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.