# AMLA Compliance for Malaysian Businesses: Reporting Institutions and DNFBPs

> Company secretaries, real estate agents, dealers in precious metals and other non-financial businesses are reporting institutions under Malaysia's AMLA. Here are the customer due diligence, record-keeping and suspicious-transaction-reporting duties owed to Bank Negara Malaysia's FIED.

- Category: business
- Language: en
- Status: published
- Updated: 2026-08-07
- Canonical: https://negaraku.md/en/business/amla-dnfbp-compliance-malaysia

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Anti-money-laundering law is not only a concern for banks. Under Malaysia's AMLA, a range of non-financial businesses and professions are also reporting institutions. A company secretary incorporating a company, an estate agent closing a property sale, or a dealer taking a large cash payment can each fall within the regime — with customer due diligence, record-keeping and reporting duties owed directly to Bank Negara Malaysia.

## Which non-financial businesses are covered?

The Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA) reaches beyond banks. BNM's policy document sets out the designated non-financial businesses and professions (DNFBPs) and non-bank financial institutions that are reporting institutions. The table below lists the main DNFBP categories; the policy document's applicability section (paragraph 3.3) also covers notaries public, licensed gaming outlets, moneylenders and pawnbrokers.

| Sector | Typical trigger activity |
| --- | --- |
| Company secretaries | Forming companies, acting as nominee or director |
| Lawyers and notaries public | Handling client money, property or company transactions |
| Accountants | Managing client assets or arranging transactions |
| Registered estate agents | Buying and selling real property for clients |
| Dealers in precious metals or stones | High-value dealing in gold, gems and jewellery |
| Trust companies | Administering trusts and client assets |
| Licensed casinos and licensed gaming outlets | Gaming, betting and wagering transactions |

## What rulebook applies?

The obligations are set out in BNM's policy document, **Anti-Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing and Targeted Financial Sanctions for DNFBPs and NBFIs (AML/CFT/CPF and TFS)**, issued on 5 February 2024 and effective from 6 February 2024. It applies a risk-based approach: the depth of your controls should match the money-laundering and terrorism-financing risk of each client and transaction.

## What are the core duties?

Three obligations sit at the centre of compliance:

- **Customer due diligence (CDD).** Identify and verify who the customer is, understand the purpose of the relationship, and identify the beneficial owner behind a corporate client. Higher-risk clients require enhanced due diligence.
- **Record keeping.** Keep CDD documents, transaction records and your risk analyses for **at least six years** after the transaction is completed or the business relationship ends. Records must be kept in a form admissible in court under the Evidence Act 1950.
- **Suspicious Transaction Reporting.** File a Suspicious Transaction Report (STR) whenever a transaction appears unusual, has no clear economic purpose, appears illegal, or points to money laundering or terrorism financing.

## How and when do you report?

An STR must reach FIED **by the next working day** after your compliance officer establishes the suspicion. You can submit by email or physical mail to FIED, and through the Financial Intelligence System (FINS) where applicable.

Two protections make reporting safer: AMLA overrides secrecy and confidentiality obligations so a report is not a breach of duty, and a person who reports in good faith is shielded from civil, criminal or disciplinary action. Deliberately splitting a transaction to dodge a reporting threshold is itself an offence under section 4A.

Note one common misconception: the **Cash Threshold Report** for cash of RM25,000 and above is not a DNFBP-wide duty. It falls only on banking institutions, selected development financial institutions, Lembaga Tabung Haji and the licensed casino.

## What's next

Appoint a compliance officer, adopt a written AML/CFT policy, and read BNM's 5 February 2024 DNFBP policy document in full before your next high-value engagement. If you are a company secretary or estate agent unsure whether a specific activity makes you a reporting institution, confirm with your professional body, or with BNM's FIED through the submission channels on BNM's "Reporting to Bank Negara Malaysia" page, rather than assuming you are outside the net.

## Sources

- AML/CFT/CPF and TFS for DNFBPs and NBFIs (policy document, issued 5 February 2024) — https://amlcft.bnm.gov.my/documents/6312201/13444269/pd-AMLCFTCPF-TFS-DNFBI-NBFI-Feb2024.pdf (Bank Negara Malaysia)
- Designated Non-Financial Businesses and Professions (DNFBPs) & Non-Bank Financial Institutions (NBFIs) — https://www.bnm.gov.my/dnfbp (Bank Negara Malaysia)
- Reporting to Bank Negara Malaysia (STR and CTR) — https://amlcft.bnm.gov.my/reporting-to-bnm (Bank Negara Malaysia)
- AML/CFT Policies — https://amlcft.bnm.gov.my/aml/cft-policies (Bank Negara Malaysia)
- Record Keeping — https://amlcft.bnm.gov.my/record-keeping (Bank Negara Malaysia)

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