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BIODATA - NIK ZAFRI


 



NIK ZAFRI BIN ABDUL MAJID,
CONSULTANT/TRAINER
Email: nikzafri@yahoo.com, nikzafri@gmail.com
https://nikzafri.wixstudio.com/nikzafriv2

Kelantanese, Alumni of Sultan Ismail College Kelantan (SICA), Business Management/Administration, IT Competency Cert, Certified Written English Professional US. Has participated in many seminars/conferences (local/ international) in the capacity of trainer/lecturer and participant.

Affiliations :- Council/Network Member of Gerson Lehrman Group, Institute of Quality Malaysia, Auditor ISO 9000 IRCAUK, Auditor OHSMS (SIRIM and STS) /EMS ISO 14000 and Construction Quality Assessment System CONQUAS, CIDB (Now BCA) Singapore),

* Possesses almost 30 years of experience/hands-on in the multi-modern management & technical disciplines (systems & methodologies) such as Knowledge Management (Hi-Impact Management/ICT Solutions), Quality (TQM/ISO), Safety Health Environment, Civil & Building (Construction), Manufacturing, Motivation & Team Building, HR, Marketing/Branding, Business Process Reengineering, Economy/Stock Market, Contracts/Project Management, Finance & Banking, etc. He was employed to international bluechips involving in national/international megaprojects such as Balfour Beatty Construction/Knight Piesold & Partners UK, MMI Insurance Group Australia, Hazama Corporation (Hazamagumi) Japan (with Mitsubishi Corporation, JA Jones US, MMCE and Ho-Hup) and Sunway Construction Berhad (The Sunway Group of Companies). Among major projects undertaken : Pergau Hydro Electric Project, KLCC Petronas Twin Towers, LRT Tunnelling, KLIA, Petronas Refineries Melaka, Putrajaya Government Complex, Sistem Lingkaran Lebuhraya Kajang (SILK), Mex Highway, KLIA1, KLIA2 etc. Once serviced SMPD Management Consultants as Associate Consultant cum Lecturer for Diploma in Management, Institute of Supervisory Management UK/SMPD JV. Currently – Associate/Visiting Consultants/Facilitators, Advisors/Technical Experts for leading consulting firms (local and international), certification bodies including project management. To name a few – Noma SWO Consult, Amiosh Resources, Timur West Consultant Sdn. Bhd., TIJ Consultants Group (Malaysia and Singapore), QHSEL Consultancy Sdn. Bhd.

He is also currently holding the Position of Principal Consultant/Executive Director (Special Projects) - Systems and Methods, ESG, QHSE at QHSEL Consultancy Sdn. Bhd.* Ex-Resident Weekly Columnist of Utusan Malaysia (1995-1998) and have produced more than 100 articles related to ISO-9000– Management System and Documentation Models, TQM Strategic Management, Occupational Safety and Health (now OHSAS 18000) and Environmental Management Systems ISO 14000. His write-ups/experience has assisted many students/researchers alike in module developments based on competency or academics and completion of many theses. Once commended by the then Chief Secretary to the Government of Malaysia for his diligence in promoting and training the civil services (government sector) based on “Total Quality Management and Quality Management System ISO-9000 in Malaysian Civil Service – Paradigm Shift Scalar for Assessment System”

Among Nik Zafri’s clients : Adabi Consumer Industries Sdn. Bhd, (MRP II, Accounts/Credit Control) The HQ of Royal Customs and Excise Malaysia (ISO 9000), Veterinary Services Dept. Negeri Sembilan (ISO 9000), The Institution of Engineers Malaysia (Aspects of Project Management – KLCC construction), Corporate HQ of RHB (Peter Drucker's MBO/KRA), NEC Semiconductor - Klang Selangor (Productivity Management), Prime Minister’s Department Malaysia (ISO 9000), State Secretarial Office Negeri Sembilan (ISO 9000), Hidrological Department KL (ISO 9000), Asahi Kluang Johor(System Audit, Management/Supervisory Development), Tunku Mahmood (2) Primary School Kluang Johor (ISO 9000), Consortium PANZANA (HSSE 3rd Party Audit), Lecturer for Information Technology Training Centre (ITTC) – Authorised Training Center (ATC) – University of Technology Malaysia (UTM) Kluang Branch Johor, Kluang General Hospital Johor (Management/Supervision Development, Office Technology/Administration, ISO 9000 & Construction Management), Kahang Timur Secondary School Johor (ISO 9000), Sultan Abdul Jalil Secondary School Kluang Johor (Islamic Motivation and Team Building), Guocera Tiles Industries Kluang Johor (EMS ISO 14000), MNE Construction (M) Sdn. Bhd. Kota Tinggi Johor (ISO 9000 – Construction), UITM Shah Alam Selangor (Knowledge Management/Knowledge Based Economy /TQM), Telesystem Electronics/Digico Cable(ODM/OEM for Astro – ISO 9000), Sungai Long Industries Sdn. Bhd. (Bina Puri Group) - ISO 9000 Construction), Secura Security Printing Sdn. Bhd,(ISO 9000 – Security Printing) ROTOL AMS Bumi Sdn. Bhd & ROTOL Architectural Services Sdn. Bhd. (ROTOL Group) – ISO 9000 –Architecture, Bond M & E (KL) Sdn. Bhd. (ISO 9000 – Construction/M & E), Skyline Telco (M) Sdn. Bhd. (Knowledge Management),Technochase Sdn. Bhd JB (ISO 9000 – Construction), Institut Kefahaman Islam Malaysia (IKIM – ISO 9000 & Internal Audit Refresher), Shinryo/Steamline Consortium (Petronas/OGP Power Co-Generation Plant Melaka – Construction Management and Safety, Health, Environment), Hospital Universiti Kebangsaan Malaysia (Negotiation Skills), Association for Retired Intelligence Operatives of Malaysia (Cyber Security – Arpa/NSFUsenet, Cobit, Till, ISO/IEC ISMS 27000 for Law/Enforcement/Military), T.Yamaichi Corp. (M) Sdn. Bhd. (EMS ISO 14000) LSB Manufacturing Solutions Sdn. Bhd., (Lean Scoreboard (including a full development of System-Software-Application - MSC Malaysia & Six Sigma) PJZ Marine Services Sdn. Bhd., (Safety Management Systems and Internal Audit based on International Marine Organization Standards) UNITAR/UNTEC (Degree in Accountacy – Career Path/Roadmap) Cobrain Holdings Sdn. Bhd.(Managing Construction Safety & Health), Speaker for International Finance & Management Strategy (Closed Conference), Pembinaan Jaya Zira Sdn. Bhd. (ISO 9001:2008-Internal Audit for Construction Industry & Overview of version 2015), Straits Consulting Engineers Sdn. Bhd. (Full Integrated Management System – ISO 9000, OHSAS 18000 (ISO 45000) and EMS ISO 14000 for Civil/Structural/Geotechnical Consulting), Malaysia Management & Science University (MSU – (Managing Business in an Organization), Innoseven Sdn. Bhd. (KVMRT Line 1 MSPR8 – Awareness and Internal Audit (Construction), ISO 9001:2008 and 2015 overview for the Construction Industry), Kemakmuran Sdn. Bhd. (KVMRT Line 1 - Signages/Wayfinding - Project Quality Plan and Construction Method Statement ), Lembaga Tabung Haji - Flood ERP, WNA Consultants - DID/JPS -Flood Risk Assessment and Management Plan - Prelim, Conceptual Design, Interim and Final Report etc., Tunnel Fire Safety - Fire Risk Assessment Report - Design Fire Scenario), Safety, Health and Environmental Management Plans leading construction/property companies/corporations in Malaysia, Timur West Consultant : Business Methodology and System, Information Security Management Systems (ISMS) ISO/IEC 27001:2013 for Majlis Bandaraya Petaling Jaya ISMS/Audit/Risk/ITP Technical Team, MPDT Capital Berhad - ISO 9001: 2015 - Consultancy, Construction, Project Rehabilitation, Desalination (first one in Malaysia to receive certification on trades such as Reverse Osmosis Seawater Desalination and Project Recovery/Rehabilitation), ABAC Centre of Excellence UK (ABMS ISO 37001) Joint Assessment (Technical Expert)

* Has appeared for 10 consecutive series in “Good Morning Malaysia RTM TV1’ Corporate Talk Segment discussing on ISO 9000/14000 in various industries. For ICT, his inputs garnered from his expertise have successfully led to development of work-process e-enabling systems in the environments of intranet, portal and interactive web design especially for the construction and manufacturing. Some of the end products have won various competitions of innovativeness, quality, continual-improvements and construction industry award at national level. He has also in advisory capacity – involved in development and moderation of websites, portals and e-profiles for mainly corporate and private sectors, public figures etc. He is also one of the recipients for MOSTE Innovation for RFID use in Electronic Toll Collection in Malaysia.

Note :


TO SEE ALL ARTICLES

ON THE"LABEL" SECTION BELOW (RIGHT SIDE COLUMN), YOU CAN CLICK ON ANY TAG - TO READ ALL ARTICLES ACCORDING TO ITS CATEGORY (E.G. LABEL : CONSTRUCTION) OR GO TO THE VERY END OF THIS BLOG AND CLICK "Older Posts"


 

Showing posts with label FRAUD. Show all posts
Showing posts with label FRAUD. Show all posts

Monday, July 07, 2025

Exposing Modern Investment Frauds - Forex, Stock Market, and Cryptocurrency Traps - Overview by Nik Zafri


In the ever evolving world of digital finance, fraud and scams have also evolved becoming more sophisticated, harder to detect, and dangerously convincing. Investors, especially those new to online trading, are now increasingly vulnerable to elaborate schemes involving fake Forex platforms, stock market trading sites, and cryptocurrency exchanges.

1) The Illusion of Legitimacy

Fraudsters deploy advanced digital tactics to appear legitimate.

1. Fake Live Charts

Many fraudulent platforms use convincing, real-time charts to simulate active trading. These charts are entirely controlled by a back-end operator and bear no connection to actual market data. Investors are lured by apparent gains, only to be denied withdrawals later under false pretenses (e.g., needing to “upgrade accounts” or pay “taxes”).

2. Bogus Licensing and Fake Review Portals

Fraudsters create fake websites mimicking regulatory bodies or ranking agencies. These sites display fabricated ratings and licensing credentials, often appearing high on Google search results thanks to paid ads and SEO manipulation. Victims may believe they're investing through a "licensed broker" or "top-rated crypto exchange."

3. Interactive and Engaging Fake Platforms

Well-designed websites offer demo accounts, AI chatbots, and "account managers" to build trust. Some even use deepfake video calls or pre-recorded webinars to showcase fake testimonials and investor success stories.

4. Pretending to Fight Scams

In a bold twist, some fraudulent websites go to great lengths to appear trustworthy by displaying "anti-scam" warnings on their own platforms. They may even include links to real regulatory authorities like the SEC, FCA, or local police departments. This reverse psychology tactic is designed to lower your guard and convince you they are above suspicion.


2) Reducing the Risk - What You Can Do

1) Verify Licensing with Official Sources

In Malaysia, verify a broker or platform’s registration with:

Securities Commission Malaysia (SC) or Bank Negara Malaysia (BNM)

Both regulators provide Investor Alert Lists that identify unlicensed or suspicious entities.

1.1) International Verification


For international checks, refer to:

  • Financial Conduct Authority (UK)
  • U.S. SEC’s Investment Adviser Public Disclosure
  • IOSCO (International Organization of Securities Commissions)

Avoid Platforms That:

  • Pressure you into “urgent” investments
  • Ask for payment via crypto or gift cards
  • Block withdrawals without explanation
  • Have no physical address or hide behind offshore jurisdictions

Report Immediately

Victims or whistleblowers can file reports with:

  • CCID (Commercial Crime Investigation Department) – PDRM
  • CyberSecurity Malaysia
  • SC Malaysia Investor Affairs – hotline or online form
  • The National Scam Response Centre (NSRC)

Conclusion

Financial scams today are not run by amateurs, they are often coordinated operations involving web developers, social engineers, and online marketers. The key defense is awareness, skepticism, and verification through official channels. Never let the appearance of legitimacy override proper due diligence.


#InvestmentScamAlert #CryptoFraudAwareness #ForexScamPrevention #VerifyBeforeYouInvest #StopOnlineScams

MALAYSIANS INVOLVEMENT IN COUNTERFEIT CARD OPERATIONS IN THE UK

Based on the online news, "Foot Soldiers" and one of the leaders of the organized crime from Eastern Europe for skimming and hidden cameras at ATMs have been caught by the Fraud Squad from both UK City and Metropolitan Police.

One of their greatest bust is a huge delivery of more than 2000 counterfeit cards (Citibank, Standard Chartered, DBS etc complete with Visa/Mastercard, Hologram features and magnetic strip (to store compromised data) for swipe with signature, all without chip/pin facilities (using only swipe) from Malaysia to another young Malaysian man renting a room in North London.

During the raid, search in the room found lists of account numbers, foil to emboss the credit cards and details of regular shipments from Malaysia. If the cards haven't been intercepted, stolen British account details would have been encrypted onto the magnetic strips.

What’s particularly disturbing to me is the involvement of Malaysians in such sophisticated and intricate criminal operations. It’s a stark reminder that the issue isn’t just international, it has local roots too.

I sincerely hope the Malaysian government will urgently re-examine the operations of licensed security printing companies, investigate the possible involvement of bank insiders, and crack down on underground black-market printers, in order to strengthen oversight and prevent further abuse of our financial systems.

#FinancialCrime #CardFraud

According to The Register, a total of 105 individuals suspected of credit card fraud were arrested across Asia and Europe following a complex, months-long investigation spanning two continents.

The operation focused on a syndicate allegedly led from Malaysia, with networks extending into 14 European countries including the UK and Germany that specialized in using counterfeit credit cards to purchase high-value goods.

As part of the coordinated takedown, nine suspects were arrested in Malaysia and 76 in various parts of Europe. The crackdown included multiple raids on targeted locations, including two sites believed to be used for producing “high-quality” counterfeit credit cards.

During the searches, authorities seized approximately 3,000 counterfeit payment cards, along with fake passports, surveillance equipment, jewellery, and large sums of cash.

Sunday, July 06, 2025

Cases where money disappear from customer's account - it's not a scam but fraud - By Nik Zafri

Free AI Generated from Google Search 



Disclaimer: This short article is not intended to discredit or generalize all banking institutions. Its purpose is solely to raise awareness and help customers understand the possible risks, as well as the appropriate steps to take should such incidents occur. Responsible banking practices and customer vigilance are both essential in maintaining trust and security.

A bank is expected to serve as a secure and trustworthy place to safeguard one’s money. However, there have been troubling incidents where funds have mysteriously gone missing, not due to scams, but without any clear trace accessible to the customer. In several cases, it was discovered that the theft was committed by the bank’s own staff, representing a serious breach of trust and governance. Such incidents typically involve insider threats, manipulation of internal systems, or exploitation of security vulnerabilities. In response, the bank has taken steps to strengthen its internal controls, enhance staff screening processes, and upgrade its cybersecurity measures.

Not limited to the following, these are some possible fraud cases and how the theft is disguised.





PREVENTIVE MEASURES (many have been adopted by the Banks)

1. Strong Segregation of Duties

  • Prevent the same employee from initiating and approving transactions,
  • Implement dual or triple controls for sensitive operations.

2. Mandatory Audit Trails

  • Ensure tamper-proof, automated, and real-time logging of all activities.
  • Logs must be independently monitored.

3. Behavioral Monitoring and AI Alerts

Use AI tools to flag unusual employee behavior (e.g., accessing dormant accounts, frequent manual overrides).

4. Strict Role-Based Access Control (RBAC)

  • Limit access to transaction systems based on job role,
  • Regularly review access privileges.

5. Regular Reconciliation and Surprise Audits 

  • Reconcile customer transactions with system logs daily,
  • Conduct surprise audits on branches and back offices.

6. Customer Notification Systems

  • Immediate SMS/email alerts for any withdrawal, transfer, or account update.
  • Let customers flag unauthorized transactions promptly.

7. Whistleblower Mechanism

  • Encourage staff to report suspicious activities anonymously,
  • Ensure whistleblower protection.

8. Periodic Penetration Testing and System Audit

  • Test the integrity of core banking systems regularly,
  • Identify and patch security vulnerabilities.

Real-World Cases

  • Employees created millions of unauthorized accounts to meet sales targets.
  • Fraud of over $1.8 billion through unauthorized SWIFT transfers.
  • Hackers transferred $12 million after gaining access to SWIFT credentials (with suspected insider collusion).

ACTION

If you're a customer suspecting theft, take the following actions:
  • Report to the bank immediately in writing - detail the events as much as possible and attach any relevant documents
  • File a police report and Bank Negara (if in Malaysia) - ditto - 
Keep all documentation and get written acknowledgement from the bank.

APPLICABLE LAWS/REGULATIONS

  • Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA) - Applies when the money was diverted and later laundered through businesses, banking channels, or cross-border transactions. (e.g. Section 4),
  • Malaysian Anti-Corruption Commission Act 2009 (MACC Act) - applies when there is report, suspicion and prove of abuse of power, bribery, or collusion by government or bank officers in the diversion of the money. (e.g. Section 23),
  • Financial Services Act 2013 (FSA) - applies when the offense involves commercial banks or financial institutions regulated by Bank Negara Malaysia (BNM).
  • Penal Code (Act 574)
  • Communications and Multimedia Act 1998 (CMA) - applies when digital systems or networks were used to commit or conceal the crime.
SPECIAL NOTE : UNIQUE CASES YOU MANY NOT KNOW - DESTROYED MONEY THAT IS NOT DESTROYED

it is possible, though extremely rare and difficult to execute, for currency that is meant to be destroyed (burnt, shredded, or withdrawn from circulation) to be illegally diverted and laundered instead. This would typically involve high-level corruption, insider collusion, and breakdowns in oversight within central banks or cash-handling agencies.

1. Currency Destruction Process Manipulation

  • Central banks periodically remove old, damaged, or outdated notes from circulation,
  • These notes are supposed to be counted, verified, logged, and destroyed (burned or shredded),
  • Insiders could falsely record that the currency was destroyed, while actually diverting the physical notes.
2. Collusion Among Officials

This kind of fraud requires multiple layers of insider cooperation.

3. Laundering the “Destroyed” Money

The stolen, undeclared cash could then be laundered

PREVENTION

  • Central Bank Controls,
  • Serial number tracking of notes meant to be destroyed,
  • CCTV surveillance and biometric access to high-security cash destruction zones.
  • Random third-party inspections during destruction,
  • Use of automated machines that count and shred notes without human contact,
  • Auditing and Transparency,
  • Real-time logging and cross-verification by independent departments,
  • Forensic tracking of serial-number batches after destruction,
  • Audit trails retained for a mandatory period, often years.

Real-World Examples (or Similar Cases)

  • Some bank officers were caught trying to launder old currency meant to be surrendered and destroyed,
  • Allegations arose of old bills being recirculated or exchanged on the black market.
  • cases were reported of cash meant for destruction re-entering circulation via insider collusion.

Read More : 



#BankFraudAwareness, #CustomerProtection, #FinancialIntegrity, #InsiderThreat, #TrustInBanking



Friday, August 16, 2024

A BRIEF ON HOW TO DETECT FRAUD IN BANKING AND FINANCIAL SECTORS - Nik Zafri



Please also read my other articles about money laundering and anti-corruption.

Detecting fraud is usually linked money laundering, and corruption in the banking and financial sectors is crucial for maintaining the integrity of the financial system. there are strategies and technologies need to be taken into account.

1. Fraud Detection

a. Transaction Monitoring Systems (TMS)

These systems analyze transaction patterns in real-time or near real-time to detect suspicious activities. They use predefined rules, statistical models, and machine learning algorithms to flag anomalies. This will enable banks to proactively detect and investigate suspicious activities, helping to prevent them from escalating into more significant financial crimes. By identifying and halting illegal transactions early, banks can avoid potential losses and reduce the risk of regulatory scrutiny.

b. Anomaly Detection (AI)

Machine learning techniques (AI), such as supervised and unsupervised learning, are employed to detect deviations from typical behavior. These methods can identify unusual patterns that may indicate fraud. Machine learning models has proven effective in detecting anomalies by identifying unusual patterns in vast datasets. These AI models continuously learn from transaction data, adapting to emerging fraudulent schemes in real-time.

c. Behavioural Analytics

Sometimes, a user behaviour can also indicate fraudulent activity. These include frequent login times, transaction types, and sometimes at different locations and mixture of transactions (frequent use of cash deposit machine with significantly large amounts at different locations and online transfers/interbank transfer) 

d. Multi-factor Authentication (MFA)

Implementing MFA helps in preventing unauthorized access to banking systems, which is a common precursor to fraud. It can pose problems to the customers with too many authentications and verifications but it will protect both customers and bank from fraud and scamming. MFA adds an extra layer of security beyond just a password. Customers must provide two or more verification factors—such as something they know (a password), something they have (a smartphone or security token), or something they are (a fingerprint or facial recognition). This makes it much more difficult for unauthorized users to gain access, as even if they manage to obtain one factor, they would still need the additional factor(s) to successfully log in.

2. Money Laundering Detection (Anti-Money Laundering or AML)

a. Know Your Customer (KYC) and Customer Due Diligence (CDD)

KYC involves verifying the identity of customers, while CDD involves ongoing monitoring of their transactions to help identify potentially suspicious behavior linked to money laundering.

b. Suspicious Activity Reporting (SAR)

Banks are required to file SARs for any transactions that they suspect may involve money laundering. These reports are then reviewed by financial regulatory authorities such as Bank Negara.

c. Risk-Based Approach

Financial institutions categorize customers and transactions based on their risk level. Higher-risk transactions are monitored more closely to detect potential money laundering.

d. Transaction Structuring Detection

Money launderers often structure transactions in small amounts to avoid detection. Advanced algorithms can detect patterns of structuring across multiple accounts or over time.

e. Beneficial Ownership Identification

It's essential to determine the true owners behind complex corporate structures, as money launderers often hide behind layers of corporate entities.

3. Corruption Detection

a. Conflict of Interest Checks

Regular audits and checks can help identify situations where employees or executives of the bank might have conflicts of interest, potentially leading to corrupt activities via specific client favoritisms.

b. Vendor and Third-Party Risk Management

Financial institutions should monitor and evaluate the integrity of vendors and third-party relationships to detect corrupt practices, such as bribery or kickbacks.

c. Whistleblower Programs

Encouraging employees to report corrupt activities internally through protected channels can lead to the early detection of corruption.

d. Internal Audits and Controls

Regular internal audits can identify weaknesses in financial controls that could be exploited for corrupt purposes.

4. Technology and Data Analytics

a. Artificial Intelligence and Machine Learning:

AI and ML are increasingly used to detect complex fraud, money laundering, and corruption schemes. These technologies can analyze large datasets and identify patterns that humans might miss.

b. Blockchain Technology

Blockchain’s transparency and immutability make it a powerful tool in preventing fraud and money laundering, especially in tracking the provenance of funds.

c. Big Data Analytics

Analyzing vast amounts of structured and unstructured data helps in identifying suspicious activities across different systems and jurisdictions.

d. Network Analysis

Analyzing relationships between different entities (e.g., customers, accounts, transactions) can reveal hidden connections that may indicate fraudulent or corrupt activity.

5. Regulatory Compliance and Reporting

a. Regulatory Technology 

Regulatory Technology help financial institutions comply with regulatory requirements by automating the monitoring, reporting, and auditing processes.

b. Continuous Training and Awareness

Financial institutions must regularly train their employees on the latest fraud, AML, and anti-corruption techniques and regulations to ensure vigilance and compliance.

c. Collaboration with Law Enforcement

Financial institutions often work closely with law enforcement agencies such as Bank Negara Malaysia, Security Commission, the Police (PDRM), Company Commission etc. to share information and intelligence, helping to detect and prevent illicit activities.

6. Challenges and Emerging Threats

a. Cyber Fraud

As banking becomes increasingly digital, cyber fraud (e.g., phishing, hacking) poses a significant threat. Institutions must continuously update their cybersecurity measures.

b. Cross-Border Transactions

Detecting fraud and money laundering in cross-border transactions is challenging due to differing regulations and the complexity of tracking funds across multiple jurisdictions.

c. Cryptocurrency Risks

The rise of cryptocurrencies presents new challenges for detecting money laundering, as these digital assets offer a degree of anonymity and are harder to trace.

Conclusion

Detecting fraud, money laundering, and corruption requires a multi-faceted approach that combines advanced technology, strict regulatory compliance, and robust internal controls. As threats evolve, financial institutions must stay ahead by adopting innovative detection methods and continuously improving their risk management strategies.

Saturday, January 28, 2023

PART 2 - ANTI-BRIBERY MANAGEMENT SYSTEM - by Nik Zafri

Note : For all parters of my articles, I will not touch clause 2.0 and 3.0. The articles may follow the sequential order of the standard clauses or quoting certain paras/phrase from the standard but the contents are mostly self-explanation based on my understanding and experience. The contents may also be customized to the Malaysian environment with some references cited from international laws and case studies.

Scope

All documented information is recommended to use anti-bribery laws and voluntary commitments as their guidelines.

Among others, ISO 37001:2016 entails the need for detect, prevent and respond to many types of bribery. The scope involves personnel, associates, business activities, 3rd parties from public, private and not-for-profit sectors (example NGO). 

This means that it's not limited only to clients but also branching out to customers, JV, JV partners, consortium partners, outsourcing providers, contractors, consultants, sub-contractors, suppliers, vendors, advisors, agents, distributors, representatives, intermediaries and investors.

For public official, the system should also cover person holding a legislative, administrative or judicial office, whether by appointment, election or succession, or any person exercising a public function, including for a public agency or public enterprise, or any official or agent of a public domestic or international organization, or any candidate for public office.

These requirements are typically addressed in the Anti Bribery Management System (ABMS) Manual. 

Although the standard may not be thorough, to organizations practicing (corporate) governance especially Public and Public Listed Company, the manual and the associated procedures should include fraud, cartels, anti-trust/competition offences, money laundering etc.

However, this may require a joint effort between those in the financial positions and the duly authorized personnel from the management.

It is recommended the organization work closely to Bank Negara Malaysia, Security Commission, Registrar of Company/Society etc. for more information on legislation or conditions for public-listing/investment.