1

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CONTENTS

A. Introduction 4

B. Reporting Checklist 6

C. Gazetted Activities 8

D. DCR Reporting Guide

Part A of DCR: Information on Reporting Institution

10

Part B of DCR: Business Information and Structure

13

Part C of DCR: AML/CFT Risk Assessment

19

Part D of DCR: AML/CFT Programme 21

E. Frequently Asked Questions on DCR

General & Applicability 29

Submission of DCR 31

Information on Reporting Institutions 33

Business Information and Structure 34

Implementation of AML/CFT Measures 35

Sector specific FAQs 36

F. DCR 2021 39
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INTRODUCTION
The purpose of this document is to guide reporting institutions in completing the Data and
Compliance Report (DCR) 2021.

DCR is one of supervisory tools adopted by Bank Negara Malaysia (BNM) as the Competent
Authority appointed under the Anti-Money Laundering, Anti-Terrorism Financing and
Proceeds of Unlawful Activities Act 2001 (AMLA). DCR is issued pursuant to section 8(3)(a)
of the AMLA read together with section 143(2) of the Financial Services Act 2013 (FSA).

DCR is issued to reporting institutions under the AMLA which have been specified by BNM
to be subjected to the Anti-Money Laundering, Countering Financing of Terrorism and
Targeted Financial Sanctions for Designated Non-Financial Businesses and Professions &
Non-Bank Financial Institutions (AML/CFT and TFS for DNFBPs and NBFIs) Policy
Document. Please refer to the relevant AMLA subsidiary legislation and paragraphs 3.3 and
3.4 of the AML/CFT and TFS for DNFBPs and NBFIs Policy Document (hereinafter referred
to as ‘Policy Document’) on designation and gazetted activities of reporting institutions.

The DCR 2021 does not apply to:

i. licensed casino carrying on gaming business under the Common Gaming Houses
Act 1953;
ii. building credit business and development finance business;
iii. any reporting institutions which has been selected and informed for onsite
assessment for 2021; and
iv. in-house lawyers and accountants that are employees of other types of businesses
or professionals working with government agencies.

Note that “in-house company secretaries” are encouraged to fill in a specific form which
can be found at the "In-House Cosec" tab on top of portal homepage for the purpose of
understanding risk of the sub-sector. This, however, EXCLUDES in-house company
secretaries of –
i. any reporting institutions subjected to Anti-Money Laundering, Countering Financing
of Terrorism and Targeted Financial Sanctions for Financial Institutions (AML/CFT
and TFS for FIs) issued by Bank Negara Malaysia; and
ii. any reporting institutions subjected to Guidelines on Prevention on Money
Laundering and Terrorism Financing for Reporting Institutions in the Capital Market
issued by Securities Commission Malaysia.
 5

Lawyers, notaries public, accountants, company secretaries (external) or trust companies

who do not provide any of the listed Gazetted Activities are required to declare non-provision
of Gazetted Activities through the portal by 15 November 2021.

Information submitted by reporting institutions in the DCR 2021 are confidential and will be
used by BNM for supervisory purposes and risks assessments. Reporting institutions are
advised to use the DCR as a self-assessment tool to help identify gaps and areas of
improvements in complying with the AML/CFT requirements.

Submission period of DCR 2021 is until 15 November 2021, in the manner specified by
BNM. Only completed DCRs will be accepted and processed by BNM for subsequent
issuance of a report card to the reporting institution. Please be reminded that all DCR 2021
submissions are final and BNM will not entertain any requests to amend the DCR that has
been submitted.

For further details on applicability of DCR 2021, please refer to the Frequently Asked
Questions on DCR i.e. Part E of this information kit. Should you have any additional queries
related to the DCR, please submit the queries to dcr@bnm.gov.my.
 6

REPORTING CHECKLIST
Before starting the DCR, it is recommended that the reporting institution review and compile
the following information or document beforehand to assist in responding to the DCR.

PART A – INFORMATION ON REPORTING INSTITUTION (RI)

i. RI information (name, type/nature of business, registration/license [ ]
number)
ii. RI contact information (email, phone number, address) [ ]
iii. Compliance Officer (CO) information
• CO name and contact information [ ]
• CO number (if already provided by BNM) [ ]
iv. RI size:
Number of all employees (for all RIs) [ ]
• Number of practising lawyers, accountants, company [ ]
secretaries or real estate agents.
• Number of practising lawyers, accountants or company [ ]
secretaries carrying out Gazetted Activities
• Number of real estate negotiators [ ]
v. Information on AML/CFT compliance system, (if any) [ ]
vi. Total value of annual investment/expenses on AML/CFT [ ]
compliance
vii. Membership of association(s) (if any) [ ]
viii. AMLA investigation orders received and responded [ ]

PART B – BUSINESS INFORMATION AND STRUCTURE OF RI

i. Transaction information for 2019 and 2020 (all business activities)
• Revenue [ ]
• Numbers of transactions and customers [ ]
• Total amount of cash transactions [ ]
ii. General customer information
• Breakdown of customer by types (e.g. individual, legal [ ]
person, legal arrangement, and politically exposed person,
high net worth and/ or sanctioned/ specified person/ entity
etc.)
• Breakdown of customer by nationality [ ]
• Payment type and delivery channel (on-boarding channel) [ ]
iii. Local and foreign branch information [ ]
iv. Transaction information by type of product/services [ ]
• Value of transactions/cash transactions (DPMS) [ ]
• Number or volume of transactions [ ]
• Number of customers [ ]
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PART C – AML/CFT RISK ASSESSMENT

i. Conduct of AML/CFT risk assessments by RI
• Process or guidance available (e.g. manual or standard operating [ ]
procedure (SOP))
• Frequency of review [ ]
• Risk ratings assigned to products, services, customers, etc. [ ]
• Risk drivers / risk issues (if any) [ ]
• Number of customers classified as having high ML/TF risk (if any) [ ]
• Product/services classified as having high ML/TF risk (if any) [ ]

PART D – AML/CFT PROGRAMME

i. RI AML/CFT standard operating procedures (SOP) or implementation
manual, specifying the processes, procedures or policy for/ on:
• Customer Due Diligence or Know Your Customer [ ]
• Record keeping [ ]
• Screening of customers against sanctioned persons/ entities lists [ ]
• Risk profiling / risk rating for customers [ ]
• Enhanced Due Diligence for higher risk customers (if any) [ ]
• Ongoing Due Diligence (for repeat customers) [ ]
• Reporting suspicious transaction (STR) and other STR related [ ]
information (i.e. number of STR submitted or internally generated
STR)
• Storing customers’ information and transactions records [ ]
(electronic or manual)

ii. RI AML/CFT Compliance Programme in relation to:

• AML/CFT Policy & Procedures for implementation of compliance [ ]
programme
• Employee training on AML/CFT measures [ ]
• Screening of employee [ ]
• Competency and certification/training attended by Compliance [ ]
Officer
• Independent AML/CFT audit (where relevant) [ ]
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GAZETTED ACTIVITIES
The following Gazetted Activities are applicable to lawyers/ notaries public, accountants,
company secretaries (external) and trust companies as stipulated under paragraph 3.3 of
the Policy Document. Please note that examples cited below are non-exhaustive.

Gazetted Activities (GAs)

Lawyers and GA I Buying and selling of immovable property.
Notaries Public and Examples:
Accountants • Advisory services related to buying and selling of real property
• Preparation of legal documents to facilitate buying and selling of
immovable property
• Facilitating payments for buying and selling of immovable property
GA II Managing of client's money, securities or other property.
Examples/explanation:
• Hold or keep client monies/ funds/ assets in separate account
(client/escrow account) and use the monies according to the
client’s instructions in conjunction with any of the specified GAs,
e.g., holding of earnest deposit in firm’s client account as
stakeholder funds pending completion of property acquisition
• Administer and manage client assets in a separate account
(client/escrow account), e.g., in relation to lawyer’s role as a
trustee for the administration of client’s assets
• For lawyers, there could be circumstances of spill-over, in which
the funds from litigation process may pass-through the client’s
account, and hence form part of the Gazetted Activities.
GA III Managing of accounts including savings and securities accounts.
Examples:
• Managing of client’s accounts including bank accounts or
securities accounts, e.g., acting as authorised signatory on behalf
of client to facilitate funds transfer/salary payment from client’s
bank account to third party/employees, power of attorney over
accounts
• Make investments on behalf of clients in securities and/or other
assets
• Book-keeping and the preparation of annual and periodic accounts
GA IV Organising of contributions for the creation, operation or management
of companies.
Examples:
• Advisory services related to capital contribution or funding/
financing arrangement of companies, e.g., initial public offerings
(IPOs) or issuance of bonds
• Preparation of agreement related to funding / financing
arrangement, e.g., IPOs or issuance of bonds
• Advisory services related to tax/ tax planning, investments in
securities and/or other assets
GA V Creating, operating or managing of legal entities or arrangements and
buying and selling of business entities.
Examples:
• Formation or setting up of companies/ entities, including the
related advisory services
• Formation or setting up of trust arrangement, including the related
advisory services and preparation of trust deed
• Provision of nominee director/ shareholder services
• Takeover, mergers and acquisition arrangement, including the
related advisory services and preparation of Share Sale
Agreement
• Insolvency/ receiver-managers/ bankruptcy, including the related
advisory services
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Gazetted Activities (GAs)

Company GA I Act as a formation agent of legal entities.
Secretaries Example:
• Register or incorporate new companies with Companies
Commission of Malaysia (CCM) or other registrar, where relevant

GA II Act as (or arrange for another person to act as) a director or secretary
of a company, a partner of a partnership, or a similar position in
relation to other legal entities.
Examples:
• Company secretarial services, including acting as director and the
related advisory services
• Maintain statutory registers such as register of directors, register
of members
• Administration of company related matters, e.g., file updates with
CCM on changes of company name or address, issue of shares,
changes in directors, shareholders, filing annual returns, making
amendments to company constitution, drafting resolutions,
organizing the company's board meetings and annual general
meeting and prepare agendas and minutes, etc.

GA III Provide a registered office, business address or accommodation,

correspondence or administrative address for a company, a
partnership, or any other legal entities or arrangement.
Example:
• Provide or maintain a registered address for companies

GA IV Act as (or arrange for another person to act as) a trustee of an express
trust.
Example:
• Provide trustee services, including advisory, administration and
management of trust
GA V Act as (or arrange for another person to act as) a nominee
shareholder for another person.
Example:
• Arrange for person B to act as nominee shareholder for company
JKW Sdn Bhd on behalf of person C, who is the actual owner of
JKW Sdn Bhd
Trust Companies GA I Act as (or arrange for another person to act as) a director or secretary
of a company, a partner of a partnership, or any similar position in
relation to other legal entities.
Examples:
• Arrange for person A to act as director for any given company
• Offer nominee director services (either company secretary
himself/herself or other part(ies))
GA II Act as (or arrange for another person to act as) a trustee of an express
trust.
Examples:
• Provide trustee services, including advisory, administration and
management of trust.

GA III Act as (or arrange for another person to act as) a nominee
shareholder for another person.
Example:
• Arrange for person B to act as nominee shareholder for company
JKW Sdn Bhd on behalf of person C, who is the actual owner of
JKW Sdn Bhd
 10

DCR REPORTING GUIDE

Part A: Information on Reporting Institution
Information in this part is based on current business information, unless stated otherwise.

No. DCR question Guidance

A1 – • Sector Choose your sector and type of business
A11 • RI name and contact details correctly from the drop-down list. Your choice of
• Type of business sector would determine the questions that you will
• Nature of business (for Dealers need to answer throughout the DCR.
in Precious Metal or Precious
Stones only) Complete the RI’s name and contact details
based on current details.

For Question A5 in relation to firm identification,

fill in business, company or firm registration
number (BRIC) and/or Licence Number of your
firm. You may type ‘Not Applicable’ or N/A if the
field is not relevant to your firm (e.g., ‘Not
Applicable’ if your firm has no licence number or
business or company or firm registration number)

A12 Name and contact details of your Appointment of CO is compulsory pursuant to

firm’s AML/CFT Compliance section 19(4) of the AMLA and paragraph 11.5.13
Officer (CO) of the Policy Document stipulate on the
requirement to notify BNM of the appointment.

If your firm has appointed a CO, you can proceed

to start filling in the DCR.

Otherwise, please click on the ‘CO Nomination

Notification’ tab / heading and complete the form.
After submission of the CO Nomination
Notification form, you can continue filling in the
DCR. You do not need to wait for the CO number
as the CO number is issued only for
administrative purpose.

Please fill in name, CO number, if available and

CO contact details accordingly.

The roles of CO can be found here.

A13 Number of all employees in your Number of employees in your firm should include
firm any person within the firm who is employed full
time or part time, under contract or permanent
employment.

Number of employees should be as at 31

December 2020.

No. DCR question
A14 Number of practising lawyer/
company secretary/
accountant/ registered estate
agents in your firm
A14A Number of practising lawyer/
company secretary/ accountant
that provides Gazetted Activities
(GA)
A15 For registered estate agents,
number of real estate negotiators
attached to your firm for the year
2020.
A16 Does your firm employ any
compliance system to aid the
firm’s compliance to AML/CFT
requirements?
A17 How much is the firm's total
annual investment/ expenses on
AML/CFT compliance (including
11
Guidance
For lawyer/company secretary/ accountant/
registered estate agents only, please fill in the
total number of:
• lawyer/ company secretary/ accountant
who is practising; or
• registered estate agents.
For lawyers, accountants and company
secretaries, please fill in the number of practising
lawyers, company secretaries or accountants who
provides GA services.
Please refer to paragraph 3.3 of the Policy
Document or page 7 of this Information Kit for
reference and non- exhaustive examples of GAs.
Provide the exact number of real estate
negotiators attached to your firm for the year
2020.
A compliance system/ process refers to an
infrastructure that supports the implementation of
key AML/CFT requirements. This could be in the
form of centralisation of customers’ data and
transactions, risk rating assignment, screening in
relation to targeted financial sanctions (TFS),
matching of politically exposed person (PEP) lists
etc.
Please note that employment of an automated
compliance system is not a compulsory
requirement. RIs may employ any system,
manual or otherwise, for effectiveness of its
compliance programme.
In answering this, you may consider any of the
following statements:
• Whether the system/ process adopted
commensurate with the total number of
customers and complexity of products.
• Whether the system/ process adopted allows
the firm to detect irregularities/ any suspicious
activity.
• Whether the system/ process adopted is
capable to centralise information across all
branches, systems and agents.
These investments/ expenses can include the
cost of procuring a system, providing training to
staff and preparation of documentation for due
diligence processes, or adjustment to processes

No. DCR question
system, training, documentations,
etc.), if any?
A18 Are you/ your firm a member of
any industry associations?
A19 Have any investigation orders
under AMLA (including sections
32, 37, 44, 45, 48, 49, 50, 51 and
52 of the AMLA) been issued to
your firm?
12
Guidance
in complying with the AML/CFT requirements, if
any.
You may provide an estimation if the exact figure
is not available.
Indicate if you/ your firm is a member of any
associations within your sector and to specify the
name of the associations in the column provided.
Please indicate the number of AMLA investigation
orders that have been issued to your firm and
number of orders that you have responded to in
the year 2020, if any.
Refer to the table below for the relevant
provisions under the AMLA:
Section 32 Power to examine persons
Section 37 Delivery of property, record, report
or document
Section 44 Freezing of property of a person
who is under investigation for an
offence of money laundering or
terrorism financing
Section 45 Seizure of movable property
Section 48 Investigation powers in relation to a
financial institution
Section 49 Public Prosecutor’s powers to obtain
information
Section 50 Seizure of movable property in
financial institution
Section 51 Seizure of immovable property
Section 52 Special provisions relating to
seizure of a business
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Part B: Business Information and Structure

Information in this part is based on the following:
ALL sectors B1-B4 Based on the entire business/operations of your firm in
2019/2020.
B5 onwards Based on:
(i) activities regulated under the AMLA; or
(ii) customer due diligence threshold for relevant sectors as
specified under the Policy Document.

No. DCR question Guidance

B1 – B4 • Total revenue/fees Scope of revenue for selected sectors are as follows
• Total number of (for year 2019 and 2020):
transactions
• Total value (in RM) of all (a) Registered Total fees for the
cash transactions (inward estate agents property/tenancy transaction
and outward payments). RI (b) Pawnbrokers Total interest income on
is allowed to provide
(c) Moneylenders pawns/loans collected by the
estimated value.
• Total number of customers firm and remains due to the
✓ As at 31 December firm in 2020.
2019 (d) Other sectors Annual revenue (or fees
✓ As at 31 December received) based on the
2020 audited account/ financial
statement for FY2019/ 2020
(If not available, based on
non-audited accounts for year
2019/ 2020).

For revenue, please include services which

commenced OR still worked on between 1 January
2020 to 31 December 2020 regardless of whether the
said services were completed in OR after the said
period.

Value and number of transactions (including cash

transactions) should exclude operational expenses
such as payroll, bills, finance expenses and dividend
payment.

Cash transactions cover both inward and outward

payments. Cash transactions include (please see
para 6.2 of Policy Document:
• bank notes and coins to the RI or into a bank
account of the RI (via counter or CDM);
• bearer negotiable instruments including
traveller’s cheques, vouchers and others but
exclude bank drafts, cheques and electronic
transfers; and/ or
• precious metals and/or precious stones.

No. DCR question
B5 Provide the total number of
customers of your firm and
number of respective type of
customers for each category,
where applicable:
• Individual customers
• Legal person customers
• Legal arrangement
customers
B6 Does your firm have foreign
individual/ legal person/ legal
arrangement customers?
B7 How do customers make
payment to your firm?
14
Guidance
Based on the listed type of customers here:
• To fill in the absolute number of customers for
each category of customers (if any).
• Fill in zero (‘0’) if there is no customer from that
category.
• You may refer to links provided at the portal
homepage for sanctions lists or the FCA list in
order to identify customers in these categories.
Example of legal persons:
• Companies, bodies corporate, government-linked
companies
• Foundations, non-profit organisations or
associations
• Partnerships
Example of legal arrangement:
• Trust
Note: Legal arrangement does not include
nominee shareholders/ director)
Please refer to the definition provided in the Policy
Document for ‘politically exposed persons’. While
there is no definitive list provided for PEPs, reporting
institutions are to develop its own list based on the
definition provided.
Please refer to Question 51 and 52 in the Frequently
Asked Questions on AML/CFT and TFS for DNFBPs
and NBFIs, which can be accessed here.
The Policy Document does not provide definition for
high-net-worth individuals (HNWI). RIs can develop
its own parameter or classification of HNWI based on
open sources, its own customer base/ profiles or past
business dealings.
Question 6 will only require to be answered if you
have foreign individual/ legal person/ legal
arrangement customers.
Please identify the country of your customers from
the dropdown list in question 6A and fill in the number
of customers for each of the selected country.
This refers to the methods of payment used by your
firm.
Fill in the total value of transactions for each method
of payment as follows, where relevant:
• Cash (including cash payment deposited into the
cash deposit machine (CDM)/ at counter into RI's
account)
• Cheque

No. DCR question
B8 How does your firm establish
business relationships with its
customers?
B9 What is the method use for
non face-to-face option?
B10 – Does your firm have any
B11 local/ international
branch(es)?
B12 For Lawyers/Notaries
Public, Accountants and
Company Secretaries and
Registered Estate Agents
only
Does your firm have any
formal domestic/ international
affiliation?
B13 - For Lawyers/Notaries
B14 Public, Accountants (B13)
15
Guidance
• Telegraphic Transfer (TT)/ Bank Transfer into
firm's account
• Debit Card/ Credit Card
• E-Wallet/ e-money
Value of transactions shall be from 1 January 2020
until 31 December 2020. Fill in zero (‘0’) if your firm
does not use any of the given payment methods
indicated above. You may provide an estimation if the
exact figure is not available.
Indicate how your firm establish a business
relationship with your customers/ customers i.e.
either by face-to-face or non face-to-face,
accordingly.
Non face-to-face means that you do not meet the
customers at all during on-boarding and throughout
the business relationship such as through mobile
apps or online transaction.
Fill in the corresponding total value of transactions if
you have on-boarded or accepted customers through
any of the following non face-to-face method:
• Online / web-based
• Agent incl. outsource marketing agent
• Telephone
• Post
• Email
RIs are allowed to provide estimated value of
transactions.
Fill in the number of branches and the location (by
postcode) for domestic branch(es) and by country
name for international branch(es), if any.
Domestic / international affiliation refers to formal
arrangements with domestic/ international firms to
acquire a wider customer reach. For example,
collaboration between international law offices.
This, however, does not constitute a branch and head
office relationship.
For questions 12B and 12C, indicate ‘Yes’ or ‘No’ for
the following questions:
• Whether you or your firm have assisted any
domestic customers for overseas transactions
• Whether you or your firm have assisted any foreign
customers, domiciled or located overseas for
domestic transactions or transactions in Malaysia.
For each GA relevant to the firm, please fill in:
• the total number of customers;

No. DCR question
and Company Secretaries
(B14) only
Please provide the number of
customers, number of
transactions and value of
transactions (excluding fees),
for each GA that your firm
undertakes/provides.
B15 – For Company Secretaries
B16 only
To provide:
• the number of shelf
companies available for
purchase as at 1 April
2021; and
• the average number of
company incorporated (per
month) by your firm in
2020.
B17 - For Lawyers/Notaries
B19 Public, Company
Secretaries and Trust
Companies only
Does your firm provide
nominee services in 2020?
B20, For Trust Companies only
B20A
and
B20B
16
Guidance
• the total number of transactions; and
• the total value of transactions (excluding fees);
Fill in zero (‘0’) in the relevant column if your firm does
not undertake/provide the GA as indicated. If the
number is not available, please provide the best
estimate.
Include GA services which commence OR still
worked on between 1 January 2020 to 31 December
2020 regardless of whether the said services were
completed in OR after the said period.
To enter the exact number in the columns provided. If
the number is not available, please provide the best
estimate.
If yes, to provide the common reason cited by
customers in requesting nominee shareholding and
nominee director services.
For each GA and other Non-GA activities (if any)
relevant to the firm, please fill in:
• the total number of customers
• the total number of transactions
• the total value of transactions (excluding fees).
For questions B20A and B20B, indicate whether your
firm has assisted:
• local customers (whether citizens or foreigners),
domiciled or located in Malaysia, in forming legal
arrangements overseas
• foreign customers, domiciled or located overseas,
in forming legal arrangements domestically or in
Malaysia.

No. DCR question
B21 For Dealers in Precious
Metal or Precious Stones
(DPMS) only
Please provide the number of
customers, number of CASH
transactions and value of
CASH transactions for the
respective products that your
firm offers.
B22 For DPMS only
Does your firm provide any
type of gold safekeeping
services (such as gold
storage or accumulation)?
B23 For DPMS only
Please provide the number of
CASH transactions for the
respective transaction range.
B24 For Registered Estate
Agents only
Please provide the total value
of fees, number of
transactions and number of
customers for the respective
services that your firm offers.
17
Guidance
DPMS needs to provide the total value of CASH
transactions, total number of CASH transactions and
total number of customers for the following products
that your firm offers, where relevant:
• Minted bar (gold bar, gold coin, gold nugget)
• Loose diamond
• Jewellery
• Luxury watch
• Loose precious stones
• Scrap gold
• Cast bar
• Workmanship
Please note that this should only applies to cash
transactions equivalent to RM50,000 and above.
If you have no cash transactions equivalent to
RM50,000 and above, either in a single or linked
transactions, fill in zero (‘0’) in the column.
DPMS needs to indicate whether their firm offers
services related to gold safekeeping which can be in
the form of gold storage or accumulation. This does
not mean any account which provide returns.
To provide the total number of CASH transactions
only based on the range listed (regardless of
threshold), below:
• RM4,999 and below;
• RM5,000 – RM9,999;
• RM10,000 – RM24,999;
• RM25,000 – RM49,999;
• RM50,000 – RM74,999;
• RM75,000 – RM99,999; and
• RM100,000 and above.
Note that this only refers to CASH transactions. If you
have no cash transactions at all, fill in zero (‘0’) in the
corresponding columns.
Please provide the total value of fees, total number of
transactions, and total number of customers for the
following services that your firm offers, where
applicable.
• Tenancy;
• Sub-sales (domestic);
• Project sales (domestic);
• Sub-sales (overseas); and/or
• Project sales (overseas).
For sub-sales and project sales services, please also
provide the breakdown between domestic and
overseas sales. If you do not provide any overseas
sales, please fill in zero (‘0’).

No. DCR question
B25 For Moneylenders only
Please provide the total value
of loans, number of loan
transactions and number of
customers for the respective
type of loan that your firm
offers.
B26 – For Pawnbrokers only
B27
• Does your firm
provides Ar-Rahnu
services?
• Please provide the
total value of pawn /
redemption, number of
pawn / redemption and
number of customers
for pawn and
redemption.
B28 For Leasing Companies
only
Please provide the total value
of lease arrangements and
total number of lease
arrangements for the
respective type of lease that
your firm offers.
B29 For Gaming Outlets only
Please provide the total value
and total number of tickets
sold and total winnings.
18
Guidance
Please provide the total value and number of
transactions (by disbursement and repayment) as
well as number of customers for the following type of
loan that your firm offers, where applicable.
• Secured loan to individual customer (pinjaman
bercagar untuk peminjam individu)
• Secured loan to corporate customer (pinjaman
bercagar untuk peminjam syarikat)
• Unsecured loan to individual customer (pinjaman
tak bercagar untuk peminjam individu)
• Unsecured loan to corporate customer
(pinjaman tak bercagar untuk peminjam syarikat)
Please indicate whether your firm provides Ar-Rahnu
services in question 26.
In question 27, please provide the total value of
transactions, the total number of transactions as well
as total number of customers for both pawn and
redemption. If you do provide Ar-Rahnu services, you
will see the column as Ar-Rahnu pawn and Ar-Rahnu
redemption.
Please provide the total value and total number of
lease arrangements for both financial lease and
operational lease that your firm offers in the relevant
column.
To fill in the total value and total number of tickets sold
and total winnings in the relevant column.
Subsequently, in question 29A, gaming outlets need to
provide the breakdown in terms of the number of total
winnings based on the following range:
• RM50,000 – RM100,000;
• RM101,000 – RM250,000;
• RM251,000 – RM500,000; and
• RM500,000 and above

Part C: AML/CFT Risk Assessment
Information in this part is based on current process/practice/assessment of the firm, unless
otherwise stated.
No. DCR question
C1 On a scale of 1 - 5, to what
extent does your firm
understand its own money
laundering (ML) and terrorism
financing (TF) risks?
C2 – Has your firm conducted any
C2A ML/TF risk assessments on its
own business?
C3 Does your firm have
processes/ policy to ensure
that the firm's ML/TF risk
assessments are up-to-date?
C4 If your firm had undertaken
ML/TF risk assessments,
please select the
corresponding ML and TF risk
19
Guidance
This question intends to gauge your firm’s level of
understanding of ML/TF risks based on assessment
or perception, on a scale between 1 and 5.
1 = does not understand your firm’s ML/TF risks
5 = highly understood your firm’s ML/TF risks.
Please select the appropriate scale that reflects your
firm’s level of understanding.
The ML/TF risk assessment refers to the systematic
assessment in relation to the vulnerability of ML/TF
risks that your business faces by considering various
risk factors as provided in the Policy Document (i.e.,
customer, product/services, geographical location
and delivery channels).
Assessing the ML/TF risk will enable you to
recognise which area your business is most
vulnerable to, which can be exploited by criminals.
If your firm have undertaken any sort of ML/TF risk
assessments, indicate ‘Yes’ in question 2 and
proceed to answer whether such risk assessment was
documented in Question 2A.
Otherwise, that is the end of Part C and you may
proceed to Part D.
This refers to any policy, guidelines or parameter for
your firm to update and review its risk assessment.
For example, the policy or guidelines require your
firm to ensure risks understanding to be reviewed or
updated on a pre-set period or / and when there is
any triggering event such as offering of new
products, targeting a new customer base,
implementation of a new policy on cash transactions
or any compliance breach that you may have
discovered.
If you select ‘Yes’, you will then be asked in sub
question 3A on the frequency of the review of ML/TF
risk assessment for your firm.
There are four types of risks to be considered by RIs
(and examples of each factor);
 20

No. DCR question Guidance

rating level for the following Customer risk
factors. Firm’s exposure to different types of customers
including their nationality and exposure to PEP
• Low customers or other risk factors
• Medium
• High Product and services risk
• Not assessed • Nature and complexity of the products/services
offered
• Cash intensity related to the products/services

Transaction/ Delivery Channel risk

• Whether product/ services offered via non face-
to-face channels which are more susceptible to
ML/TF as compared to face-to-face channels

Geographical risk
• Geographical location of the RIs’ holding
company, head office, branches and subsidiaries
and agents, if any.

If your firm’s assessments do not take into account

any of the above specified risk factors, please choose
‘Not Assessed’ from the dropdown choices.

If your firm has identified the main risk drivers or risk

issues during the risk assessment, you may include
a brief explanation of them under question 4A.
Examples, which are non-exhaustive includes, high
cash exposures, complex product or services
structure, large customer base, international network,
involvement of offshore centres etc.

C5 – How many customers does
C6 your firm classify as having
high ML and TF risk?
To indicate the total number of customers that has
been classified as having high ML and TF risk.
Subsequently, in question 6A, please indicate what
your firm constitutes as customers with high TF risk.
Examples may include customers that you have
identified from specified high risk countries for
terrorism.

C7 – What products/ services do To indicate the types of products and services

C8 your firm classify as high risk offered by your firm, that your firm has identified and
for ML? Please specify, if any. classified as having high ML and TF risk, in the
relevant column, if any.
 21

Part D: AML/CFT Programme

Information in this part is based on current process/ practice on customers/ transactions
relating to (i) activities regulated under the AMLA; or (ii) meets the Customer Due Diligence
(CDD) threshold specified for relevant sectors. You may refer to the table listing of the CDD
threshold for selected sectors in the homepage of the DCR portal.

No. DCR question Guidance

D1- Type of customers
D3 (individual, legal person,
legal arrangement),
documents.
• Information collected to
identify customers
• Documents used to
verify identity of
customers
CDD is the process of identifying and verifying (using
reliable and independent documentation including
electronic data) the identity of your customers, persons
conducting the transaction as well as beneficial owners.
To indicate whether your firm deals with individual
customers, legal person customers such as company,
partnership or legal arrangements customers such as
trust under D1, D2 and D3.

Sub-questions A and B will then require you to indicate

from the list:
• The type of information that you collect to identify
your customer, persons conducting the transaction
as well as beneficial owners; and
• The type of documents that you use to verify the
identity of your customer, persons conducting the
transaction as well as beneficial owners.

Where relevant, you can also provide examples of

documents that you request from customers who are
either a foreign legal person or foreign legal
arrangement in sub-questions D2C and D3C.

For more information, please refer to the infographic on

CDD which can be accessed here.

D4 Does your firm identify and
take reasonable measures to
verify the identity of
beneficial owner(s) of
customer who are legal
persons through the
following steps?
Beneficial owner refers to any natural person(s) who
ultimately owns or controls a customer and/or the
natural person on whose behalf a transaction is being
conducted. It also includes those persons who exercise
ultimate effective control over a legal person or
arrangement.
As provided in paragraph 14A.9.6 of the Policy
Document, RIs should identify the beneficial owners of
legal persons through the steps provided in the Policy
Document.

You are required to indicate what document or actions

that your firm uses or does for verification of beneficial
owner for this question.

For more information, please refer to the Guidance on

Beneficial Ownership which can be accessed here.

DCR Reporting Guide


No. DCR question
D5 Has your firm conducted
delayed verification?
D6 Does your firm use biometric
identification methods (i.e.
scan fingerprints by using
biometric device) to verify
the NRIC of the customers?
D7 Does your firm rely on third
party reporting institution in
conducting CDD?
D8 Does your firm keep copies
or records of the
identification documents of
the customer as requested in
questions 1B, 2B, 2C, 3B,
3C and 4?
D9 Does your firm keep copies
of all transaction records
of customers?
22
Guidance
RIs can delay verification only when ML/TF risk is
assessed as low and verification is not possible at the
point of establishing the business relationship.
If your firm has conducted delayed verification
previously, you are required to provide one or more
examples of situations where your firm has applied
delayed verification in sub-question A.
You may refer to paragraphs 14.10.20 and 14.10.21 of
the Policy Document for more details on delayed
verification.
Using biometric identification is an optional method to
verify a customer’s NRIC.
In question D6, answer ‘Yes’ if your firm employs this
method and ‘No’ if your firm does not. Please note this is
not a mandatory requirement.
Third parties refers to RIs that are supervised by a
relevant competent authority and meets the
requirements under paragraph 16 of the Policy
Document on Reliance on Third Parties.
This includes RIs such as banks, insurance companies,
company secretaries, foreign banks, etc.
This does not include outsourcing or agency
relationships because the outsourced service provider or
agent is regarded as synonymous with the RI.
Please refer to paragraph 16 of the Policy Document for
more details and conditions that enable reliance on third
parties.
Please indicate whether copies of documents used
during the identification and verification process of
customers are kept by your firm.
To indicate whether your firm keep copies of all
transaction records of your customers. These include
receipts, agreements and invoices,
If the records are kept, answer sub-questions A, B and
C:
• A: Period of records being kept
• B: In what form records are being kept, either hard
copies, digital copies or other types
• C: Whether records kept are sufficient to reconstruct
any individual transactions if necessary.
 23

No. DCR question Guidance

Some questions also provides options of ‘Yes’, ‘Partial’ or
‘No’. Please select the answer that is most relevant to
your firm’s practice.

D10 - What are the sanctions lists • Select ‘Yes’ if your firm maintains the particular list
D10B maintained by your firm? • If you select ‘Yes’ to any of the sanctions lists, please
proceed to question 10A on the screening of
customers against the lists
• If you do not maintain any of the lists, select ‘No’ for
each lists and proceed to question 11

Maintaining sanctions lists and screening of all new and

existing customers against these lists is part of the
AML/CFT requirements and is asked in sub-question
10A.

Your firm may use/subscribe to external screening

platform in conducting screening on your customers. If
your firm has assessed that the system is up-to-date
and has incorporated the latest sanctions list, the
requirement on 'maintenance of sanctions list' is deemed
as met.

In sub-question 10B, you need to indicate whether your

firm has work processes in place, in the event of any
match from the sanctions lists that you maintain, as
indicated in question 10.

You may refer to the homepage of the portal for links to

D11- Does your firm risk profile or
D11C classify its customers for
ML/TF risk to enable conduct
of enhanced due diligence
and monitoring?
the relevant sanctions lists.
Risk profiling of customers is conducted during customer
on-boarding. Please choose ‘Yes’ or ‘No’. If yes, proceed
to answer sub-questions A, B and C.
(A) Indicate if your firm can identify higher risk
customer.
(B) Choose the risk factors that you have taken
into account when rating your customers:
• customer risk
• products and services risk
• delivery channel/ transaction risk
• geographical risk.
(C) Determine the practices of your firm in
dealing with customers that are rated as
high risk.
 24

No. DCR question Guidance

D12 - Is your firm able to Choose ‘Yes’ or ‘No’ if your firm is able to identify repeat
D12B identify repeat customers or otherwise. If yes, proceed to answer sub-
customers? questions A and B accordingly.

(A) Does your firm have any repeat customers,

if ‘Yes’;
(B) Indicate which of the listed practices that
your firm use when dealing with repeat
customers.

D13 Has your firm identified
relevant triggers, conditions
or scenario (also called red
flags) to help indicate that a
transaction is suspicious?
In order to detect suspicious transactions, does your
firm, either formally or informally identify scenarios (red
flags) where a customer or a transaction may be
suspicious.
Select ‘Yes’ if your firm has identified these red flags and
proceed to question 13A.

In question 13A, select ‘Yes’ if the identified red flags are

recorded in writing or documented, for example in the
firm’s SOP. Select ‘No’ if the identified red flags are known
by the firm but is not written or documented anywhere.

Do note that you can also refer and obtain the common or
sector-specific red flags in the Policy Document, as a
guidance in identifying your firm’s red flags. (See
Appendix 15 of the Policy Document).

D14 - Has your firm established
D14C procedures/ workflow for the
submission of Suspicious
Transaction Report (STR) to
BNM?
Suspicious transactions should be reported to BNM
whenever the RI suspects that the transaction (including
attempted or proposed), regardless of the
amount:
• appears unusual;
• has no clear economic purpose;
• appears illegal;
• involves proceeds from an unlawful activity or
instrumentalities of an offence; or
• indicates that the customer is involved in ML/TF.

In question 14, firms are required to indicate whether

there are procedures in place in relation to submission of
STR to BNM. This refers to –
• procedures to channel internal STR from employee
to the CO;
• duration of time for the CO to review the interna
STR; and
• duration of time for the CO to submit an STR to
BNM, upon confirmation of suspicion.

If the answer to question 14 is ‘Yes’, proceed to

answer sub-questions A, B and C.

D15 - Has your firm reported any If your firm has submitted STRs to BNM previously,
D15C STRs to BNM? please select ‘Yes’ in question 15. Otherwise, select
‘No’.
 25

No. DCR question Guidance

For RIs that are backed by financial institutions, STR

reported refers to STR that is submitted by the RI itself.

Under question 15A, for firms that have never submitted

STRs, BNM would like to understand further on the
possible reasons on why STRs are not being submitted.
Please provide the reason that is most relevant to your
firm.

For question 15B, please fill in the average number of

internally generated STR (per month), if any, even
though the firm has never submitted STR to BNM.

For the firm that has submitted STRs, you will need to
select the method used to submit STRs to BNM in
question 15C.

D16 - Does your firm have a MIS refers to any system used by your firm to store
D16A management information customers’ information and transactions records.
system (MIS), either
electronic or manual? MIS does not necessarily have to be digitalised or
computerised. MIS can be in a manual form as long as
MIS adopted by the firm is capable of aggregating
customer’s transaction from multiple accounts or across
all branches. And more importantly, is able to pick up any
anomalies in the transactions. Sub-question 16A will
proceed to ask whether your MIS is able to do the above,
please indicate ‘Yes’ or ‘No’ where relevant.

Examples of an electronic MIS:

• In-house/ off-the-shelves accounting/ centralised
data management system
• Excel or any database software

Example of a manual MIS:

• Hardcopy files and centralised filing system

D17 - Compliance Programme AML/CFT Compliance Programme consists of several

D21 requirements as follows:

• Written AML/CFT policy (paragraph 11.2 of the

Policy Document)
• Employee training (paragraph 11.8 of the
Policy Document)
• Employee screening (paragraph 11.7 of the
Policy Document)
• Independent audit (paragraph 11.9 of the
Policy Document)

Please refer to the Policy Document for full details on

AML/CFT compliance programme. Click where relevant
to the practice of your firm.
 26

No. DCR question Guidance

D17 - For big size firms: In question 17, you need to indicate if your firm has
D17C Does your firm have a established a written AML/CFT policy, procedures and
written AML/CFT policy, controls.
procedures and controls?
Please note that if you are a small sized firm, at minimum,
For small sized firms: your firm can adopt the ‘AML/CFT and TFS for DNFBPs
Does your firm have a and NBFIs Policy Document’ as your policies and
written AML/CFT policy, procedures.
procedures and controls or
at a minimum, adopt the If the answer is ‘Yes’, in question 17A, you are required to
AML/CFT and TFS for indicate whether the written policies are kept up-to-date
DNFBPs and NBFIs Policy with the regulatory requirements.
Document as your policies
and procedures? Sub-question 17B requires you to indicate whether the
policies are approved by your senior management
including board of directors or senior partners. You may
indicate ‘Yes’, ‘Partial’ or ‘No’ that best reflects your firm’s
practice.

Sub-question 17C proceeds to ask how often your firm

reviews the AML/CFT policies and procedures. Select the
answer that best reflects your firm’s practice based on the
following options:
• Annually;
• Once every 2 years;
• Once every 3 years; or
• When there is significant change in business
process/event

D18 - Does your firm conduct Select ‘Yes’ if your firm has provided training and
D18B training and awareness awareness programmes for your employees in relation to
programmes for the your firm’s AML/CFT practices and measures and
employees on the firm's proceed to questions 18A and 18B.
AML/CFT practices and
measures? In sub-question 18A, select the type of training that your
firm provides to your employees by indicating ‘Yes’ or ‘No’
to the relevant categories provided as follows:
• Internal AML/CFT training
• Regular refresher or update
• Newsletter or circular
• External training - BNM
• External training - e.g., Bar Council, MIA,
MAICSA, MACS, MIEA, PEPS etc.
• Online or e-module available via electronic means

In sub-question 18B, please indicate whether your firm

ensures that the training provided corresponds and is
appropriate to the employee’s level of responsibilities in
detecting ML/TF activities and the risks of ML/TF
identified by your firm.

No. DCR question
D19 - Does your firm conduct
D19C employee screening?
D20 Does your firm’s Compliance
Officer (CO) have the
necessary knowledge and
skills to discharge his/her
AML/CFT obligations?
D21 Does your firm conduct
regular AML/CFT
independent audits
(frequency to be determined
by the Board/SM/senior
partners) to determine
compliance and
effectiveness of AML/CFT
measures employed by your
firm?
D22 What areas of the AML/CFT
requirements does your firm
find the most challenging to
implement?
27
Guidance
Choose ‘Yes’ or ‘No’ based on whether the firm conducts
employee screening or otherwise.
If the answer is ‘Yes’, there are three sub-questions that
needs to be filled in.
(A) When is the screening conducted;
(B) How is the screening conducted; and
(C) Type of assessment involved in the
screening process.
Choose ‘Yes’ or ‘No’ based on whether your CO has the
necessary knowledge to discharge his/her AML/CFT
obligations.
Further, for sub-questions 20A and 20B:
(A) Indicate whether the CO has attended any
AML/CFT trainings; and
(B) Indicate whether the CO obtains any
AML/CFT certifications. Do note that
obtaining certification is a best practice,
which is encouraged and not a requirement
or mandatory under the Policy Document.
Select ‘Yes’ if your firm conducts regular independent
audits on AML/CFT measures to determine the
effectiveness and compliance with AMLA and the Policy
Document.
Please proceed to sub-questions A, B and C in relation to
further questions on the independent audits:
(A) Frequency as determined by the firm’s
senior management/ board of
directors/senior partners, where relevant;
(B) Method; and
(C) Scope.
BNM would like to hear if there are any specific areas of
the AML/CFT requirements that your firm finds particularly
challenging to implement.
This is an important feedback for BNM and relevant self-
regulatory bodies to focus on especially the identification
of areas that requires the most support in assisting your
firm or sector to comply.
Please select the corresponding answer that best reflects
your firm’s views and experience.
 28

No. DCR question Guidance

D23 Is there any other You may provide any feedback in relation to the AML/CFT
information / comments requirements or implementation, including challenges
relating to the AML/CFT arising from the Covid-19 pandemic, if any.
requirements/implementation
within your firm that you wish
to provide (including
implementation challenges
during the period of MCO or
Covid-19 pandemic
generally)
 29

FREQUENTLY ASKED QUESTIONS ON DCR

NO. QUESTION ANSWER

General & Applicability

1. What is DCR? DCR is one of the supervisory tools for AML/CFT
adopted by Bank Negara Malaysia as the competent
authority under the AMLA

2. Who must submit the DCR DCR 2021 must be completed and submitted by all RIs
2021? from the following sectors:
• Lawyers & Notaries Public*
• Accountants*
• Trust Companies*
• Company Secretaries (External)*
• Dealers in Precious Metals or Precious Stones
• Registered Estate Agents
• Pawnbrokers
• Moneylenders
• Licensed Gaming Outlets
• Leasing Businesses
• Factoring Businesses
• Company Secretaries (Internal/ in-house) #

* Applicable only to institutions carrying out Gazetted

Activities. DCR is not intended to be applicable to
‘internal’ or ‘in-house’ lawyers and accountants that are
employees of other types of businesses, nor to
professionals working within government agencies.

# In-house company secretaries are encouraged to fill

3. What if my firm does not
provide any Gazetted
Activities, should my firm still
submit the DCR?
in a specific form which can be found at the "In-House
Cosec" tab on top of portal homepage for the purpose
of understanding risk of the sub-sector. This, however,
EXCLUDES in-house company secretaries of –
i. any reporting institutions subjected to Anti-
Money Laundering, Countering Financing of
Terrorism and Targeted Financial Sanctions for
Financial Institutions (AML/CFT and TFS for
FIs) issued by Bank Negara Malaysia; and
ii. any reporting institutions subjected to
Guidelines on Prevention on Money Laundering
and Terrorism Financing for Reporting
Institutions in the Capital Market issued by
Securities Commission Malaysia.
If your firm does not provide any Gazetted Activities, you
are required to declare non-provision of Gazetted
Activities through the DCR portal. Please refer to the
‘Overview and Applicability’ on the portal homepage for
further details on steps to declare.
 30

NO. QUESTION ANSWER

4. Why should I submit the By submitting the DCR, RIs are:
DCR? • complying with the requirements stipulated under
Section 8(3)(a) of the AMLA read together with Section
143(2) of the Financial Services Act; and
• self-assessing their level of compliance and identify
gaps and rooms for improvement to protect its firm from
potential abuse and misuse by money launderers or
terrorist financiers.
5. When can I submit the The DCR can be submitted via portal from 16 June 2021
DCR? onwards up until 15 November 2021.

6. Where can I access and This year, submission of the DCR by RIs must be made
submit the DCR? through the DNFBP portal which is accessible beginning
16 June 2021 at this link:
dnfbpportal.bnm.gov.my

Please follow the instructions in the portal to complete

your DCR.
7. Do I need to appoint a CO Yes, RIs need to appoint a CO before attempting to
prior to submitting the DCR? answer the DCR.

If you have yet to do so, please appoint your firm’s CO

and notify BNM by filling an online form included in the
portal. Choose the ‘CO Nomination Notification’ tab /
heading and you will see an online form.

Complete the form and submit. BNM will revert via email
with your unique CO number for administrative purpose.

Nonetheless, you may proceed to fill in the DCR without

waiting for the CO number. You will only need to provide
name and contact details of the CO in the column
provided.

8. If my firm has appointed No, the CO number previously assigned to the CO of your
Compliance Officer and has firm is still valid and can be used to fill in DCR 2021.
notified the appointment to
Bank Negara Malaysia
previously, do we still need
to fill up the CO Nomination
Notification Form this year?

NO. QUESTION
9. What does the DCR cover?
10. Will any enforcement action
be undertaken for the gaps
identified?
11. How will the information in
the DCR be used by BNM?
12. My firm has received a letter
from Bank Negara Malaysia
for onsite examination but it
is now postponed due to
MCO. Are we still required to
submit the DCR by 15
November 2021?
Submission of DCR
13. Is submission of the DCR
mandatory?
31
ANSWER
The DCR consists of four parts:
• Part A: Information on Reporting Institution
• Part B: Business Information and Structure (including
aggregate information on products and services,
customers and channels of delivery)
• Part C: AML/CFT Risk Assessment
• Part D: AML/CFT Programme
RIs may refer to the ‘DCR Reporting Guide’ section
above in this information kit for a more detailed
explanation on each DCR question.
No.
However, RIs are expected to conduct improvement
based on the gaps identified in the DCR submissions and
areas highlighted in the Report Card.
BNM will use the DCR information for supervision and
monitoring purposes including for:
• Understanding how RIs meet the AML/CFT
obligations;
• Identifying areas of the AML/CFT requirements that
require further guidance; and
• Assessing the risk of money laundering and terrorism
financing faced by RIs at both firm and sectoral levels.
No, for the firms that have been selected and informed on
onsite assessment for 2021 by Bank Negara Malaysia are
not required to submit DCR 2021.
Yes. Submission of the DCR is compulsory and is an
enforceable requirement on all specified RIs.
The DCR is issued pursuant to the AMLA, Financial
Services Act 2013 and is a mandatory requirement under
paragraph 25.1(a) of the Policy Document. The DCR has
been made as an annual reporting requirement beginning
2020, unless specified otherwise by Bank Negara
Malaysia.

NO. QUESTION
14. If an RI qualifies as small-
sized, is the RI exempted
from the submission of the
DCR?
15. What are the consequences
or penalty for failure to
submit the DCR?
16. For a firm who only
undertakes audit services, is
submission of the DCR
required?
17. I am a Compliance Officer
for a group of companies or
multiple practising certificate
holders doing different
activities under the AMLA.
Can I just submit one DCR
for the group of companies?
18. I am a sole proprietor with
no employee. Can I appoint
myself as the Compliance
Officer?
19. How should the DCR be
completed and submitted for
a firm with multiple
branches?
32
ANSWER
No, small-sized RIs are still subjected to the DCR
submission.
The simplification or exemption are only for selective
AML/CFT requirements. This include simplification on the
conduct of employee screening and training and
exemption of AML/CFT Independent audit functions.
Please refer to paragraph 11.1.1 of the Policy Document
for more information on the exemptions and simplifications
applicable to small-sized reporting institutions.
Enforcement action can be taken on RIs who fail to submit
the DCR within the stipulated timeline.
Not required. Audit services is not part of the Gazetted
Activities for accountants.
However, if the firm undertake audit services as well as
Gazetted Activities, submission of the DCR is required for
the firm.
Please refer to Section C of this kit for examples of
Gazetted Activities.
Given the different nature of business operations and
customer profiles for each business activity, DCR needs to
be submitted separately for each company or practice
areas.
For instance, for a group of companies undertaking
leasing, factoring and money lending business, one DCR
for each business activity.
Yes.
For firms with multiple branch offices, submission is by the
head office only. However, if the branch office is operating
independently from the head office, then the branch
office should respond to the DCR separately.

NO. QUESTION
20. I have submitted the DCR
but I would like to change
my answers. Can I amend
my submission or should I
submit new DCR?
21. My firm previously provided
Gazetted Activities between
January to June 2021.
Starting from July 2021, the
business has been changed
to activities / services which
does not fall under Gazetted
Activities. Do I still need to
submit DCR for my firm?
22. Can I save my DCR in the
portal as draft for review
prior to submission?
23. Can I print / retain soft copy
of the DCR upon submission
for our reference?
Information on Reporting Institution
24. For the ‘number of all
employees’, should I include
temporary staff or staff who
do not deal with customers
such as drivers? Should the
directors (with or without fee)
be included in the number of
all employees?
25. Is Bar Council. MIA,
MAICSA and MACs
considered as industry
association?
33
ANSWER
Submission of the DCR is final and cannot be
changed/amended after submission. No new DCR should
be submitted. BNM will only record the first submission by
RI. RIs are responsible to ensure that all information
provided in the DCR are true and accurate to the firm’s
knowledge.
No, your firm needs to fill the Declaration Form for Non-
Provision of Gazetted Activities which can be accessed at
the portal homepage, before or by 15 November 2021.
RIs will not be able to save as draft for review prior to
submission.
The portal currently does not support for reporting
institution to print / retain soft copy of the DCR after
submission. You may use the full set of DCR questions in
PDF format or excel format (upon request) to document
your answers.
The number of all employees should include any person
within the firm who is employed full time or part time,
under contract or permanent position.
Procurement of part-time external manpower for one-off
work assignments is not considered as employees.
Number of employees should be as at 31 December 2020.
Yes. For the purpose of DCR, all self-regulatory bodies
are considered as industry association.

NO. QUESTION
Business Information and Structure
26. What does the ‘total revenue
in year 2019/2020 refer to?
Is revenue based on
calendar or financial year?
(Part B – Question 1)
27. What is meant by cash
transaction?
28. Is money released from
bank loans considered cash
transactions for a purchase
of property?
34
ANSWER
For accountants, lawyers, company secretaries and trust
companies sectors, the revenue refers to total
revenue/fees obtained for year 2019/2020 from all
activities provided by the firm.
For registered estate agents, it refers to the total fees for
the property transactions.
For pawnbrokers and moneylenders, it refers to total
interest income on pawns/loans. This should include
interest collected as well as interest remains due to the
firm in 2020.
Revenue is preferably based on audited financial year of
2020. Otherwise, firm can provide revenue based on
calendar year.
This includes revenue for services which commenced OR
still worked on between 1 January 2020 to 31 December
2020 regardless of whether the said services was
completed in OR after the said period.
Cash transaction is not just limited to physical currencies
such as bank notes and coins but also includes bearer
negotiable instruments such as travellers’ cheques,
vouchers, cash cheques and precious metals and/or
stones. If your customers deposit ‘cash’ over the
counter or via CDM into your bank accounts, that is
also considered cash.
Cash transaction excludes bank drafts, cheques and
electronic transfers.
Calculation of cash transactions should cover both
incoming and outgoing payments.
If the money is released from bank loans straight into the
firm’s or vendor’s accounts for initial or subsequent
payments, this is not considered as cash transaction.

NO. QUESTION
29. My firm has a legal person
customer with 3 foreign
shareholders. Should I
include the foreign
shareholder as part of
foreigner client under
question B6?
30. My customer is a Sendirian
Berhad company owned by
foreign individuals. Do I
consider my customer as
local or foreign client?
31. What is meant by non face-
to-face?
Is a video call considered
face-to-face or non face-to-
face?
32. What is meant by "formal
domestic/ international
affiliations"?
33. I am a DPMS and do not
have any cash transactions
equal to RM50,000 or more.
Do I still need to answer Part
B?
Implementation of AML/CFT Measures
34. What is meant by delayed
verification?
35
ANSWER
Yes, only when the foreign shareholders are deemed as
beneficial owner.
As provided in paragraph 14A.9.6 of the Policy Document,
RIs should identify the beneficial owners of legal persons
through the steps provided in the Policy Document.
The customer is considered as local customer. However, if
the beneficial owner of such customer is foreign person,
the information should be filled in Question 5 of Part B.
Non face-to-face refers to a scenario where the customer
is not physically present in the process where RIs on-
boards the customer and completes the CDD process.
Examples of non face-to-face interactions include but are
not limited to phone call, mobile applications or website/ e-
commerce platform. Video call is considered face-to-face.
Domestic or international affiliations refers to formal
arrangements with either domestic or international firms
to acquire a wider reach to customers (e.g., marketing
purposes). Do note that this does not constitute branch
and head office relationships.
Yes, DPMS still needs to complete all parts of the DCR.
For questions 21, 22 and 23 of Part B, DPMS with no cash
transactions equivalent to RM50,000 and above, either in
single transaction or linked, can fill in zero (‘0’) in the
relevant columns.
Verification is conducted and completed after the
establishment of the business relationship with a customer
or beneficial owner.
Delayed verification is allowed under selected
circumstances where verification is not possible at the
point of establishing the business relationship. Please
refer to paragraph 14.10.20 of the Policy Document for
more details on delayed verification.
 36

NO. QUESTION ANSWER

35. What is the difference Please refer to Question 42 in the Frequently Asked
between “source of wealth” Questions on AML/CFT and TFS for DNFBPs and NBFIs,
and “source of funds”? which can be accessed here.

36. What is meant by repeat Repeat customers refer to someone whom a firm has
customers? established a business relationship previously and has
returned for subsequent/other transactions or dealings.

Company Secretaries
37. As a company secretary, am No. The obligation to ensure that the DCR is submitted is
I obligated to ensure that all on the RI and its own compliance officer.
my customers who are RIs
submit the DCR?
The company secretary is only responsible for its own
firm’s submission and not the customers’.

38. My firm is appointed as DCR is filled and submitted based on your firm's
external company secretary business (as Company Secretary) and not your clients'.
to multiple companies. Do Each firm who is an RI needs to submit one DCR.
we have to submit 1 DCR for
each of my clients?
39. Are in-house company In-house company secretaries acting for Financial
secretaries for Financial Institutions are not required to submit the DCR.
Institutions required to
submit the DCR?

40. We have two firms in the One DCR by each firm that provides Gazetted Activities.
same group that provides
company secretarial
services and both firms
handle similar portfolio of
clients. How many DCR
should we submit?

41. Does total transactions refer No. Total transactions (in number and value) refers to
to annual revenue for all transactions made between you and your clients.
clients?

Lawyers
42. My firm has 3 lawyers Each firm is only required to submit one DCR.
carrying out Gazetted
Activities. How many DCRs
should the firm submit?
 37

NO. QUESTION ANSWER

43. My law firm provides Yes, deposit payment for the purpose of SPA made by
conveyancing services. One customers in cash into the customers’ account of the firm
of my customers paid half of is considered as cash transaction.
the deposit for the Sales and
Purchase Agreements (SPA)
by using cash. Should this
be considered as cash
transactions for the firm?

44. i. My firm provides both i. Two sets of DCRs according to business activities.
legal and company
secretarial services.
How many DCRs should
I submit?

ii. I am a lawyer and notary ii. Only one DCR.

public. Do I submit DCR
separately or as one for
my firm?

45. How do I calculate number Number of transactions

and value of transactions?
i. Refers to number of files/deals/matters facilitated or
attended by the law firm. All related services rendered
for the same deal/matter are considered as one (1)
transaction.
• For example, the services rendered for the
purchase of a property and all related
payments made should be considered as one
(1) single transaction (i.e. preparation of SPA,
preparation of loan agreement, charge to bank
and other ancillary services).

ii. For a file/deal/matter that involves more than one

Gazetted Activity (GA), law firm may report all related
services rendered or transactions facilitated under the
core transaction.
• For example, for a transaction of sale and
purchase of a property (GA 1 – buying and
selling of immovable property), if the money
was deposited by the client into the law firm's
client account as stakeholder pending the
completion of the transaction (GA 2 - managing
of client’s money, securities or other property),
law firm may report such transaction and client
under GA 1 only.
Value of transactions
Refers to value of deals or services facilitated or attended
by the law firm. Excluding legal fees and other
reimbursement such as stamp duty, registration fees, etc.
 38

NO. QUESTION ANSWER

• For example, for a sale and purchase of a
property, the value of the transaction would be
the purchase price of the property.

46. i. My firm has just started Yes, if the firm provides Gazetted Activities, the firm needs
operation in 2021. Am I to submit DCR.
required to submit DCR?
You may fill in ‘zero’ for information relating to transaction
ii. Previously, my firm only in 2020 especially in Part B and provided explanation at
provided litigation the end of Part B in the free text column.
services and started to You are not required to fill any declaration form for non-
provide conveyancing provision of Gazetted Activities in 2020.
services (Gazetted
Activities) in 2021.
Do we still need to fill in
DCR and fill in
Declaration Form for
Non-Provision of
Gazetted Activities for
2020?
47. Do we need to submit the Yes, DCR submission is required as long as your firm
DCR if our firm has a client’s provides Gazetted Activities, regardless of whether the
account but do not hold any firm holds or does not hold clients' money in the clients'
monies for our client in the account.
client’s account?

48. If the firm has two COs If the different Gazetted Activities fall under a single sector
representing different (i.e., lawyer), only 1 DCR should be submitted by the firm.
Gazetted Activities
undertaken by the firm,
should each of the CO
submit his/her own DCR or
both COs should issue only
1 DCR for the firm?
49. My firm acts for banks in By the banking group i.e., counted as one client.
preparation of loan
documents. Normally, loans
are processed and approved
by several different
branches. Do I count my
client by the banking group
or number of branches that I
dealt with?

Gaming Outlets
50. Does number of transactions
refer to customers who
purchase lottery ticket
(punters) or winners?
For question 2 until 4 of Part B, number of transactions
and customers should be based on all business activities.
Hence, it should be based on number of punters.
 39

NO. QUESTION ANSWER

Moneylenders
51. We have three Each moneylending company with a valid license should
moneylending companies submit one DCR.
with separate licenses
managed by the same
directors. How many DCR
reports should we submit?

Registered Estate Agents

52. Does total number of Total number of customers should include every party that
customers include number of your firm represents either tenant, buyer or owner. If you
tenant, buyer and owner? only represent a buyer in a property purchase, your firm's
customer is the buyer.
 40

DCR 2021

Reporting institutions can access and download the full set of DCR 2021 questions in PDF
format by accessing this link:
http://amlcft.bnm.gov.my/dcr/FullDCR.pdf
Note: The above document features questions for all sectors. You may refer to questions that are relevant to
your sectors, especially for Part B.

End of Document