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May 18, 2023

You are a member of the anti-money laundering (AML) team of a regulated financial services firm operating in Malaysia. Part of your role involves signing off, at the client onboarding stage, high-risk and complex business relationships that the firm is considering. You have been advised that your firm is becoming more cautious about its risk appetite and wishes to de-risk some of its business activities.

A file on a potential new client has been referred to you for evaluation.

The potential client is Global Metals Trading Sdn. Bhd. (GMT). The client account-opening file contains the following summary:

  • GMT’s business activity is as a dealer in precious metals
  • the company’s head office is in Kuala Lumpur, Malaysia
  • there are two directors, C.K. Lee, and John Ma, both Malaysian nationals; C.K. Lee is a former politician in one of the states of Malaysia
  • the company is registered via a company service provider in Labuan
  • the ultimate beneficial ownership of the company is difficult to determine owing to a complex corporate ownership structure which makes beneficial ownership difficult to trace
  • GMT has been in business for three years and has doubled its turnover annually
  • GMT is seeking an investment of RM50 million.
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