frequency must COMMENSURATE with ML/TF risk level. ML/TF risk level is based on:-
(i) Customer’s risk profile
(ii) Customer’s nature of transaction
Enhanced ODD (Para 14C.14.4):-
2. Ensure [document, data & info] collected during CDD is :-
(i) kept up to-date
(ii) relevant (i) Increase number & timing of
[especially high risk customer] controls (to be applied); and
(ii) select patterns of transactions
(those that need further examination)
91
Look out for red flags Para 14C.14.2
In conducting on-going due diligence, MSBs

may take into CONSIDERATION the
economic background and purpose of any
transaction or business relationship which:
a appears unusual;
is inconsistent with the expected type of

b
activity and business model when compared
to the volume of transaction
c
does not have any apparent economic
purpose
d casts doubt on the legality of such

transactions, especially with regard to
complex and large transactions or involving
GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER higher risk customers.
EDUCATION PROGRAMME
92
How to Perform Ongoing Due Diligence?
Create Exception Reports in the MIS based on each MSB’s Red Flag parameters;
Sample Exception Reports
By Large Transaction ● Transaction value / frequency

Amount / Number ● Detect breaking of transactions
By Higher Risk
To detect ML/TF attempts
Countries / PEP How to detect irregular transaction
patterns
By Beneficiary Details Able to detect multiple senders sending
(For remittance service) to same beneficiary
● View Exception Reports from the MIS
Able to detect transactions that exceeds regularly;
By Customer Profile
customer’s profile ● Monitor irregular transaction patterns
from the relevant reports and identify
To identify attempts to avoid detection
By Delivery Channel
by using various transaction channels suspicious transaction activities.

93
Justify Suspicious Transaction
Once suspicious transaction is detected
during the ODD process
● Scrutinize customer transactions history
● Determine whether transactions performed are

consistent with the customer’s business and risk profile
● Verify supporting documents received during the

ECDD process and check whether it is consistent with
the purpose of transactions and the source of fund
Actions on justified suspicious transaction
If there is reasonable ground for suspicions, raised STR

and submit to FIED.

94
WHAT to keep? Para 24.1
● Accounts, files, business correspondence, documents relating to transactions [esp those
obtained through CDD process]
● Includes: ID verification document and analysis results
CDD ● Records maintained must remain up-to-date and relevant
Record Keeping ● Guide – documents kept must enable reconstruction of transaction & evidence for
prosecution of criminal activity
Para 24
Keep in WHAT form? Para 24.5
● In the form that is admissible as evidence in court pursuant to Evidence Act 1950
● Avail such record to supervisory authority(ies) / law enforcement agency in a TIMELY
manner
Keep for HOW long? Para 24.3

● At least SIX YEARS from:-
(i) completion of transactions;
(ii) termination of business relationship;
(iii) date of occasional transaction
Where ongoing investigation or prosecution started in Court:

-retain document as long until LEA informs that records are no longer required

95
Additional Requirement for MSB Where does the additional requirement need to be
Para 24.6 incorporated? In the RECEIPT of Transaction
What are the additional information

needed to be recorded? Wire Transfer (Remittance)
-RI’s name, business address & phone number

-Date of Transaction
Money Changing/Wholesale Currency -Receipt Serial Number
-Exchange rate offered;
-RI’s name, business address & phone number -Amount of funds to be remitted in ringgit and its equivalent
-Date of Transaction amount in foreign currency to be received by beneficiary;
-Receipt Serial Number -Name of originator (where applicable);
-Amount & type of currency exchanged by Customer -Name of beneficiary (where applicable);
-Amount & type of currency exchanged for; -Customer’s ID (where applicable).
-Exchange rate offered;
-fees & charges for services provided to customer;
-Name of customer (where applicable);
-Customer’s ID (where applicable).
96
ACCURATE
DATA
ENTRY
THE IMPORTANCE
97
Importance of accurate
data entry
During the CDD process
Customer data must be accurately keyed in the
MIS according to the ID and the information given

98
CDD
Importance of Accurate Data Entry
During Transaction
• To ensure customers are properly screened against the PEPs List
• To ensure customers are properly screened against the negative names or

sanction list in order to detect ML/TF attempts
• To ensure alert mechanism is bale to detect Red Flags attempts
After Transaction
• To establish accurate customer’s profile and transaction patterns

during the ongoing due diligence process
• To ensure that RBA results are accurate

99
MIS
Management Information System
100
RI must have :-
Adequate manual/electronic MIS to complement its CDD process

CDD
• MIS must be able to provide timely information on regular basis [Purpose –
Management Information to enable RI detect irregularities &/or suspicious activity]
System (MIS) • MIS must commensurate with:-

(i) nature, scale and complexity of RI’s activities; and
Para 25 (ii) ML/TF risk profile.
• MIS must (at minimum) shall be able to do the following:-

Nex Gen (i) Multiple transactions over a certain period;
(ii) Large transactions;
(iii) Anomalies in transaction patterns;
(iv) Customer’s risk profile;
(v) Transactions exceeding internally specified threshold
• MIS must be able to aggregate customer’s transactions from multiple

accounts and/or from different systems.
• MIS may be integrated with RI’s information system that contains customer’s
normal transactions or business profile which is accurate, up-to-date and
reliable
101
Management Information System (MIS)
• Sanction Lists • UNSCR 1267 / UNSCR 1988

ROBUST MIS Input Customer’s
• PEP Lists • List 66B / List 66C
Name
• Other Negative Lists • Domestic / Foreign PEPs
• OFAC / Own List / etc.
Input Nationality • Higher Risk • FATF Blacklist / Grey List

Countries • Own List of Higher Risk Countries
• Below RM3K • CDD Threshold Alerts

Input Amount
• RM3K to RM10K • Max Aggregate Daily Transaction Limit Alert
Data Entry • Above RM10k • Other Internal Limit Alert
Input Other Details • Red Flags Tracker • ECDD Alerts

Mechanism • Suspicious Transaction Alerts
RBA Mechanism Exception Reports Ongoing Due Diligence Record Retention
• Customer Profiling
• Irregular Transaction • Irregular Transaction • Mandatory Data Archiving
• High Risk / Medium Risk
Alerts Monitoring
/ Low Risk

102
NO
Can RI rely on 3rd Party to do ODD on
customers? Para 16.9
103
CDD Form
To facilitate in obtaining the information
of customers and beneficial owners

104
AMLA Anti-Money Laundering, AntiTerrorism Financing and Proceeds of Unlawful Activities Act 2001
AML/CFT & TFS Anti-Money Laundering, Countering Financing of Terrorism and Targeted Financial Sanctions for
for Fis Financial Institutions
BO Beneficial Owner
BOD Board of Directors
ID number Identification number
LEA Legal Enforcement Agency
MIS Management Information System
NF2F Non Face to Face
Para Refers to the specific paragraph in BNM Policy Document called Anti-Money Laundering,
Countering Financing of Terrorism and Targeted Financial Sanctions for Financial Institutions
PEP Politically Exposed Person
RI Reporting Institution
105
Kindly NOTE:-
Evaluation and
Assessment
(i) Programme Evaluation by participants
Please complete it at the end of Training
(ii) 40 minutes 30 MCQ exam
Secretariat will notify you the date of assessment

106
STATEMENT OF COPYRIGHT
All rights reserved. No part of this document may be reproduced, stored in a retrieval system or transmitted in any form by any means electronic,
mechanical, photocopying, recording or otherwise, without the prior written permission MAMSB. Use (by adoption or otherwise) of any part of this
document (in whole or in part) without the prior written permission of MAMSB shall be a violation of copyright.
Website http://www.mamsb.org.my
Telephone 603-7727 5808
Fax 603-7727 5008
E-mail [email protected]
Address Persatuan Perniagaan Perkhidmatan Wang Malaysia

(Malaysian Association of Money Services Business-MAMSB)
Unit 3A01, Lobby 1, 3A Floor, Block C, Damansara Intan No. 1, Jalan
SS20.27, 47400 Petaling Jaya, Selangor

107

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GROUP OF

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

• Covers the fundamental aspects of

• Provides in-depth understanding of

By the end of this module, participants will have

• The importance of due diligence in managing

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

 What is CDD & When to conduct CDD

 What is ECDD & When to conduct ECDD

 What is ODD & why it is needed?

CDD REGULATORY REQUIREMENT

AML/CFT & TFS for Fis

RI (in this case) MSB

conduct CDD on customer (and BO)

Develop Red Flags Implement CDD/ECDD Analyze transactions

Feedback loop to continuously improve the effectiveness of CDD implementation

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

Customer Verification Customer Monitoring

CDD ECDD ODD

Identify Customer & Beneficial Owner Continuously monitor the customer

• Face to face or electronic verification of • Back office monitoring after transaction is

• Raise STR if there is basis of suspicion

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

CDD Using reliable, independent source document, data or information,

• Identify the beneficial owner and take reasonable measures to

• Understand, and where relevant, obtain information on the

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

• When establishing business relations, where applicable

• When providing money changing and wholesale

• When providing wire transfer/remittance services

• When in suspicion of ML/TF activities regardless of the

• When in any doubt about the accuracy or adequacy of

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME 17

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

For Representative or Authorised Person

• Perform CDD on the representative

• Identify the beneficial owner

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

Who is Beneficial Owner? • The BO is the person on whose behalf a transaction is

• The BO is the natural person(s) who ultimately own or control

For Legal Arrangement*

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

Natural Person Refers to an individual

Legal Person Refers to companies, corporate bodies or others similar entities

Authorised Person Refers to any individual authorized to perform transaction on

Legal Arrangement Refers to trusts or similar arrangements

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

2. RI needs to identify and verify customer based on :-

4. Identification & verify BO following this sequence:-

• SSM – Companies Commission of Malaysia

For Company For Sole-Proprietorship / Partnership

• Certificate of incorporation Form 24

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

SSM Corporate Profile

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

• Public listed companies or corporations listed in Bursa Malaysia;

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME

GROUP OF COMPLIANCE OFFICERS AML/CFT TRAINING MODULES MEMBER EDUCATION PROGRAMME