On 10 June 2026, Bank Negara Malaysia (BNM) imposed administrative monetary penalties (AMP)[1] of RM132,000 on Standard Chartered Bank Malaysia Berhad (SCBMB) and RM132,000 on Standard Chartered Saadiq Berhad (SCSB) (collectively referred to as SCB) for failure to comply with targeted financial sanctions (TFS) requirements.[2]
As reporting institutions (RIs), SCB is required to update the sanctions database without delay upon publication of the Domestic List[3] and conduct sanctions screening on existing, potential or new customers against the Domestic List and the United Nations Security Council Resolutions (UNSCR) List[4] as part of its customer due diligence process. This is essential to protect RIs and the broader financial system from being abused for terrorism financing activities.
BNM discovered the breaches following an on-site supervisory examination on SCB. During the examination, it was found that SCB had failed to update its sanctions database without delay upon the publication of the Domestic List. This resulted in sanctions screening being conducted against an outdated database. Nonetheless, there were no specified entities[5] onboarded, and no transactions involving such entities were facilitated by SCB. These breaches were attributed to gaps in SCB’s sanctions screening controls, as well as deficiencies in ensuring that the screening process aligns with regulatory requirements.
SCB has since taken remedial measures to strengthen its controls and improve the effectiveness of its sanctions screening management, including strengthening oversight and enhancing the timeliness of its sanctions screening controls to ensure compliance with TFS requirements.
In deciding the AMP to be imposed, relevant aggravating and mitigating factors were considered. These include the severity of the breaches and SCB’s:
- lack of reasonable care in ensuring compliance with the TFS requirements;
- past compliance record; and
- post-misconduct behaviour, including the effectiveness of remedial measures to prevent recurrence of breaches.
On 15 June 2026, SCBMB and SCSB each paid RM132,000 for the AMP imposed by BNM.
BNM requires all RIs to maintain a high level of commitment in ensuring compliance with TFS requirements. BNM will not hesitate to take appropriate supervisory and/or enforcement actions should any RI fail to meet legal and/or regulatory requirements.
The enforcement actions taken against SCB is in line with the approach and processes outlined in BNM’s published Enforcement Approach.
[1] BNM imposed the AMP pursuant to section 234(3)(b)(i) of the Financial Services Act 2013 (FSA) and section 245(3)(b)(i) of the Islamic Financial Services Act 2013 (IFSA).
[2] For SCBMB, these requirements are set out under section 48(1)(a) of the FSA read together with paragraphs 27.3.5, 27.3.7 and 27.4.1 (read together with 27.4.4(a)) of the Anti-Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing and Targeted Financial Sanctions for Financial Institutions Policy Document (AML/CFT/CPF and TFS for FIs PD).
For SCSB, these requirements are set out under section 58(1)(a) of the IFSA read together with paragraphs 27.3.5, 27.3.7 and 27.4.1 (read together with 27.4.4(a)) of the AML/CFT/CPF and TFS for FIs PD.
[3] The Domestic List is a list of names and particulars of specified entities declared by the Minister of Home Affairs under the relevant subsidiary legislation made under section 66B(1) of the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA).
[4] The UNSCR List is a list of names and particulars of persons as designated by the United Nations Security Council (UNSC) or its relevant Sanctions Committee pursuant to the relevant UNSCR and are deemed as specified entities by virtue of section 66C(2) of the AMLA.
[5] Individuals or entities listed in the Domestic List and the UNSCR List.
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