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BNM AML/CFT enforcement · 2025–2026

One report nobody filed. RM560,000.

That's what a Malaysian bank paid BNM after staff missed the red flags on large cash withdrawals and no suspicious transaction report went in. A company secretary was fined RM50,000 for two more.

Nakhoda checks your AML/CFT programme against BNM's requirements and shows every gap, with the paragraph behind it.

Start free trial Check my AML risk first
For banks, insurers, MSBs and capital market firms Every finding cites the paragraph

2-minute AML risk check

1. If a transaction trips your red flags, does front-line staff know to escalate it for an STR?
2. Do you screen every customer and transaction against current sanctions lists?
3. When did you last refresh your enterprise-wide ML/TF risk assessment?

Answer all three to see your result. Nothing you click here is stored.

A quick indicator, not legal advice.

In production at a leading Malaysian fund manager Independent security audit passed Backed by Antler Malaysia
What BNM has fined for

The gaps that cost real money, in the last 18 months

Unfiled STR · announced Jan 2026RM560k

A bank that never filed a suspicious transaction report, though its own red flags fired.

CDD and sanctions · May 2025RM3.26M

A bank group with lapses in customer due diligence and sanctions screening.

Unfiled STRs · May 2026RM50k

A company secretary who failed to file two suspicious transaction reports.

Source: Bank Negara Malaysia enforcement announcements, 2025–2026.

Find the gap before the examiner does.

The old way

  • Re-read the policy document clause by clause, by hand
  • Hope front-line staff remember when an STR is due
  • Learn what's missing at the next BNM examination

With Nakhoda

  • Upload your AML/CFT policy and procedures
  • See each BNM requirement marked met, partial or gap
  • Ask "When must we file an STR?" and get the cited answer
See it work

Your policy, against BNM's, line by line.

AML/CFT gap check

aml-cft-programme-2026.pdf · BNM policy document for FIs
Illustrative
  • GapEnterprise-wide risk assessment not refreshedpara 10.1
  • PartialSTR escalation path not set out for front-line staffpara 22.3.2
  • PartialCustomer identification and verificationpara 14.1
  • MetCompliance officer appointedpara 9.1

Covers BNM's AML/CFT and TFS policy document for financial institutions and the SC's AML guidelines for capital market intermediaries.

The next STR you miss has a price.

Check your AML/CFT programme against BNM's requirements yourself, with the paragraph behind every gap.

Company secretary, lawyer or accountant? You have AML reporting duties too. Ask Nakhoda what you must report, with the provision cited.

Need team access, or Nakhoda deployed inside your own environment? Email [email protected].

Questions

Which AML rules does it cover?

Gap checks run against BNM's AML/CFT and TFS policy document for financial institutions and the SC's AML guidelines for capital market intermediaries. Professionals can ask about their own obligations; a gap check against the policy document for designated non-financial businesses is not available yet.

Is this legal advice?

No. Nakhoda shows you what the requirement says and where your documents fall short, with the paragraph cited so your compliance officer can check it.

Can it run inside our own environment?

Yes. Institutions can use it as SaaS or have it deployed inside their own environment. Uploaded documents stay in your own private workspace.