Keep your licence clean from day one.
An AML and CFT programme is the set of controls a Labuan entity runs to detect money laundering and terrorism financing. We design it, operate it, and keep it aligned to Labuan FSA and AMLA.
Make an enquiryWhere AML and CFT programmes slip.
Once a Labuan entity takes on clients and moves money, it carries a standing obligation: identify customers, watch transactions, screen against sanctions, and report suspicion. The guidelines keep moving, and a single named officer stays accountable for the whole programme.
We build and run the programme as your outsourced compliance function. Documented procedures, ongoing operation and direct familiarity with Labuan FSA expectations keep the controls holding up under review, with nothing material left undone.
See what we handleA licensed Labuan trust company carrying your AML load.
QX Trust Co. Ltd is a Labuan Managed Trust Company headquartered in Labuan IBFC. We build and run the programme under your licence, not through an intermediary. We serve you in English, Chinese and Malay.
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Labuan FSA licensed
LMT0081
Our Labuan licence
EN + ZH + MS
Language desks
Labuan IBFC
Headquartered
What an AML and CFT programme covers.
Six controls assembled into one programme, aligned to Labuan FSA guidelines and the Malaysian AMLA, then operated on an ongoing basis.
Customer due diligence
Procedures to identify and verify customers and beneficial owners, understand the purpose of each relationship, and capture the data set the guidelines require. The starting point of every onboarding.
Enhanced due diligence
Deeper checks for higher risk relationships such as politically exposed persons, complex ownership and higher risk jurisdictions, adding source of funds, source of wealth and closer monitoring.
Transaction monitoring
Ongoing surveillance of activity against the expected profile of each relationship, with internal criteria to flag the unusual and route it for review before any conclusion is reached.
Sanctions and TFS screening
Screening of customers and counterparties against sanctions and targeted financial sanctions lists, with a process to handle matches and the obligations that follow a positive hit.
Suspicious transaction reporting
Evaluation of internal reports and, where suspicion is established, a suspicious transaction report to the Financial Intelligence and Enforcement Department at Bank Negara Malaysia, with Labuan FSA kept informed.
Training and independent review
Staff training so the controls are understood and applied, record keeping that stands up to scrutiny, and an independent review cycle that tests the programme and feeds the required audit reporting.
From risk assessment to a running programme.
Four steps to stand up the AML and CFT function, run by the team that operates it afterwards.
Risk assessment
We map your money laundering and terrorism financing risk across products, customers, channels and geographies. The assessment sets where standard due diligence applies and where enhanced checks are triggered.
Policies and procedures
We draft the AML and CFT policy, the procedures manual and the screening and reporting workflows, calibrated to your business and aligned to Labuan FSA guidelines and the AMLA.
Officer and onboarding
We put the compliance officer arrangement in place, train your staff, and onboard the controls so screening, monitoring and reporting run from the first transaction.
Operation and review
We run the programme day to day: due diligence, monitoring, screening and reporting. We schedule the independent review and refresh procedures as the guidelines move.
One programme, one named owner.
An AML and CFT programme only works when someone is accountable for it. A Labuan entity appoints a compliance officer who runs the controls, evaluates internal reports before they are filed, and stays alert to risk in new products and operational change. We carry that weight as your outsourced function, while accountability stays with your board.
- A designated compliance officer runs the programme and makes the reporting decision.
- Internal reports are evaluated before any suspicious transaction report is filed.
- Reports go to the Financial Intelligence and Enforcement Department at Bank Negara Malaysia, on the next working day after suspicion is established.
- The AML Policy Unit of Labuan FSA is kept informed in line with the guidelines.
- If the officer role falls vacant, Labuan FSA is notified within ten working days and a replacement identified within thirty days.
- Outsourced operation, board accountability retained. We run the work, you hold the line.
Frequently asked.
Direct answers on scope, reporting, the compliance officer and the role we play.
What does an AML and CFT programme include for a Labuan entity?
An AML and CFT programme covers customer due diligence and enhanced due diligence procedures, ongoing transaction monitoring, sanctions and targeted financial sanctions screening, suspicious transaction reporting, record keeping, staff training and an independent review cycle. It also names a compliance officer responsible for the programme. The framework aligns with Labuan FSA AML, CFT and TFS guidelines and the Malaysian Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001.
Who does a Labuan entity report a suspicious transaction to?
A Labuan reporting institution evaluates an internally generated suspicious transaction report and, where suspicion is established, submits a suspicious transaction report to the Financial Intelligence and Enforcement Department at Bank Negara Malaysia. The compliance officer also keeps the AML Policy Unit of Labuan FSA informed in line with the guidelines. The report is made promptly, on the next working day after the suspicion is established.
Does a Labuan entity need a compliance officer for AML and CFT?
Yes. A Labuan reporting institution appoints a compliance officer who is accountable for the AML and CFT programme, including detecting suspicious transactions, evaluating internal reports before filing, and identifying money laundering and terrorism financing risks in new products or operational changes. If the role falls vacant, Labuan FSA is notified within ten working days and a replacement is identified within thirty days of the vacancy.
Can a Labuan entity outsource its AML and CFT programme?
Yes. Labuan FSA permits the outsourcing of operational AML and CFT work, including due diligence, transaction monitoring, screening and policy maintenance, provided the entity retains accountability through a designated compliance officer and board oversight. The outsourced provider must be suitably qualified and engaged under a clear service agreement. We build and run the programme while accountability stays with your board and compliance officer.
What is the difference between customer due diligence and enhanced due diligence?
Customer due diligence is the standard process of identifying and verifying a customer and beneficial owner and understanding the purpose of the relationship. Enhanced due diligence applies to higher risk relationships, such as politically exposed persons, complex ownership structures or higher risk jurisdictions, and adds deeper verification, source of funds and source of wealth checks, and closer ongoing monitoring. The level applied follows the entity's documented risk assessment.
How often should an AML and CFT programme be reviewed?
An AML and CFT programme is kept current through an independent review cycle and is updated when the business, products, customer base or regulatory guidelines change. Labuan FSA expects periodic compliance and AML and CFT audit reporting, and the programme should reflect the latest Labuan FSA guidelines and AMLA requirements rather than a fixed snapshot. We schedule the review and refresh the procedures as standards move.
Does QX Trust provide legal opinions on AML and CFT obligations?
We provide advisory and documentation: programme design, procedures, training and ongoing operation aligned to Labuan FSA and AMLA standards. Where a formal legal opinion is needed, we coordinate external counsel to provide it. We do not issue legal opinions ourselves.
Building or outsourcing an AML and CFT programme?
Tell us about your entity and what it does. We assess the risk, draft the procedures, and run the programme to Labuan FSA and AMLA standards.
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