SIDC Module 6 Market conduct, client treatment and AML/CFT question: walk-in prospect offers RM8,000 in cash to open a trading account but leaves without

SIDC Module 6Market conduct, client treatment and AML/CFT

A walk-in prospect offers RM8,000 in cash to open a trading account but leaves without opening it when asked where the cash came from. The firm is suspicious. What should it do?

A Take no action, since no account was opened and no transaction took place
B Lodge an STR with the FIED, because attempted transactions are reportable whatever the amount
C Take no action, since the amount is too small to warrant a suspicious transaction report
D Report the matter to the SC, which forwards capital market STRs to the police

Show the answer and explanation

Answer: B. Lodge an STR with the FIED, because attempted transactions are reportable whatever the amount

Paragraph 11.8 of the SC's AML/CFT/CPF Guidelines requires a reporting institution to report all suspicious transactions, including attempted transactions, regardless of the amount. Paragraph 11.6 says that where it has reasonable grounds to suspect proceeds of unlawful activity, the transaction should be reported immediately to the Financial Intelligence and Enforcement Department (FIED) of Bank Negara Malaysia by lodging an STR. An abandoned account opening is still an attempted transaction, so 'nothing happened' is no defence. There is no minimum ringgit threshold for STRs, and STRs go to the FIED, not to the SC or the police. Source: SC Guidelines on Prevention of Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing and Targeted Financial Sanctions for Reporting Institutions in the Capital Market (SC-GL/AML-2014 (R3-2024), revised 13 June 2024) paras 11.6, 11.8; Appendix C (as at October 2026).

Common mistake

Thinking an STR needs a completed transaction or a minimum amount.

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Original study material mapped to the public SIDC Module 6 syllabus. Unofficial, not endorsed by SIDC or the SC. Verify figures and rules against current guidance before relying on them.