Labuan IBFC Licensed Trust Company
Our Services

Labuan Compliance Function

Compliance framework design, risk management, corporate governance advisory and AML/CFT/CPF programmes for Labuan entities. Tailor-made setup or ongoing monthly support, built and managed by the Signature Trust compliance team.

Legislation
AMLATFPUA 2001
Scope
Framework, Risk, Governance & AML
Reporting
FIED & Labuan FSA
Approach
Outsourced, Not Overhead

Outsource your Labuan compliance function to licensed experts

Signature Trust delivers a complete outsourced compliance solution for Labuan FSA licensees. We design frameworks, build risk management and internal controls, advise on governance, draft AML/CFT/CPF programmes covering Counter Proliferation Financing (CPF) and Targeted Financial Sanctions (TFS), and provide ongoing support to your Designated Compliance Officer (DCO). All work is performed under the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLATFPUA 2001) and current Labuan FSA guidelines.

Outsourcing arrangements are subject to Labuan FSA approval and conducted under its oversight, ensuring accountability remains with your Board and appointed DCO.

Request a consultation

Two ways to engage the compliance function

Tailor-made setup builds your compliance function from scratch. Monthly outsourcing keeps it running. Many clients engage both, while others outsource only selected functions.

Tier One

Tailor-Made Compliance Setup

A one-time engagement that builds your compliance function from scratch. We establish the framework and management structure, recruit and interview suitable talent, draft all rules, policies, procedures, templates and agreements, and deliver initial AML/CFT/CPF training.

The output is a documented, operational compliance function ready for Labuan FSA review.

  • Framework and management structure design
  • Recruitment and interviewing of compliance personnel
  • Rules, procedures, checklists, forms and templates
  • Initial AML/CFT/CPF and statutory training
Tier Two

Monthly Compliance Outsourcing

Ongoing monthly support alongside your Designated Compliance Officer and team. We provide guidance on programme application, proper maintenance of records, customer due diligence, ongoing due diligence and STR reporting under the AMLATFPUA 2001.

Keeps the compliance function running without the cost of a full in-house department.

  • Monthly guidance to your DCO and team
  • CDD, ongoing due diligence and record-keeping support
  • STR preparation to FIED and Labuan FSA
  • Policy updates as Labuan FSA guidance evolves

Your compliance function, covered from start to finish

Why Signature Trust

We Practice What We Advise

As a Labuan FSA licensed trust company, we are subject to the same compliance, risk and governance standards we help our clients implement, giving us practical, firsthand knowledge of the regulatory expectations.

CAMCO-Certified Expertise

Our Compliance Officer holds the Certified Anti-Money Laundering and Counter Financing of Terrorism Compliance Officer (CAMCO) certification, with hands-on experience across compliance framework design, risk management and Labuan FSA examination preparation.

Integrated AML, Governance and Risk

Compliance specialists work alongside Licensed Secretaries, Accountants and Legal professionals, so risk management, governance, legal advisory and AML/CFT execution sit within one integrated team.

Sensitive Data, Strictly Handled

Compliance functions handle sensitive client data, suspicious transaction reports and internal risk assessments. We maintain the highest level of confidentiality across every engagement.

CAMCO Credential

Our Compliance Officer holds the Certified Anti-Money Laundering and Counter Financing of Terrorism Compliance Officer (CAMCO) certification, with hands-on experience across compliance framework design, risk management and Labuan FSA examination preparation. CAMCO is the recognised industry credential for AML/CFT compliance professionals operating within the Malaysian regulatory regime.

From compliance gap to fully functioning programme

1

Consultation

We review your current compliance arrangements, licence category and applicable obligations, covering risk, governance, AML/CFT/CPF and TFS. We identify any gaps and confirm whether a Designated Compliance Officer appointment is required by Labuan FSA.

2

Proposal

We prepare an engagement proposal covering the scope of the compliance function: framework design, risk management, governance advisory, policy drafting, AML/CFT programme, DCO appointment where required and the ongoing reporting obligations included in the retainer.

3

Onboarding

We draft or review your compliance framework, risk and governance policies, AML/CFT/CPF manual, KYC procedures and internal controls. Where a Designated Compliance Officer is to be appointed, we complete the required notification to Labuan FSA and set up the compliance function end to end.

4

Execution

We operate the compliance function or your selected outsourced services on an ongoing basis: monitor transactions, conduct periodic risk reviews, advise on governance matters, prepare regulatory reports and update policies as Labuan FSA guidance evolves.

Frequently asked questions

Common questions about the Labuan compliance function.

What does a tailor-made compliance outsourcing service include?

The tailor-made compliance outsourcing service covers the full setup of your compliance function. This includes establishing the compliance framework and management structure, recruiting and interviewing suitable compliance personnel, drafting AML/CFT guidelines and all related policies, drafting rules, procedures, checklists, forms and templates, drafting relevant agreements, delivering AML/CFT and annual statutory compliance training, and providing risk management, internal control and corporate governance advisory. The output is a complete, documented compliance infrastructure ready for regulatory review.

How does monthly compliance outsourcing work in practice?

On a monthly basis, the Signature Trust compliance team works alongside your Designated Compliance Officer and team to provide guidance on current AML/CFT requirements and ensure that policies are properly implemented. This includes supporting effective execution of customer due diligence, record-keeping, ongoing due diligence, suspicious transaction reporting and counter-terrorism financing measures. The arrangement is structured so your team has expert support available on an ongoing basis without the cost of a full in-house compliance department.

How are suspicious transactions reported in Labuan?

Labuan licensees must report suspicious transactions to the Financial Intelligence and Enforcement Department (FIED) of Bank Negara Malaysia and concurrently notify the AML Policy Unit of Labuan FSA. Signature Trust assists with STR preparation and maintains internal red-flag criteria to identify suspicious activity, including triggers related to Counter Proliferation Financing (CPF) and Targeted Financial Sanctions (TFS). Final evaluation and submission of each STR remain the responsibility of your appointed DCO. We also manage requisite periodic reporting to the Authority.

What is a Designated Compliance Officer and is one required in Labuan?

A Designated Compliance Officer (DCO) is the individual within a Labuan entity who is responsible for the day-to-day management of the compliance function, including oversight of AML/CFT/CPF policies, customer due diligence procedures and suspicious transaction reporting. Every Labuan licensee must appoint a DCO who is adequately trained and empowered with authority and resources to perform compliance duties effectively. For entities without suitable in-house personnel, Signature Trust Ltd can provide the compliance officer function as part of its outsourced compliance service, subject to Labuan FSA approval.

What is the difference between the tailor-made setup and the monthly compliance service?

The tailor-made compliance setup is a one-time engagement that builds your compliance function from scratch. It covers framework design, policy drafting, recruitment, agreements and initial training. The monthly compliance service is an ongoing arrangement where the Signature Trust compliance team works alongside your Designated Compliance Officer to keep the compliance function running, policies implemented and reporting obligations met. Many clients engage the tailor-made setup first and then transition to the monthly service. Others engage both from the outset. The two services are designed to work together.

Does a Labuan company need an AML policy?

Yes. All Labuan entities that fall under the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLATFPUA 2001) are required to have documented AML/CFT policies in place. This applies to all Labuan FSA licensees and, to varying degrees, to other Labuan entities carrying on relevant business activities. The policy must cover customer due diligence (CDD) and KYC procedures, record-keeping obligations, internal suspicious transaction reporting channels and counter-terrorism financing controls. Labuan FSA expects the AML policy to be tailored to the specific business activities and risk profile of the entity, not a generic template. Signature Trust drafts and implements AML/CFT and KYC policies as part of both the tailor-made setup and the monthly compliance outsourcing service.

Related articles

Build your compliance function without the overhead

Signature Trust sets up and runs your compliance programme so you stay focused on your business.